What is Extended Producer Responsibility (EPR) in the Netherlands?
Overview of Dutch EPR Legislation
The Dutch Extended Producer Responsibility (EPR) framework, managed by Verpact (formerly Afvalfonds Verpakkingen), is mandatory for all businesses placing packaging on the Dutch market. In effect since January 1, 2023, the system requires companies to pay a Packaging Waste Management Contribution.
You are obligated to register if your company places more than 50,000 kilograms of packaging annually on the market. However, compliance is also required—regardless of weight—if you place beverage cans, plastic soft drink or water bottles, or Single-Use Plastic (SUP) packaging on the market.
Get access to our comprehensive EPR guide for NetherlandsBenefits for Businesses and the Environment
The Dutch EPR system supports the prevention, collection, and recycling of packaging waste, encouraging the use of recyclable and reusable materials.
From a business perspective, EPR compliance can offer financial advantages—especially for exporters. If you export products purchased from a Dutch supplier, or if your Dutch customers export the packaged goods, you may be eligible to reclaim the Packaging Waste Contribution, provided the 50,000 kg threshold is met and proof of prior payment is submitted.
Additionally, direct exports are excluded from your declaration, helping reduce your total contribution.
Get access to our comprehensive EPR guide for NetherlandsWhat qualifies as packaging:
- Sales Packaging (Primary) – Directly contains the product
- Grouped Packaging (Secondary) – Bundles multiple units for sale or transport
- Transport Packaging (Tertiary) – Used for handling and shipping
- Composite Packaging – Made of multiple, inseparable materials
- Point of Sale Packaging – Items such as bags, sachets, and cups used at the point of purchase
Reusable Packaging is also included and refers to packaging designed to be refilled or reused for the same purpose across multiple trips during its lifespan.
Special obligations apply to certain packaging types—such as beverage cans, plastic drink/water bottles, and Single-Use Plastics (SUP)—regardless of the total weight placed on the market.
Exempted items include: hypodermic syringes, non-refillable lighters, pens, correction rollers, toner/ink cartridges, and small envelopes for confidential correspondence. Additionally, packaging used exclusively for export is excluded from the declaration.
Get access to our comprehensive EPR guide for NetherlandsSpecial Requirements for Single-Use Plastic (SUP) Packaging
Single-Use Plastic (SUP) packaging is subject to stricter and more specific rules within the Dutch EPR system.
Crucially, SUP packaging triggers compliance obligations regardless of the 50,000 kg annual threshold—meaning even small volumes place your business within the regulatory scope.
As of 2022, businesses handling SUP packaging must:
- Register with Verpact, regardless of the total packaging weight
- Submit a dedicated SUP declaration that includes quantity and weight of SUP packaging and number of plastic-containing disposable units per category
These requirements ensure that SUP packaging is comprehensively monitored and reported within the EPR framework.
Get access to our comprehensive EPR guide for NetherlandsWho Must Register for EPR in Netherlands?
You are required to register with Verpact if:
- You are a producer or importer of packaging and place more than 50,000 kilograms of packaging on the Dutch market annually.
- You market beverage cans, plastic soft drink bottles, plastic water bottles, or Single-Use Plastic (SUP) packaging, even if your total packaging is below 50,000 kilograms per year.
These conditions apply to both domestic and foreign businesses placing packaged products on the Dutch market, either directly or via distance selling.
Get access to our comprehensive EPR guide for NetherlandsRegistration with Verpact
Registration with Verpact is mandatory if you meet any of the following criteria:
- You place more than 50,000 kilograms of packaging on the Dutch market annually.
- You handle Deposit Refund System Packaging, such as plastic deposit bottles or metal beverage cans.
- You deal with Single-Use Plastic (SUP) packaging—regardless of total weight.
By April 1st each year, you must submit a declaration to Verpact detailing:
- The types, quantities, and weights of packaging introduced into the market.
- Specific, itemized reporting for Plastic Drink Bottles, Metal Drink Packaging, and SUP packaging.
This declaration determines your Packaging Waste Management Contribution, which must be paid accordingly.
Get access to our comprehensive EPR guide for NetherlandsData Management and Record-Keeping
Accurate data collection and record-keeping are essential. You’re required to:
- Maintain a detailed administration of your packaging activities for seven calendar years.
- Track material types, quantities, and weights for all packaging placed on the market.
Special Requirements:
- Composite Packaging: Report the weight of each material component separately.
- Reusable Packaging: Report the total weight multiplied by the number of trips.
- Deposit Packaging: Include weight and quantity (especially for metal).
- SUP Packaging: Provide detailed data per category, including the number of disposable plastic units, quantity, and weight.
Complying with these requirements ensures that your business meets Dutch EPR obligations and avoids potential non-compliance penalties.
Get access to our comprehensive EPR guide for NetherlandsCommon EPR Compliance Challenges in Netherlands
Complying with Dutch EPR requirements presents several challenges for producers and importers. A major hurdle is interpreting complex packaging definitions—such as Sales, Grouped, Transport, Composite, and SUP (Single-Use Plastic) packaging—and determining which items are exempt. Maintaining accurate records is essential: packaging data, including materials, weights, quantities, and reuse metrics, must be documented and preserved for seven years.
Submitting the annual declaration to Afvalfonds Verpakkingen by April 1st also requires precision, especially with levy-free thresholds, indirect exports, and category-specific rules. Special attention is needed for SUP packaging, drink containers, and reusable items due to their unique reporting requirements.
Keeping up with evolving regulations, including updates to fees and definitions, is vital. Importantly, even businesses below the 50,000 kg threshold must register if they place SUP or deposit packaging on the market. Errors or incomplete submissions may lead to assessments or fines, making compliance a continuous and detailed process.
Get access to our comprehensive EPR guide for NetherlandsFrequently Asked Questions About EPR Netherlands
Do I need an authorized representative?
No, an authorized representative is not explicitly required for foreign companies. The policy defines a “Producer or Importer” as any individual or legal entity established in the Netherlands that places packaging on the Dutch market—or any entity, including those established abroad, that sells packaged products directly to Dutch consumers via distance selling (e.g., e-commerce).
Get access to our comprehensive EPR guide for NetherlandsWhat happens if I miss the declaration deadline?
The annual declaration to Afvalfonds Verpakkingen must be submitted by April 1st of the following year. Late, incomplete, or incorrect declarations may result in additional assessments and fines. Afvalfonds can audit declarations for up to five years post-submission. In case of non-compliance, they may issue a notional (estimated) declaration. Deadline extensions are only granted under exceptional circumstances and must be requested in writing at least three working days before April 1st.
Get access to our comprehensive EPR guide for NetherlandsCan I register for multiple packaging categories together?
Yes. Registration is based on the entity, not by category. If your company places more than 50,000 kg of packaging on the market annually—or handles Deposit Refund System or SUP (Single-Use Plastic) packaging—you are obligated to register. The annual declaration requires reporting by material type and category (e.g., plastic, metal, glass), but a single registration covers all applicable packaging types placed on the market by your entity.
Get access to our comprehensive EPR guide for NetherlandsHow do I calculate my packaging volumes?
You must track and record the types, quantities, and weights of all packaging placed on the market.
- Composite packaging: Declare weights of each material separately.
- Reusable packaging: Declare weight × number of trips.
- Plastic drink bottles & metal drink packaging: Declare weight and quantity (for metal).
- SUP packaging: Report the number of plastic-containing disposable units per category, along with quantity and weight.
All data must be documented and retained for seven years. These records are critical for assessing whether your company meets the registration threshold and for completing the annual declaration.
Get access to our comprehensive EPR guide for NetherlandsWhat are the penalties for non-compliance?
Failure to comply—whether through non-declaration, late submission, or incorrect reporting—can result in:
- Additional assessments imposed by Afvalfonds
- Fines, as outlined in Annex 3 of the ABBO
- Estimated declarations if proper records are unavailable
Afvalfonds can conduct audits for up to five years after the initial submission. You may submit an objection within four weeks of receiving an assessment or fine.
Get access to our comprehensive EPR guide for NetherlandsHow often do the regulations change?
The regulations are updated periodically. The current policy framework took effect on January 1, 2023, introducing changes such as revised definitions, updated fees, SUP packaging obligations, and reuse schemes. Afvalfonds Verpakkingen may amend the policy as needed.
Additionally, annual updates to fees and sector-specific agreements are common. Businesses must stay informed and adapt to any regulatory changes to remain compliant.
Get access to our comprehensive EPR guide for NetherlandsGet Expert Help with Your EPR Registration
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