EPR in the Netherlands: the Verpact guide, and the 50,000 kg threshold

Who Verpact is

Verpact is the producer responsibility organisation for packaging in the Netherlands. It is the same body sellers used to know as Stichting Afvalfonds Verpakkingen: the foundation merged with its delivery organisations (Nedvang, Nederland Schoon and the packaging knowledge institute KIDV) into a single legal entity on 1 January 2024, and took the name Verpact on 1 March 2024. The Dutch deposit-return system, Statiegeld Nederland, sits under the same roof. Plenty of guides and forum answers still say Afvalfonds Verpakkingen, so treat the two names as the same scheme.

The law behind it is the Besluit beheer verpakkingen 2014, the Dutch packaging management decree, together with the extended producer responsibility rules that hang off it. Verpact collects the *afvalbeheersbijdrage*, the waste-management contribution, and uses it to fund collection and recycling. There is no separate licensing step the way Germany splits LUCID registration from a dual-system contract: in the Netherlands the registration, the declaration and the fee all run through Verpact.

Who has to register

The duty falls on the producer or importer, which in Dutch packaging law means whoever first makes packaging available on the Dutch market. That is usually the party that fills the packaging or the one that brings packaged goods into the country. Since 1 January 2023 it also explicitly catches the brand owner who commissions manufacture under its own label, so a private-label or store-brand arrangement does not push the duty onto your supplier.

The case that matters for a Shopify store is the one with no Dutch party in the chain at all. If you are established in the United States, the United Kingdom, Germany or anywhere else, and a Dutch consumer buys from your site and you ship the parcel to them, nobody in the Netherlands imported those goods. You did. The Dutch government's own business portal puts it plainly: the packaging rules apply if you are "a company in another country and sell directly (online) to Dutch consumers". See Business.gov.nl on the packaging waste management contribution.

The 50,000 kg threshold, precisely

This is the single most-searched fact about Dutch packaging EPR, and it is also the one people get wrong in both directions. The rule is that a producer or importer who places less than 50,000 kg of packaging on the Dutch market in a calendar year falls outside the notification duty in the packaging decree, and Verpact does not invoice the waste-management contribution below that line. Verpact states it directly: if you meet the threshold value you are required to file a declaration and in most cases you will pay the fee. Below it, you are not.

That is still the published position after 12 August 2026. Verpact's own PPWR guidance lists the 50,000 kg threshold among the things that are unchanged for 2026. Other sources now say the opposite, and the PPWR section further down sets out which of the two to work from.

How much packaging is 50,000 kg?

A lot. Fifty tonnes. At 100 grams of packaging per order, a fairly ordinary mailer and its contents, you would need half a million Dutch orders in a year to reach it. Almost every independent Shopify brand shipping to the Netherlands is far below this, and that is the honest answer most sellers are looking for. It is also why the Netherlands feels so much lighter than Germany, where VerpackG has no small-seller exemption at all and one parcel counts.

What the threshold does not do

Being under the line is not a blanket exemption from Dutch packaging law, and four things sit outside it:

• Single-use plastic packaging has no threshold. Packaging covered by the SUP rules, which is mainly food and drink packaging, beverage cups, and lightweight plastic carrier bags, is chargeable from the first kilogram. Verpact applies a separate SUP surcharge on top of the per-kilo material rate.
• Deposit packaging has no threshold. Drinks bottles and cans in the *statiegeld* system are handled through Statiegeld Nederland from the first unit.
• The threshold is measured across a Dutch VAT fiscal unity, not per entity. The decree removes the exemption where the producer is part of a Dutch VAT fiscal unity (fiscale eenheid) and that unity as a whole goes over 50,000 kg. Splitting one business into several selling entities inside the same fiscal unity does not create several allowances. It is the fiscal unity that aggregates, not any corporate group you happen to sit in.
• You still have to be able to prove where you sit. Nothing exempts you from knowing your own packaging weights. If Verpact or an authority asks why you never filed, "we are under the threshold" is only an answer if you can show the number.

One detail that works in your favour: reusable logistics aids such as pallets and crates that move up and down the supply chain do not count toward the threshold weight, so a business moving goods on pallets is not pushed over the line by them.

What it costs once you are over the line

Verpact resets its rates each year and publishes them per kilogram, per material, excluding VAT. These are the 2026 rates:

The shape of that table is the point. Cardboard is priced at less than two cents a kilo; plastic is priced at more than a euro, roughly seventy times higher. Verpact also runs a recyclate discount and a fee differentiation that lowers the plastic rate for packaging that is genuinely recyclable, so the headline plastic number is a ceiling rather than a fixed cost. Check the live figures on Verpact's rates page before you budget, and see what EPR actually costs across the EU for the wider picture.

How and when you report

Reporting runs on the calendar year. You register with Verpact first, then file a declaration of the quantity of packaging you placed on the Dutch market, broken down by material, for the year that has just ended. The filing window closes on 31 March, so the 2026 year is declared by 31 March 2027. Larger producers are asked to file interim declarations during the year rather than a single annual figure, and Verpact is moving filings from its old PackTool portal to a new one, so check which system you are being pointed at.

There is a second, less visible date. The producer organisation has to report to Rijkswaterstaat on how the sector met its recycling obligations before 1 August each year, covering the previous calendar year. If you file through Verpact, that report is made collectively and you do not deal with it separately, but it is why your March figures need to be right rather than approximately right.

Everything here depends on one number you probably do not have yet: the mass of packaging per material that you actually ship. Calculating packaging weight for EPR walks through getting it out of a Shopify catalogue rather than estimating it.

What changed on 12 August 2026, and what did not

The EU Packaging and Packaging Waste Regulation (PPWR) has applied since 12 August 2026, and it lands on top of the Dutch system rather than replacing it. Two things moved for a seller shipping into the Netherlands. First, the party that counts as the producer is now defined by PPWR rather than by the older Dutch producer or importer wording, and Verpact's own summary of the change says responsibility for reporting packaging released on import shifts largely to the foreign supplier or the logistics service provider. If you ship parcels into the Netherlands from outside it, that is you. Second, a producer not established in the Netherlands has to be represented locally, which is the next section.

What did not move is the 50,000 kg threshold. It is a national rule in the Dutch packaging decree, and it answers a different question from the producer definition. One asks who carries the Dutch obligation. The other asks at what volume Verpact wants a declaration and sends an invoice. PPWR settled the first. Verpact's PPWR guidance currently lists the second among the things that are unchanged for 2026.

You will read the opposite, often stated with more confidence than this paragraph. Several compliance vendors publish that from 12 August 2026 the Dutch threshold is gone for foreign sellers and that registration, reporting and fees start at the first kilogram. It is a coherent reading of where the regulation points, and the Netherlands may yet land there. It is not what Verpact publishes, so do not budget or plan on it as though it were settled.

Do you need an authorised representative in the Netherlands?

The Netherlands used to be more relaxed about this than France, where a *mandataire* has long been expected of foreign producers. Sellers outside the country could generally deal with Verpact themselves. Since 12 August 2026 PPWR has narrowed that discretion. A producer established elsewhere in the EU that places packaging on the Dutch market has to appoint a packaging authorised representative established in the Netherlands, on a written mandate, who registers, declares and pays on its behalf. For a producer based outside the EU, PPWR leaves the representative question to the Netherlands, so confirm your position with Verpact rather than assuming.

Read that carefully, because it is the sentence most often stretched into something it does not say. It settles who acts for you in the Netherlands and who carries the obligation. It does not set the volume at which Verpact invoices you. That is still the 50,000 kg question above, and the two are decided separately.

The trap is that this is per country, not per company. It is not one appointment for the EU. Ship to the Netherlands, Germany and France and that is three representatives, three registrations and three sets of declarations. Our guide to the packaging authorised representative covers the mandate, the timing, and why the December 2025 proposal to postpone it never applied to sellers established outside the EU in the first place.

The Netherlands next to Germany and France

If you already run LUCID and a dual system in Germany or Citeo and Triman in France, the Dutch scheme will feel like the same job with fewer moving parts and one large exemption bolted on the front. The work that carries across countries is the packaging data. The work that does not is every registration, every portal and every deadline.

What to actually do

1. Total your Dutch packaging by material for a full year, in kilograms, including outer carton, filler, tape and labels. Without this number nothing else in this guide is answerable.
2. Check whether any of it is SUP or deposit packaging. Food and drink packaging, beverage cups and light plastic carrier bags are chargeable from the first kilogram regardless of your total.
3. Compare your total to 50,000 kg. If your Dutch selling entities sit inside one Dutch VAT fiscal unity (fiscale eenheid), the decree measures the total across that unity rather than per entity. It is not a general rule across any corporate group. Write down the result with the date you calculated it. That record is your answer if anyone asks.
4. If you are over, register with Verpact and diarise 31 March for the declaration covering the previous calendar year.
5. If you are under, do not file it away as settled. Recheck annually, and if you are anywhere near the line, ask Verpact where you stand rather than taking a vendor summary of what PPWR did to the threshold.
6. If you are not established in the Netherlands, get your representative in place. That requirement has been live since 12 August 2026, so any gap is open now, and mandates and registrations take weeks.

How Assuro helps

Every question on this page reduces to knowing your packaging weight by material and knowing which countries you actually ship to. Assuro connects to your Shopify store, totals your packaging by material across the catalogue, and shows you where that total sits against country thresholds such as the Dutch 50,000 kg. It carries obligation data for six countries, Germany, France, the Netherlands, Austria, Italy and Spain, so it flags those of the six you sell into but have not registered for, and tracks the dates that go with them, including 31 March. It does not register you with Verpact, act as your representative, or file your declaration, and it links every flag to the rule behind it. Scanning your catalogue is free.

• Calculate your Dutch packaging weight per material for a full year
• Identify any single-use plastic or deposit packaging, which is chargeable from the first kilogram
• Compare the total to 50,000 kg, aggregated across a Dutch VAT fiscal unity (fiscale eenheid) where one applies rather than across your whole group, and record the result
• If you cross it, register with Verpact and file by 31 March each year
• If you are not established in the Netherlands, appoint a Dutch packaging authorised representative, required since 12 August 2026
• Take the threshold question from Verpact's own PPWR page, not from a vendor summary
• Confirm your specific position with Verpact rather than relying on a guide