compliance teamWhat PPWR changed on 12 August 2026
Step 1
Check the producer profile
Step 2
Assess Article 45(3)
Step 3
Record the mandate
Step 4
Review before each year
| 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 |
What applies now
Regulation (EU) 2025/40 has applied since 12 August 2026 under its Article 71.
Article 45(3) currently requires a producer established in another EU Member State that makes packaging or packaged products available in the Netherlands for the first time directly to the end user to appoint an EPR authorised representative in the Netherlands by written mandate. Distance contracts are included rather than defining the whole scope, and the rule covers producer profiles 3(15)(c) and (d). Article 45(4) separately obliges online marketplaces to obtain registration information and a self-certification from sellers. For a third-country producer the Dutch national choice must be verified rather than assumed.
The register gap
The producer registers foreseen by Article 44 are not operational, so there is no Dutch government packaging register publishing a per-seller number today.
The duty and the machinery are not on the same timetable, and that gap is described rather than papered over.
The threshold watch item
The 50,000 kg allowance is expected to change when the PPWR producer register arrives, on reporting that points to 12 August 2027 at the earliest.
We treat that as a watch item to review before each calendar year rather than as a present rule, and we do not date a change we cannot evidence.
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.