PPWR · applies now

Review PPWR
For direct-to-consumer brands

Connect every Dutch order,
to the pack that actually ships.

Own-webshop sales need a channel-specific analysis. Current the producer organisation guidance describes voluntary foreign-company membership for this route. 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. The rule covers producer profiles 3(15)(c) and (d); importer or reseller routes and third-country cases require separate review.

Standard packaging reference €474/year + €150 setup · the waste management contribution and labelling audit separate

Free Human review No commitment

Timing depends on document completeness and independent registry and scheme review

A direct-to-consumer brand preparing product and shipment packaging for customers in the Netherlands
PPWR watch

The Article 45(3) rule is in force for its defined scope

The proposed suspension until 2035 is not adopted. The file records the producer’s establishment, the Article 3(15)(c) or (d) profile, first making available in the Netherlands directly to the end user and any distance contract. It keeps Dutch importer or reseller routes and third-country national-choice evidence separate.

DTC obligations sit across sales, logistics and packaging

Marketplace and own-shop rules are merged

The current the producer organisation route can differ by channel. Mixed sales should be split before an application or declaration decision.

The 3PL packaging is absent

Cartons, labels, void fill and protective material added at fulfilment can belong in the Dutch packaging inventory.

Current Dutch labels are postponed for PPWR

Existing material-code and consumer sorting-information duties still require action while the PPWR transition is planned.

What's included

Included in the written scope.

  • Seller, checkout, contract, destination and fulfilment map
  • Current the producer organisation route assessed by channel
  • PPWR Article 45(3) representative review
  • Product and shipment-packaging inventory
  • Dutch environmental-labelling audit available by manual quote
  • Annual order, return and weight reconciliation plan
How it works

Four controlled steps.

01

Map the facts

Record the entity, countries, channels, contracts and products relevant to DTC sales.

02

Separate the streams

Packaging, WEEE and batteries are assessed independently, with assumptions marked for confirmation.

03

Confirm the written scope

Private fees, exclusions, external costs and client approvals are set out before any work begins.

04

Maintain authentic evidence

Official documents, filings, invoices and changes remain linked to the entity and stream that produced them.

Frequently asked

Must an own-webshop seller join the producer organisation?

Current the producer organisation guidance treats the foreign own-webshop route differently from third-party marketplaces and describes membership as voluntary. The exact channel and contracts must still be reviewed.

Does the pending PPWR amendment remove the representative duty?

No—not at present. A proposal to suspend Article 45(3) until 2035 is pending. The enacted rule covers producer profiles 3(15)(c) and (d) where a producer established in another EU Member State makes packaging or packaged products available in the Netherlands for the first time directly to the end user, including under a distance contract. Dutch importer or reseller routes and third-country cases require separate evidence.

Does my 3PL become the packaging producer?

Not automatically. Contracts, ownership, packaging added and the route to the Dutch customer must be documented.

Can you review our Dutch packaging labels?

Yes. The labelling audit is active and quoted manually after pack variants, languages and available specifications are reviewed.

Discuss the facts with the team.

Independent private service · human scope review · no third-party outcome promised.

Talk to the team

Free Human review No commitment