Registering for packaging EPR in the Netherlands yourself — the 50,000 kg exemption, Verpact and what a foreign seller actually owes

Does this apply to you

Rijkswaterstaat, the agency that administers Dutch extended producer responsibility, puts the test in one sentence: if you offer packaging on the Dutch market professionally, you are a producent and must meet the obligations — and “the sales technique used is not relevant, offering online is also covered”.

Its list of producer categories under the Besluit beheer verpakkingen includes, as its own entry, the party that “professionally sells products in packaging from abroad to consumers in the Netherlands”. The agency's glossary spells the same category out: parties established outside the Netherlands that offer packaged products directly to end users in the Netherlands, where the sale therefore takes place by means of distance contracts.

So a seller shipping into the Netherlands from anywhere, on a marketplace or their own shop, is the Dutch producer for that packaging. Sending it through a fulfilment warehouse does not move the obligation; selling to a Dutch business that resells does, because then that business is the one first placing the goods on the market.

Packaging here means all three layers, and the agency lists them explicitly: the sales packaging around the product, the grouped packaging that holds several units, and the shipping packaging — “cardboard shipping boxes, or plastic bubble wrap or strapping”. A seller who buys plain cartons and tape is placing packaging on the market.

The steps

Work out where you fall first, because the answer changes what the rest of this page asks of you.

1 · Work out whether the 50,000 kg exemption applies to you

Rijkswaterstaat states it twice, once for money and once for paperwork. On money: “producers that place 50,000 kg or less of packaging on the market per year are exempt from paying a waste management contribution to the producer organisation”. On paperwork: producers at or under that line “are exempt from the notification obligation and the reporting obligation”.

Then the carve-out, which is where most cross-border sellers actually land: the exemption does not apply to producers of single-use plastic packaging. Producers offering 50,000 kg or less of those items still pay a contribution, and the producer organisation must still notify and report them. The decree separates that group out in Article 15a and the agency lists what is in it: food packaging, drinks packaging and drinks bottles up to three litres, drinking cups, and sachets and wrappers. It covers both consumer and business packaging.

The practical consequence for a small seller: a shop shipping goods in cardboard and paper tape may genuinely be under the line and owe nothing but existence. A shop shipping anything in plastic film, pouches or single-use plastic food or drink packaging is not exempt at any volume.

2 · Register with Verpact — that is what puts you in the system

There is no producer portal you register in yourself. Rijkswaterstaat's page is headed “Registering with Verpact is compulsory”: a generally binding declaration (algemeen verbindend verklaring, AVV) has been issued for the producer organisation Verpact, formerly Afvalfonds Verpakkingen, which means Verpact collectively discharges the extended producer responsibility obligations on behalf of you and the other producers, and you pay it a waste management contribution for doing so. The current AVV runs from 1 January 2023 to 31 December 2027.

The mechanism the agency describes then runs one way: “The producer organisation makes the notification to Rijkswaterstaat on your behalf,” stating among other things the type and quantity of packaging it expects to be placed on the market. It has six weeks to do so, counted from the day the rules start applying to you — “so make sure you register with the producer organisation as soon as you are new on the market”. Changes have to be notified within six weeks as well.

What that means concretely: your deadline is not the government's six weeks, it is however long before that Verpact needs you to have signed up and given it your numbers. Ask them what the procedure is and what information they need, which is exactly what the agency tells you to do.

3 · If you are established outside the Netherlands: what is and is not required

Here is the honest state of the Dutch position, which is not the same as its neighbours'. The Rijkswaterstaat pages we could read set out the producer definition that captures foreign distance sellers, and the registration route through Verpact — but they do not state a Dutch national requirement to appoint an authorised representative, in the way the German, Austrian and Spanish authorities do on their own pages. We are not going to infer one for you.

What that leaves standing is the EU floor. Under Article 45(3) of Regulation (EU) 2025/40, a producer established in one Member State who first supplies packaged products directly to end users in another must appoint an authorised representative in that other Member State from 12 August 2026 — that is EU law and applies to the Netherlands whatever the national page says. Whether the Netherlands has taken up the separate option to extend that requirement to producers established in third countries is something we could not establish from an official page on the date shown, so we leave it open rather than fill it in. The safe reading for a seller outside the EU: you are a Dutch producer, you must be in the system through Verpact, and you should ask Verpact and Rijkswaterstaat in writing whether they require a representative for your establishment country before assuming either answer.

4 · Report your kilograms, and check the deposit obligations

Reporting follows the same pattern as notification: the producer organisation files the annual report on compliance with Rijkswaterstaat, and must do so before 1 August each year, for the preceding calendar year; it also publishes a public report. Producers at or under 50,000 kg are exempt from the reporting obligation — again, except for single-use plastic packaging, whose results the organisation must include regardless of volume. Your own obligation is to give Verpact accurate weights by material on its cycle.

The deposit-return system is a separate obligation that catches sellers by surprise, because it is charged at the till rather than by weight. Producers must charge a deposit on metal drinks packaging up to three litres and on plastic bottles up to three litres for water or soft drinks — note the narrowness: for plastic bottles it is only water and soft drinks, so fruit juice, squash, dairy drinks and alcohol are out; for metal it is only drinks cans, but there it does include soft drinks, juice and alcohol. The statutory minimums are €0.15 on metal drinks packaging and on small plastic bottles under one litre, and €0.25 on plastic bottles from one to three litres. The words Statiegeldfles on plastic bottles and Statiegeld on metal drinks packaging must be applied clearly and indelibly at a minimum type size of 1.2 millimetres, and the producer organisation additionally requires its own deposit logo.

The producer organisation

There is nothing to shop for, and that is the honest answer rather than a gap in this page. Where Germany has ten competing dual systems and Austria six licensed ones, the Netherlands has a single producer organisation with a generally binding declaration: Verpact, formerly Afvalfonds Verpakkingen. Rijkswaterstaat names it as the organisation whose AVV makes it collectively responsible, and points producers at it directly.

What the AVV covers is worth knowing before you sign, because it adds obligations on top of the statutory ones: the agency describes it as setting out how the organisation collectively meets the statutory duties, the tasks and responsibilities of both the organisation and you as a producer, how it informs producers about target results, the level of the waste management contribution and how producers pay it, and how the money collected is spent. The declaration itself is published, and linked under Sources.

The practical questions to put to Verpact when you sign up are therefore not “which one” but “what exactly”: which material categories your packaging falls into for tariff purposes, what evidence they need for the 50,000 kg line, how they treat shipping packaging you buy rather than manufacture, and what their declaration cycle and correction procedure look like.

Reporting: what you file and when

Almost none of it goes to the government directly, which is the point most guides get wrong when they describe a “Dutch EPR filing”.

• Verpact → Rijkswaterstaat, notification: within six weeks of the rules starting to apply to you, and within six weeks of any change.
• Verpact → Rijkswaterstaat, annual report: before 1 August each year, covering the previous calendar year, plus a public report.
• You → Verpact: your weights by material, on the organisation's cycle, through its declaration portal.
• Collectors and processors → the producer organisation: before 1 April each year, electronically, on the business packaging waste they received — origin, date, usual material name, quantity, and how it was recovered or disposed of. You are not in this loop, but it is why your declared figures are checkable against someone else's.

The obligations are set out across the AVV, the Besluit beheer verpakkingen 2014, the Besluit regeling uitgebreide producentenverantwoordelijkheid, the Regeling beheer verpakkingen and the Regeling verslaglegging verpakkingen; the decrees are linked under Sources.

When you actually need a provider

The Dutch structure removes most of the work a compliance provider sells elsewhere, because the producer organisation is already doing the government-facing part.

• You do not need a provider to file anything with Rijkswaterstaat. Verpact does the notification and the annual report. A quote that prices “Dutch EPR registration and filing” as separate labour is pricing something the AVV already assigns to the organisation you are paying.
• You do not need one to join Verpact. Signing up is a direct commercial relationship.
• Judgement calls worth paying for are real but narrow: deciding whether an item is single-use plastic packaging in the sense of Article 15a, which decides whether the 50,000 kg exemption survives; weighing and classifying a mixed catalogue by material; and working out whether your drinks packaging falls inside the deposit scope, where the plastic and metal rules deliberately differ.
• You may need someone in the Netherlands if it turns out a representative is required for your establishment country — see step 3, which we have marked as unverified rather than guessed.

We have no commercial relationship with Verpact or with any compliance provider, and we take no referral fees.

What it costs

The Dutch contribution is published per kilogram by material, so it can be estimated before you sign anything.

• Waste management contribution — per kilogram, by material, with plastic split into rigid and flexible since 2024. Every row on this site carries its source document and the date we verified it: the paper and cardboard row, the rigid plastic row and the glass row are the three most sellers need; the full table has the rest, including the single-use plastic surcharge and the recycled-content and mono-material discounts.
• Nothing at all — if you are at or under 50,000 kg a year and none of your packaging is single-use plastic. That is a genuine outcome in the Netherlands, and it is worth checking before you buy anything.
• Deposits — not a fee to anyone, but working capital: you charge the consumer and settle through the system, and the minimum amounts are fixed by law.

If you want to see what a country with a threshold that only simplifies your paperwork looks like by contrast, our Spanish registration guide covers a regime with no exemption line at all.