compliance teamThe duty that survives below the threshold
Step 1
Specify the packaging
Step 2
Total the Dutch volumes
Step 3
Reconstruct the weight
Step 4
Date and retain the record
| 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 obligation
A producer that stays below the limit must record in its own administration how it calculated that it stayed below, and produce that calculation to the fund on request.
Being under the limit is a factual claim. Without a record it cannot be produced when it is asked for.
What the record contains
It ties shipped volumes for the Dutch market to a packaging specification per product, so that a weight per material can be reconstructed for the calendar year.
It should identify the entities counted together, the packaging components included, the assumptions used and the date of the calculation.
It is not a filing
The record is kept in your own administration. It is not sent anywhere unless it is asked for, and it is refreshed annually because the test is per calendar year.
It documents a position established by actual volumes; it is never a plan to engineer one.
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.