compliance teamDeposit and single-use plastic ignore the threshold
Step 1
Screen for deposit packaging
Step 2
Screen for single-use plastic
Step 3
Count units as well as weight
Step 4
Register from the first unit
| Control | Evidence to retain |
|---|---|
| Scope | Entity, product, channel, stream and source |
| External action | Version, date, authorised filer and issued receipt |
| Maintenance | Source data, approval, invoice and next deadline |
Outside the allowance
The 50,000 kg limit does not apply to packaging subject to a deposit obligation or to single-use plastic packaging. Those are registered and declared whatever the annual quantity.
A seller comfortably below the threshold on ordinary packaging can still owe money on this route.
The single-use plastic surcharge
For 2026 the producer organisation lists a surcharge of €2.10 per 1,000 units excluding VAT on drinking cups, drinks packaging, rigid and flexible food packaging and carrier bags under 50 micron.
It is charged in addition to the material tariff rather than instead of it, so a unit count is needed as well as a weight.
The rules are wider than packaging
The statutory basis for these litter costs sits in section 6a of the Besluit beheer verpakkingen 2014, and the underlying single-use plastics rules reach products such as wet wipes, balloons and cigarette filters.
Scope is confirmed by a person rather than inferred from a product name.
Conclusion
Scope comes before a form. Connect the legal entity, product, sales channel and EPR stream to the rule that actually applies.
Evidence must remain traceable. Keep source data, versions, approvals, filings, receipts and every record issued by an external body.
Third-party decisions are never guaranteed. CONAI, public registers, collective systems and marketplaces control their own procedures, timing and decisions.