A written EPR mandate,
with each Dutch role kept distinct.
We scope the PPWR authorised-representative mandate separately from filing delegation and from fiscal representation. 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.
Priced in a written scope after entity, channels and powers are reviewed
✓ Free ✓ Human review ✓ No commitment
Timing depends on document completeness and independent registry and scheme review
The outcome
A versioned mandate and responsibility map
- Applicability assessed against the producer profile and the sales route
- Powers, limits and duration written down rather than assumed
- Each role separated: representation, filing delegation and tax roles
Applicability depends on the facts of the file and, for third-country producers, on the Dutch national choice
PPWR Article 45(3) has applied since 12 August 2026
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.
Primary sources · Reviewed 19 August 2026
Where a Dutch packaging file commonly breaks
The mandate is confused with tax representation
An EPR authorised representative is not a fiscal representative. We never take a role that imports joint VAT liability.
Third-country cases are assumed to match EU ones
For a producer established outside the EU the national choice must be verified rather than assumed.
A marketplace label is treated as proof
Article 45(4) puts a verification duty on the marketplace. It does not establish that the seller duty has been met.
Included in the written scope.
- Producer-profile and sales-route assessment
- Applicability review against Article 45(3) and the Dutch position
- Written mandate scope, powers and limits
- Separation from filing delegation and tax roles
- Evidence register for the mandate and its versions
- Annual review point when the rules or the sales model change
Four controlled steps.
Document the facts
Collect the entity, products, channels, contracts and available evidence for authorised representation.
Confirm scope and dependencies
Receive a written map of assumptions, exclusions, third parties and points requiring approval.
Authorise the agreed work
Private fees, external costs and client responsibilities are confirmed before any submission or commitment.
Coordinate and retain evidence
After a valid engagement, each action, external decision and authentic receipt is stored with its date and version.
Frequently asked
Is an authorised representative always required?
No. It depends on the producer profile, the establishment and the sales route. We assess applicability against Article 45(3) rather than assuming it.
Is this fiscal representation?
No. It is an extended producer responsibility mandate. We do not act as a fiscal representative and do not sell a Dutch VAT number, a KvK registration or eHerkenning.
Does a representative remove the registration duty?
No. Representation and registration are different questions and are documented separately.
Can you guarantee acceptance by a marketplace?
No. Marketplaces control their own onboarding fields, evidence and acceptance decisions.
Complete the packaging file
Service
Packaging EPR in the Netherlands
Establish the packaging position the mandate would sit on.
Service
Registration with the producer organisation
Prepare the registration record where it is required.
Service
Declarations and maintenance
Keep the recurring duties documented after the mandate is in place.
Discuss the facts with the team.
Independent private service · human scope review · no third-party outcome promised.
✓ Free ✓ Human review ✓ No commitment