compliance teamSelling B2B to a Dutch importer or reseller
Step 1
Identify the first placer
Step 2
Check what the buyer does
Step 3
Split the flows
Step 4
Record each position
| 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 |
The first-placer test
Article 1 under f defines placing on the market as offering a product professionally on the Dutch market for the first time.
Where a Dutch importer or reseller buys the goods and is first to place them, that Dutch party is normally the producer for the packaging concerned.
The end-user nuance
A professional buyer that uses rather than resells the supplied product can be an end user, so business-to-business alone is not a conclusion.
The contract and what the buyer does with the goods both matter.
Mixed flows
A seller with some volume through a Dutch buyer and some shipped directly to consumers has to split the analysis before recording a position.
One answer applied to every flow is the most common error in this area.
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.