Foreign direct seller → Dutch end user
A non-Netherlands business sells packaged goods directly to an end user in the Netherlands.
Assess PPWR Producer status, current Verpact registration trigger and the Article 45(3) representation layer.Netherlands Packaging EPR · PPWR 2026
Netherlands packaging EPR — Verpact, Article 45 representation, 2026 tariffs and Statiegeld
The Netherlands already runs a mature collective packaging-EPR system through Verpact. PPWR changes who can become the Producer and adds an Article 44 register and Article 45 representation layer, while current Dutch thresholds, SUP, deposit-return and a temporary stand-still for certain packaging categories continue to matter operationally.
Regulatory review · 6 September 2026
01
Who is the Dutch packaging EPR Producer?
Start with the real transaction and packaging type. PPWR can shift the Producer role country by country; Verpact has temporarily paused the new allocation for shipping, service and primary-production packaging.
Dutch importer / first placer
A Netherlands-established business imports or first makes the packaged product available on the Dutch market.
The Dutch business may carry the current producer/importer duties for that transaction.Shipping / service / primary-production packaging
PPWR changes responsibility for certain empty packaging categories, but Dutch implementation is currently paused by Verpact.
Use the pre-12-August-2026 Dutch practice for now and flag the account TRANSITIONAL because later clarification may be retroactive.TRANSITIONAL · VERPACT STAND-STILL
For shipping, service and primary-production packaging, Verpact currently asks companies to keep using the pre-12-August-2026 Dutch producer allocation while clarification is pending; later clarification may affect periods from 12 August 2026.
02
Article 45(3) is binding, but the Dutch operating route is transitional.
PPWR Article 45(3) creates the EPR authorised-representative layer for cross-border Producers. A separate EU proposal would suspend that appointment rule, but procedure 2025/0395/COD is still ongoing. Verpact's current Dutch guidance also ties ordinary-route registration and EPR representation to the 50,000 kg trigger for foreign EU companies, while non-EU onboarding remains case-sensitive.
Do not call the proposal law
The Article 45 suspension proposal is ongoing, not adopted. The binding PPWR text remains the legal starting point.
Current Verpact guidance
For the ordinary route, Verpact says foreign EU companies that do not currently need to register also do not need an EPR representative.
SUP / DRS are separate
The ordinary 50,000 kg rule does not remove SUP or statutory deposit-return obligations. Registration can still be triggered from the first relevant unit.
Article 17 is different
The manufacturer's authorised representative handles product-conformity representation; it is not the Article 45 EPR representative.
2025/0395/COD · ONGOING
Beyoğlu should classify the Dutch EPR-AR route as TRANSITIONAL / VERIFY CASE-BY-CASE until the Article 45 legislative proposal and Verpact's final PPWR onboarding practice are settled. Never promise an automatic AR outcome from volume alone.
03
Verpact is operational; the PPWR Article 44 register is a separate future layer.
Current declarations run through Verpact. Packtool is being migrated to VerpactPortal. Separately, PPWR requires a producer register by 12 August 2027; Verpact says it will handle registration/reporting for affiliated producers when that register exists.
Collective packaging EPR administration and annual declaration
Packtool is migrating to VerpactPortal during 2026
The PPWR producer register is not yet the current Dutch operating register
- 01
Resolve Producer + packaging category
Separate ordinary packaging from SUP, statutory deposit-return packaging and paused shipping/service/primary-production categories.
- 02
Apply the current Dutch trigger
For ordinary packaging, document the 50,000 kg position. SUP and statutory DRS are not protected by that threshold.
- 03
Register with Verpact when required
Use the appropriate Netherlands / Europe / non-Europe onboarding route and record the current representative determination.
- 04
Operate the active portal
Follow the Packtool → VerpactPortal migration instructions and preserve both old/new relation identifiers where applicable.
- 05
Prepare for Article 44
Maintain more granular packaging data now; the producer register is due by 12 August 2027 and first reporting is expected for 2028.
Three numbers have different meanings. The current 50,000 kg Dutch heffingsvrije drempel reduces the ordinary contribution base pro rata and does not apply to SUP or statutory DRS. PPWR Article 44's <10,000 kg rule is simplified register reporting, not an EPR exemption. Do not merge them.
04
One Verpact group, several operational money and reporting layers.
Verpact operates the collective packaging-EPR structure and Statiegeld Nederland sits within the Verpact group, but ordinary packaging fees, SUP charges, producer contributions, system fees and refundable deposits must still be calculated separately.
Verpact
Collective Dutch packaging EPR, annual declarations, material tariffs and packaging administration.
Statiegeld Nederland
Statutory deposit-return for qualifying plastic bottles and beverage cans, with separate producer, system and deposit components.
VerpactPortal
Packtool is being replaced in a phased 2026 migration. A new relation number is issued and historical data before 2025 is not fully moved.
Organisational integration does not mean financial aggregation. Keep Verpact material contribution, SUP surcharge, Statiegeld producer contribution, system contribution and refundable deposit as separate ledger lines.
Statiegeld 2026
€0.014small bottle producer contribution / unit
€0.016large bottle producer contribution / unit
€0.010can producer contribution / unit
€0.015/kgsystem contribution
Statutory deposit and covered SUP obligations do not use the ordinary 50,000 kg threshold. Deposits are refundable supply-chain cash, not Beyoğlu revenue.
05
Use the official 2026 rate tables — but classify before multiplying.
Regular 2026 material rates are public and binding within the current Verpact framework. A much lower official business-packer table also exists, but its eligibility must be verified before use. The public calculator therefore uses regular rates and exposes only a manual verified discount field.
Regular materials
2026 rates include €0.100/kg glass, €0.017 paper/cardboard, €1.220 rigid plastic, €1.320 flexible plastic, €0.340 aluminium and €0.920 beverage cartons.
SUP
Covered SUP packaging pays the material tariff plus €2.10 per 1,000 units. SUP sits outside the 50,000 kg heffingsvrije drempel.
Plastic eco-modulation
Tariefdifferentiatie Plastic 2.0 can reduce eligible plastic fees by up to €0.60/kg, but only verified client-specific eligibility should be applied.
Reusable pool
First pool additions use the €0.015/kg system rate; recurring cycles are still reported but carry no repeat tariff under the current model.
Statiegeld
2026 producer contributions are €0.014 small bottle, €0.016 large bottle and €0.010 can per unit; system contribution is €0.015/kg and deposits remain separate refundable cash.
Beyoğlu
Country activation is €25 + VAT once and qualifying declared parcels are €1 + VAT each. Regulatory money is never merged into service revenue.
Verpact · regular 2026 rates · €/kg ex VAT
| Material | 2026 rate |
|---|---|
| Glass | €0.100 |
| Paper & cardboard | €0.017 |
| Plastic · rigid | €1.220 |
| Plastic · flexible / unspecified | €1.320 |
| Aluminium | €0.340 |
| Other metals | €0.360 |
| Wood | €0.015 |
| Beverage cartons | €0.920 |
| Reusable · first pool addition | €0.015 |
| Reusable drinking cups | €0.280 |
| Other materials | €0.015 |
Bedrijfsverpakkers · official reference table
| Material | 2026 rate |
|---|---|
| Glass | €0.0303 |
| Paper & cardboard | €0.0154 |
| Plastic · rigid | €0.2319 |
| Plastic · flexible / unspecified | €0.2499 |
| Aluminium | €0.0735 |
| Other metals | €0.0771 |
| Wood | €0.0150 |
| Other materials | €0.0150 |
An official lower reference table exists for qualifying bedrijfsverpakkers. Eligibility must be verified for the specific company before using it; the public calculator therefore defaults to regular rates.
06
Netherlands packaging EPR + SUP + Statiegeld planning calculator
Enter ordinary packaging kilograms separately from SUP and deposit-return packaging. The calculator applies the Dutch 50,000 kg ordinary threshold as a pro-rata reduction, uses verified 2026 regular rates, and keeps refundable deposits and Beyoğlu service fees separate.
07
Keep declaration, payment, portal and future Article 44 calendars distinct.
The current Verpact cycle remains operational while PPWR register reporting is being built. Save the rule version and portal state used for each period.
Maintain material-level administration and submit the annual declaration within the current Verpact operating cycle after year-end.
Quantity and, where required, unit reporting continues without the ordinary 50,000 kg threshold.
Follow the issued migration timing; retain evidence of relation-number change and export older Packtool data where needed.
Register/report through the Article 44 layer when established. First reporting is currently expected for 2028, due before 1 June 2029.
08
What Beyoğlu coordinates
- Determine the client-specific Producer and Article 45 EPR-representation route from actual sales facts.
- Separate ordinary, SUP, Statiegeld, reusable and transitional shipping/service packaging data.
- Prepare Verpact onboarding/declaration data and maintain portal-transition evidence.
- Apply only verified current tariffs, discounts and third-party quotes; version the calculation date.
- Maintain the Netherlands evidence pack, reporting calendar, funding view and marketplace-ready proof.
09
What remains with the seller / Producer
- Provide complete legal-entity, establishment, sales-chain and Dutch customer facts.
- Maintain packaging composition, weights, SKU mapping, SUP/DRS status and reusable-pool evidence.
- Provide actual volumes and correct errors before filing; preserve source commerce/shipment records.
- Fund Verpact, DRS, EPR-AR and other regulatory cash when due; deposits remain separate cash flow.
- Retain technical PPWR conformity evidence separately from EPR registration and representation evidence.
10
Build evidence that reconstructs the Dutch route years later.
A marketplace screenshot or Verpact relation number alone is not the whole compliance file. Preserve the decision, data, tariff version, filing and payment evidence behind it.
01
Producer determination and establishment / end-user route record.
02
Article 45(3) EPR-authorised-representative analysis, mandate if applicable, and current Verpact confirmation where the route is transitional.
03
50,000 kg ordinary-threshold calculation and pro-rata reduction working paper; separate SUP/DRS quantities.
04
Verpact registration / relation number / portal migration evidence and annual declaration acknowledgement.
05
Material-by-material packaging weights, SKU mapping and business-packer classification evidence if that lower table is used.
06
Tariefdifferentiatie Plastic approval / Recyclecheck and recyclate evidence where a discount is claimed.
07
Statiegeld product/system records, producer contributions, deposit invoices and payment proof where applicable.
08
Reusable-pool documentation distinguishing first additions from recurring cycles.
09
Invoices, credit notes, payments and any indirect-export refund evidence.
10
Source snapshot / verification date for every material legal or tariff assumption.
Do not invent a Dutch Article 44 registration number before that register exists. Give marketplaces the real current Verpact/DRS/representative evidence they request, and label transitional status accurately.
11
Primary and operator sources
Source hierarchy: binding EU law → Dutch law / official publication → RVO → Verpact / Statiegeld operational sources. The current Article 45 proposal is tracked separately as an ongoing legislative procedure.
Regulation (EU) 2025/40 (PPWR)verified · 2026-09-06
Open source ↗EUR-Lex · procedure 2025/0395/COD · Article 45 EPR-AR suspension proposalverified · 2026-09-06
Open source ↗Besluit beheer verpakkingen 2014verified · 2026-09-06
Open source ↗Staatscourant 2022, 35473 · Afvalbeheerbijdrageovereenkomst Verpakkingen 2023–2027verified · 2026-09-06
Open source ↗Verpact · Tarieven 2026verified · 2026-09-06
Open source ↗Verpact · Alles over de PPWRverified · 2026-09-06
Open source ↗Verpact · Belangrijke veranderingen binnen de PPWRverified · 2026-09-06
Open source ↗Verpact · Moet je je aanmelden bij Verpact? Dit speelt er sinds de PPWRverified · 2026-09-06
Open source ↗Verpact · Administratie / PPWR producer-register transitionverified · 2026-09-06
Open source ↗Verpact · Packtool wordt VerpactPortalverified · 2026-09-06
Open source ↗Verpact · Statiegeld tarieven 2026verified · 2026-09-06
Open source ↗RVO · EU-wetgeving: verpakkingseisen (PPWR)verified · 2026-09-06
Open source ↗12
Netherlands packaging EPR FAQ
Is 50,000 kg a PPWR exemption in the Netherlands?
No. It is the current Dutch heffingsvrije drempel for the ordinary contribution route. SUP and statutory DRS sit outside it, and the future Article 44 register has a different <10,000 kg simplified-reporting rule.
If I place 80,000 kg of ordinary packaging, do I pay on all 80,000 kg?
Under the current Verpact method, the ordinary contribution is reduced by the first 50,000 kg pro rata across the material mix. The remaining ordinary base is charged at the applicable rates.
Is the PPWR Article 45 EPR representative requirement suspended?
No. A proposal to suspend it is still in the EU legislative process (2025/0395/COD). Do not treat a proposal as adopted law.
Why is the Dutch AR route marked transitional?
Because Article 45 remains binding while Verpact's current ordinary-route guidance ties EU-foreign representation to current registration, non-EU onboarding differs, and the EU suspension proposal is still unresolved. The specific case must be verified.
What did Verpact pause?
Verpact temporarily asks companies to keep using the existing Dutch practice for shipping, service and primary-production packaging while the PPWR interpretation is clarified. Later clarification may have retroactive effect to 12 August 2026.
Can I use the lower business-packer rates automatically?
No. Verpact publishes the lower table, but eligibility must be established for the specific company. The public calculator uses regular rates unless verified evidence supports a different treatment.
Are Statiegeld deposits a Beyoğlu fee?
No. Deposits are refundable supply-chain cash and must remain separate from producer/system fees and from Beyoğlu service revenue.
Build the Netherlands route from the transaction — then lock the evidence.
Use Producer → Article 45 analysis → Verpact → SUP / Statiegeld → reporting → funding → evidence. Keep the 50,000 kg current Dutch rule, the <10,000 kg Article 44 simplified-reporting rule and the temporary Verpact stand-still as three separate concepts.