The duty that survives
below the threshold.
A producer relying on the 50,000 kg allowance still has to record how it reached that figure. We build that calculation from your own shipping and packaging data and keep it in a form you can hand over.
Quoted per company after review. Documentation of a position you already hold, never advice to stay under the limit
✓ Free ✓ Human review ✓ No commitment
Timing depends on document completeness and independent registry and scheme review
The outcome
A calculation record you can produce on request
- Shipped volumes for the Dutch market tied to a packaging specification per product
- Weight per material reconstructed for the calendar year
- Entities counted together, assumptions used and the date of the calculation recorded
It is a working record for inspection, not a filing, and it is not sent anywhere unless it is asked for
Article 5.2 of Annex 2 to the packaging agreement
A producer that stays below the limit must record in its own administration how it calculated that position, and produce that calculation to the fund on request. The limit is tested across a VAT fiscal unity under article 8(3) of the Besluit beheer verpakkingen 2014.
Primary sources · Reviewed 19 August 2026
Where a Dutch packaging file commonly breaks
The position is asserted without a calculation
Being under the limit is a factual claim. Without a record it cannot be produced when asked.
Group structure is not considered
The threshold is tested across a VAT fiscal unity, so splitting sales across entities inside one unity does not lower the figure.
The record is never updated
The test is annual. A record for one calendar year says nothing about the next.
Included in the written scope.
- Packaging specification per product, by component and material
- Dutch-market shipped volumes for the calendar year
- Weight calculation per material and in total
- Fiscal-unity scoping of the entities counted together
- Assumptions, exclusions and calculation date recorded
- Annual refresh point
Four controlled steps.
Document the facts
Collect the entity, products, channels, contracts and available evidence for the threshold evidence file.
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 this a filing?
No. It is a record kept in your own administration and produced on request. Nothing is submitted.
Is this advice to stay under the limit?
No. It documents a position established by your actual volumes. We never present the allowance as something to engineer.
What if the calculation shows I am over?
Then the registration and declaration route applies, and the same calculation becomes the basis for it.
How often does it need refreshing?
The test is per calendar year, so the record is refreshed annually or whenever the packaging or volumes change materially.
Complete the packaging file
Discuss the facts with the team.
Independent private service · human scope review · no third-party outcome promised.
✓ Free ✓ Human review ✓ No commitment