Every Dutch order carries packaging,
including the box it ships in.
With your own shop there is no platform between you and the Dutch buyer, so the first-placer test in article 1 under f of the Besluit beheer verpakkingen 2014 usually points at your company. Everything that reaches the customer counts towards the calendar year: the product pack, the carton, the tape, the labels and the void fill added at fulfilment. Separately, PPWR 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). For a third-country producer the Dutch national choice must be verified rather than assumed.
Standard packaging reference €474/year + €150 setup · waste management contribution and labelling audit quoted separately
✓ Free ✓ Human review ✓ No commitment
Timing depends on document completeness and independent registry and scheme review
Article 45(3) has applied since 12 August 2026
The file records where the producer is established, the Article 3(15)(c) or (d) profile, the first making available in the Netherlands directly to the end user and any distance contract. A Dutch importer or reseller route and a third-country national choice are kept separate and evidenced rather than assumed.
The weight is larger than the product pack
Fulfilment packaging is missing from the count
Cartons, tape, labels, void fill and protective material added at a fulfilment provider are packaging placed on the Dutch market, and they belong in the same calendar-year calculation as the product pack.
The allowance is read as a cliff
Passing 50,000 kg does not make the first 50,000 kg payable. Article 2.3 of Annex 1 to the agreement leaves the kilograms below the limit uncharged and spreads them across materials in the same weight share as the total mix.
The representative question is postponed
Article 45(3) turns on where the producer is established and on who first makes the goods available to the end user in the Netherlands, so it is assessed on the file rather than assumed in either direction.
Included in the written scope.
- First-placer test for direct orders and for any Dutch buyer in the chain
- Product and shipment-packaging inventory, including material added at fulfilment
- Weight per material for the calendar year against the 50,000 kg allowance
- Deposit and single-use plastic screened from the first unit
- PPWR Article 45(3) applicability review and written mandate scope
- Annual order, return and weight reconciliation, with labelling reviewed by written quote
Four controlled steps.
Establish who places the goods on the market
Record the entity, the Dutch customer, the contracts and the route to the buyer for DTC sales, so the first-placer question is answered before anything else.
Weigh the calendar year
Packaging is reconstructed per material from pack specifications and shipped volumes, then set against the 50,000 kg allowance for the calendar year.
Separate what sits outside it
Deposit and single-use plastic packaging are charged from the first unit, and WEEE and batteries are assessed as their own regimes rather than as part of the packaging file.
Write the scope and keep the evidence
Private fees, exclusions, external costs and approvals are agreed in writing before any work begins, and the calculation and the documents behind it stay linked to the entity and the calendar year that produced them.
Frequently asked
Does the box my fulfilment provider adds count towards the 50,000 kg?
If it goes to the Dutch customer with the order, it is packaging placed on the Dutch market and it is weighed into the same calendar-year total as the product pack. Whether your company or the fulfilment provider is the producer depends on the contracts and on who first places the goods on the Dutch market, not on who folded the carton.
We are just below the allowance, so is there anything to file?
No registration, no declaration and no waste management contribution on that packaging. Article 5.2 of Annex 2 to the waste fund agreement still requires you to record how you calculated that you stayed below the limit and to produce it on request. Returns, cancellations and samples belong in that calculation as documented assumptions rather than as silent deductions.
We are established elsewhere in the EU, so do we need an authorised representative?
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). We assess it against your producer profile and sales route instead of assuming it, and for a third-country producer the Dutch national choice must be verified. It is an extended producer responsibility mandate and never fiscal representation.
Part of our volume goes to a Dutch retailer, so who registers for that?
Where a Dutch importer or reseller buys the goods and is the first to place them on the Dutch market, that Dutch party is normally the producer for the packaging concerned, under the first-placer test in article 1 under f. The volume you ship directly to Dutch consumers stays with you. A mixed model is split flow by flow rather than answered once.
Discuss the facts with the team.
Independent private service · human scope review · no third-party outcome promised.
✓ Free ✓ Human review ✓ No commitment