EPR Obligations EU → 🇳🇱 Netherlands
EPR in the Netherlands 2026: Packaging, WEEE & Batteries
Verpact (formerly Afvalfonds), the 50,000 kg registration threshold, Stichting OPEN for WEEE and what foreign online sellers need to do.
Last reviewed: · Sources linked below
Short answer: packaging producer responsibility in the Netherlands is run by Verpact (formerly Afvalfonds Verpakkingen). You only need to register with Verpact if you place more than 50,000 kg of packaging per calendar year on the Dutch market. Electrical and electronic equipment is registered with Stichting OPEN in the national (W)EEE register — foreign sellers selling directly to Dutch end users count as producers. Batteries have their own producer responsibility scheme.
At a glance
- Packaging register / scheme
- Verpact (formerly Afvalfonds Verpakkingen); registration only above 50,000 kg of packaging per calendar year in NL.
- Authorised representative
- PPWR Art. 45 for distance sellers to end users. Verpact: EU-based companies not required to register do not need an AR for EPR purposes in NL. Non-EU: check your case.
- WEEE
- Stichting OPEN, national (W)EEE register; foreign sellers selling directly to Dutch end users are producers.
- Batteries
- Own producer responsibility scheme; we check the current registration route for you.
- Thresholds
- 50,000 kg/year for Verpact registration (so there is a de-minimis for registration).
- Penalties
- Statutory fine categories (from 1 Jan 2026: 4th €27,500 · 5th €110,000 · 6th €1,100,000) — assignment to EPR breaches not confirmed.
- Marketplace checks
- Amazon.nl EPR requirements since 18 Aug 2025 (industry reports); Amazon names NL in its EU packaging notice; eBay may hide listings.
- What changed in 2026
- PPWR applies since 12 Aug 2026; Verpact published guidance on who must register (17 Aug 2026).
- What changed in 2026
- Packaging (Verpact)
- WEEE (Stichting OPEN)
- Batteries
- Authorised representative
- Deadlines
- Penalties
- FAQ
Do I have to register in the Netherlands? Quick decision table
Whether you register with Verpact depends on your Dutch packaging volume; WEEE and batteries are separate questions.
| Your situation | Packaging (Verpact) | WEEE (Stichting OPEN) |
|---|---|---|
| More than 50,000 kg packaging per year in NL | Registration with Verpact required | Register if you sell EEE to Dutch end users |
| Up to 50,000 kg packaging per year in NL | No Verpact registration; PPWR packaging requirements still apply | Register if you sell EEE to Dutch end users |
| Online seller shipping to Dutch buyers from abroad | You are the producer in NL; apply the 50,000 kg test | Foreign sellers selling directly to Dutch end users are producers |
What changed in 2026
The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) has applied directly in the Netherlands and every other member state since 12 August 2026. It entered into force on 11 February 2025 and replaced most of the old Packaging Directive 94/62/EC, which was generally repealed on 12 August 2026 (some provisions continue). National registers and schemes still exist — the PPWR sits on top of them. Read the full overview on our PPWR 2026 page.
- Authorised representative (Art. 45): producers that sell packaged products directly to end users in another member state — whether established in the EU or outside it — must appoint an authorised representative in each member state where they first make packaging available, other than their own. For other non-EU producers, member states may require one.
- Pragmatic enforcement: the European Commission has asked member states to enforce the authorised-representative duty in a "constructive and pragmatic" way while an exemption is being negotiated.
- Penalties: member states must lay down their PPWR penalty rules by 12 February 2027 (Art. 68).
- Fees and labels: EU-harmonised fee modulation by recyclability grade is expected from around 2028–2030; harmonised packaging labelling applies from 12 August 2028 or 24 months after the implementing acts, which had not been adopted as of September 2026.
Proposal – not yet law EU omnibus and the AR exemption. The Environmental Omnibus (COM(2025) 982, 10 December 2025) proposes suspending the authorised-representative duty for EU-established producers. The European Parliament adopted its position on 20 October 2026 (exemption for EU micro and small enterprises until 2035, as reported). The Council agreed its negotiating position on 21 October 2026: EU-established producers placing less than 1 tonne of packaging per year in another member state would not need an authorised representative there, until 2032. Trilogue negotiations follow. This is not law yet, and it does not cover sellers established outside the EU.
Netherlands: Verpact's PPWR guidance
In its guidance of 17 August 2026, Verpact confirms that sellers on online platforms who sell packaged products to buyers in other EU countries are producers in the countries where their buyers are based, and must register in each of those countries. In the Netherlands, registration with Verpact is only required above 50,000 kg of packaging per calendar year. Verpact also notes that the authorised-representative requirement may be scrapped, with a final decision expected by the end of 2026 — until then, the PPWR text applies.
Packaging obligations in the Netherlands (Verpact)
Verpact is the EPR organisation for packaging in the Netherlands; it was formerly called Afvalfonds Verpakkingen. Producers that place more than 50,000 kg of packaging on the Dutch market per calendar year register with Verpact.
- Count your Dutch packaging. Add up the weight of all packaging you place on the Dutch market in a calendar year — typically product packaging plus the shipping boxes and fillers you send to Dutch customers.
- Above 50,000 kg: register with Verpact and follow its declaration and contribution rules.
- Up to 50,000 kg: no Verpact registration is needed, but the PPWR's rules on the packaging itself still apply, and you should keep your calculation documented.
- Check the representative question (see below) — especially if your company is established outside the EU.
- Keep marketplaces informed. Amazon and eBay ask for EPR information per country.
Correction to a common claim: it is not true that the Netherlands has "no de-minimis" for packaging. Registration with Verpact is only required above 50,000 kg per calendar year.
WEEE obligations in the Netherlands (Stichting OPEN)
Stichting OPEN registers producers of electrical and electronic equipment in the Dutch national (W)EEE register. Foreign sellers who sell EEE directly to Dutch end users are producers in the Netherlands and must register. Whether you register directly or through a representative depends on your set-up — we check this for you.
Battery obligations in the Netherlands
Batteries have their own producer responsibility scheme in the Netherlands, separate from packaging and WEEE. The registration route depends on the battery type and on how you sell — we check the current registration route for you.
On top of national rules, the EU Battery Regulation (EU) 2023/1542 has applied its extended producer responsibility regime since 18 August 2025. Further steps are scheduled from 18 February 2027: a QR code on all batteries, removability and replaceability rules, and a battery passport for EV, LMT and industrial batteries above 2 kWh. Battery due-diligence obligations have been postponed to 18 August 2027 (Regulation (EU) 2025/1561).
Proposal – not yet law The EU omnibus would also suspend the authorised-representative duty for batteries (European Parliament vote on 20 October 2026; Council position pending).
Authorised representative in the Netherlands
Under PPWR Art. 45, producers that sell packaged products directly to end users in another member state — EU or non-EU — generally need an authorised representative in that member state. For other non-EU producers, member states may require one.
For the Netherlands, Verpact states that EU-based companies that are not required to register with Verpact do not need an authorised representative for EPR purposes. Verpact does not address non-EU companies below the threshold, so non-EU sellers should check their case. The proposed EU exemption for small EU-established producers is not law yet and would not cover non-EU sellers. Background: authorised representative explained on register-epr.com.
How Certify helps
- Free obligation check. Tell us what you sell into the Netherlands, through which channels (Amazon, eBay, your own shop) and roughly in what volumes. We map which registers, schemes and representative duties apply to you.
- Registration and representation. Certify prepares the registrations and, where the law requires it, acts as your authorised representative. Certify offers an authorized representative in all EU member states.
- Ongoing compliance. Certify supports the recurring declarations and reports, so your registration numbers stay valid for marketplaces and authorities.
Deadlines for the Netherlands and the EU
The Dutch packaging threshold is assessed per calendar year; the EU dates below apply to everyone. Full calendar: EPR deadlines.
| Date | Scope | What happens |
|---|---|---|
| 18 Aug 2025 | Amazon.nl | EPR requirements for sellers (according to industry reports) |
| 1 Jan 2026 | Netherlands | New statutory fine category amounts apply |
| 12 Aug 2026 | EU | PPWR applies; authorised-representative duty for distance sellers (Art. 45) |
| 17 Aug 2026 | Netherlands | Verpact guidance on who must register under the PPWR |
| 20–21 Oct 2026 | EU | Parliament (20 Oct) and Council (21 Oct) positions on the AR exemption; trilogue next Proposal – not yet law |
| 12 Feb 2027 | EU | Member states must have PPWR penalty rules in place |
| 18 Feb 2027 | EU batteries | QR code on all batteries, removability rules, battery passport (EV, LMT, industrial >2 kWh) |
| 18 Aug 2027 | EU batteries | Battery due-diligence obligations start (postponed) |
| 12 Aug 2028 | EU | Harmonised packaging labelling (or 24 months after implementing acts) |
Penalties in the Netherlands
Dutch law sets fines in statutory categories; we have not found an official assignment of EPR breaches to a specific category, so we give the categories only as general context.
| Fine category | Maximum from 1 Jan 2026 |
|---|---|
| 4th category | €27,500 |
| 5th category | €110,000 |
| 6th category | €1,100,000 |
At EU level, member states must have PPWR penalty rules in place by 12 February 2027.
Marketplaces check EPR numbers. In its notice of 25 March 2026, Amazon announced packaging EPR compliance checks across the EU from 12 August 2026 and named the Netherlands among the countries concerned; Amazon "may need to stop selling your non-compliant products". eBay requires packaging EPR numbers from 12 August 2026 for each country in which the seller is a producer, and listings may be hidden from buyers in that country. According to industry reports, Amazon.nl has applied EPR requirements to sellers since 18 August 2025. See also our sister site's guide to the Amazon EPR number.
FAQ: EPR in the Netherlands
Do I need to register with Verpact?
Only if you place more than 50,000 kg of packaging on the Dutch market per calendar year. Verpact, formerly Afvalfonds Verpakkingen, is the EPR organisation for packaging in the Netherlands. Below that threshold, registration with Verpact is not required.
Is there a de-minimis threshold for packaging in the Netherlands?
Yes, for registration with Verpact: it is only required above 50,000 kg of packaging per calendar year placed on the Dutch market. The PPWR's requirements for the packaging itself apply regardless of volume.
Do I need an authorised representative in the Netherlands?
Under the PPWR, producers that sell packaged products directly to end users in another member state generally need an authorised representative there. Verpact states that EU-based companies that are not required to register with Verpact do not need an authorised representative for EPR purposes in the Netherlands. Non-EU sellers should check their case. A proposed EU exemption for small EU-established producers is not law yet.
Who handles WEEE registration in the Netherlands?
Stichting OPEN registers producers of electrical and electronic equipment in the national (W)EEE register. Foreign sellers who sell directly to Dutch end users are producers in the Netherlands.
How are batteries handled in the Netherlands?
Batteries have their own producer responsibility scheme in the Netherlands, separate from packaging and WEEE. We check the current registration route for you, because it depends on the battery type and how you sell.
What fines apply for EPR breaches in the Netherlands?
Dutch law groups fines into statutory categories. From 1 January 2026 the fourth category is 27,500 euros, the fifth 110,000 euros and the sixth 1,100,000 euros. Which category applies to a specific EPR breach depends on the offence; we have not found an official assignment of EPR breaches to a category.
Does Amazon check EPR compliance for the Netherlands?
Yes. According to industry reports, Amazon.nl has applied EPR requirements to sellers since 18 August 2025, and in its notice of 25 March 2026 Amazon named the Netherlands among the countries with packaging EPR compliance checks from 12 August 2026. Amazon may need to stop selling non-compliant products.
- Verpact: Do you need to register with Verpact? (PPWR situation)
- Business.gov.nl: Electrical and electronic equipment
- Regulation (EU) 2025/40 (PPWR) on EUR-Lex
- European Commission: EPR for packaging and small businesses
- Amazon Global Selling notice, 25 March 2026
This page is general information, not legal advice. Last reviewed 27 October 2026.
Other country guides
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