By Operator One Editorial — 2026-06-14
The Netherlands has quietly become one of the most structured EPR regimes in the EU. The country has consolidated packaging compliance under a single Producer Responsibility Organisation, kept WEEE under a long-established collective scheme, and given marketplaces a clear legal mandate to verify producer registrations before allowing listings to remain online. For brands selling into NL in 2026 — whether through Bol.com, Amazon.nl, a direct-to-consumer webshop, or a wholesale route that ends with a parcel crossing the border — the practical question is no longer whether EPR applies, but which streams, under which registration number, and how the marketplace will check it.
The big rename: Afvalfonds Verpakkingen is now Verpact
The Dutch packaging EPR scheme that brands knew for years as Afvalfonds Verpakkingen rebranded to Verpact in 2024. It is the same legal vehicle, the same obligation, and the same underlying Besluit beheer verpakkingen — just a new name and a refreshed reporting portal. Verpact is the collective PRO that handles the packaging-waste fee on behalf of producers and importers placing packaged goods on the Dutch market.
The trigger for registration is volume-based. A company is treated as a packaging "producer" in NL if it brings more than 50,000 kg of packaging onto the Dutch market in a calendar year — measured across all packaging types combined (paper/cardboard, plastic, glass, metal, wood, other). Below that threshold there is no fee obligation and no annual declaration, but the activity itself is still notifiable and the threshold is calculated per legal entity, not per brand or per marketplace. A Dutch B.V. with two webshops and a Bol.com seller account adds all three flows together.
Key Verpact mechanics for 2026:
- Annual declaration covering the previous calendar year, broken down by material type in kilograms.
- Fee differentiation by material — plastic is the most expensive stream, glass and paper considerably cheaper. Recyclability-based modulation continues to expand, rewarding mono-material and recycled-content packaging.
- Statiegeld (deposit-return) overlay on plastic bottles up to 3 L and metal beverage cans. This is a separate flow administered via Statiegeld Nederland and sits on top of the Verpact fee, not instead of it.
- Non-resident producers selling into NL without a Dutch establishment can register directly with Verpact or appoint an authorised representative. The "deemed producer" concept means whoever first places the goods on the Dutch market carries the obligation — which for cross-border e-commerce is often the foreign seller, not the Dutch end-customer or the marketplace.
WEEE Netherlands: electronics, the EEE register, and the UPV-EEE numbers
Electrical and electronic equipment runs on a parallel track. The relevant body is the Nationaal (W)EEE Register, and the dominant collective scheme is Stichting OPEN (the successor to Wecycle/ICT~Office and now the de-facto national PRO for B2C electronics). Producers placing EEE on the Dutch market must:
- Register in the national EEE register and obtain a producer registration number.
- Join a collective scheme (Stichting OPEN for most B2C cases) or, in narrowly defined situations, run an approved individual scheme.
- Report annual volumes placed on market, by category, in kilograms and units.
- Mark equipment with the crossed-out wheelie-bin symbol and provide end-of-life take-back information at the point of sale.
There is no de-minimis threshold for WEEE in the Netherlands the way there is for packaging — a single charger placed on the market triggers the obligation. Categories run from large household appliances to small IT, lamps, screens, and the newer photovoltaic-panel and e-cigarette streams. Non-resident producers must appoint an authorised representative established in the Netherlands; this is not optional and marketplaces increasingly ask to see it.
Batteries: a third stream with its own registration
Battery EPR in NL is administered by Stibat (Stichting Batterijen) for portable batteries and by separate arrangements for industrial and automotive batteries. The new EU Battery Regulation (2023/1542) is being phased in through 2026 and 2027 and tightens labelling, due-diligence, and removability requirements, but the Dutch operational layer — register with Stibat, declare annual volumes in kilograms by chemistry, pay the per-kilo fee — remains broadly the same.
A common trap: any product that contains a battery (a wireless mouse, a Bluetooth speaker, a toy with an LR44 button cell) triggers both WEEE and battery obligations simultaneously. Removable batteries are declared separately from the host appliance, and the seller is responsible for both registrations even when the battery is pre-installed in the factory.
What Bol.com and Amazon.nl actually verify
This is where 2026 differs meaningfully from 2022. Both major NL marketplaces now operate active producer-number verification at the seller-account level, driven by the EU's Waste Framework Directive amendments and the Dutch implementation of marketplace co-responsibility.
Bol.com requires sellers to upload, per stream, the registration evidence that applies to their assortment:
- Verpact registration confirmation for packaging.
- UPV-EEE producer number for any electronics listings.
- Battery-scheme confirmation (typically Stibat) where applicable.
The check is performed against the seller's legal entity, not its trade name. Listings in categories that require a number but for which no valid number is on file are de-listed automatically — usually with a 14-to-30-day grace window, after which the offers are suppressed rather than deleted. Reactivation requires uploading the missing certificate and waiting for the verification team to clear the account.
Amazon.nl follows a similar logic via its Compliance Portal. Sellers are prompted, category by category, to provide producer registration numbers for each EU country they ship to. Amazon validates the format and, increasingly, cross-checks with the national registers directly. Missing or invalid NL numbers result in offer suppression on Amazon.nl specifically; the rest of the EU storefronts continue to function, which is what makes the failure mode so easy to miss — sellers see EU-wide revenue continue while NL quietly stops converting.
Who must register, and who is genuinely exempt
The clean rule of thumb for 2026:
- Packaging: register with Verpact if your legal entity places more than 50,000 kg of packaging on the Dutch market per year, regardless of channel. Below that, no fee — but if you sell on Bol.com or Amazon.nl, the marketplace may still ask you to confirm your status in writing.
- Electronics (WEEE): register from the first unit. No threshold. Non-EU producers must appoint a Dutch authorised representative.
- Batteries: register from the first unit. No threshold. Applies to standalone batteries and battery-containing products.
- Genuine exemptions: pure-service businesses with no physical product flow into NL; B2B-only sales of industrial equipment that falls outside the consumer WEEE scope (these have their own separate obligations); and goods that physically never enter the Dutch market (a Dutch-based seller fulfilling a German order from a German warehouse is a German EPR case, not a Dutch one).
The most common mistake is assuming that selling on a Dutch marketplace from a foreign warehouse exempts the seller. It does not. The "placing on the market" trigger is the moment the goods are made available to a Dutch end-customer, not the location of the stock.
Practical rhythm of staying compliant
A well-run NL EPR setup has a predictable cadence: Q1 declarations for the previous year's volumes across Verpact, WEEE, and Stibat; quarterly internal reconciliation of packaging weights from the actual purchase orders rather than guessed averages; an annual re-upload of certificates to the Bol.com and Amazon.nl seller portals before the marketplaces start their verification sweep (typically March-April); and a watching brief on the Battery Regulation milestones that will land in 2027.
For mid-sized sellers the volumes add up faster than expected. A mid-market apparel brand pushing roughly 80,000 orders a year into NL will cross the Verpact threshold on packaging weight alone before considering any hangtags or polybags. An EU-headquartered consumer-electronics seller will sit inside all three streams — packaging, WEEE, and batteries — from day one. Dabur, as a packaged-consumer-goods producer, is squarely in Verpact territory across its EU footprint.
Where Operator One fits
Operator One acts as Merchant of Record across 27 EU countries and the UK, which means we take on the producer-of-record position for the EPR streams attached to the orders we transact. For brands selling into the Netherlands through our MoR setup, the Verpact, WEEE NL, and Stibat registrations sit under our entities and the marketplace verification checks resolve against our numbers — so the listings stay live and the annual declarations get filed on time. More on the model on /merchant-of-record, the country-by-country obligations on /compliance-glossary, and the live marketplace coverage on /marketplaces.