Netherlands EPR in 2026: Verpact, WEEE NL and the marketplace verification reality

By Operator One Editorial — 2026-06-14

Key takeaways

• Dutch packaging EPR runs through Verpact (formerly Afvalfonds Verpakkingen): a producer placing more than 50,000 kg of packaging on the Dutch market in a calendar year declares by 31 March and pays the waste management fee, while single-use plastic and deposit-bearing bottles and cans count from the first unit.
• Regulation (EU) 2025/40 (PPWR) has applied since 12 August 2026, and its Article 45(3) requires a producer selling packaged products directly to end users in a member state where it is not established to appoint an authorised representative for EPR there by written mandate.
• Dutch WEEE rules set no volume threshold: producers of electrical and electronic equipment join Stichting OPEN, which also covers the Nationaal (W)EEE Register, under a generally binding declaration running from 1 January 2026 to 31 December 2030.
• Dutch battery EPR sits with Stichting OPEN for portable batteries, Stichting EPAC for e-bike batteries and ARN for vehicle batteries, with an annual report due before 1 July; as of September 2026 the Dutch implementing decree for Chapter VIII of Regulation (EU) 2023/1542 is still unpublished.
• Online platforms must obtain a producer's registration number and self-certification before letting it sell: for batteries under Article 62(6) of Regulation (EU) 2023/1542 since 18 August 2025, and for packaging under Article 45(4) of the PPWR since 12 August 2026.
• UPV textiel has applied in the Netherlands since 1 July 2023, and the Inspectie Leefomgeving en Transport (ILT) reported on 27 February 2026 that over 80 percent of textile businesses it spoke to during an inspection week were unaware of it.

The Netherlands runs one of the more structured EPR regimes in the EU. Dutch packaging compliance is consolidated under a single producer responsibility organisation, electronics and portable batteries run through Stichting OPEN, textiles have had their own UPV (uitgebreide producentenverantwoordelijkheid) scheme since 1 July 2023, and since 12 August 2026 the EU Packaging and Packaging Waste Regulation (EU) 2025/40 sits on top of the Dutch packaging rules. For brands selling into the Netherlands in 2026, whether through Bol.com, Amazon.nl, a direct-to-consumer webshop or a cross-border parcel flow, the practical question is no longer whether Dutch EPR applies, but which streams, under which legal entity and how the marketplace will check it.

Packaging: Verpact, the 50,000 kg threshold and the PPWR

The Dutch packaging producer organisation that brands knew for years as Afvalfonds Verpakkingen now operates as Verpact. Rijkswaterstaat lists Verpact's generally binding declaration (AVV) for the Dutch packaging waste management fee as running from 1 January 2023 to 31 December 2027, and Verpact fulfils Dutch packaging EPR collectively on behalf of producers and importers.

The Dutch fee trigger is volume based. A producer or importer that places more than 50,000 kg of packaging on the Dutch market in a calendar year must file a declaration with Verpact and pay the waste management fee. According to Rijkswaterstaat, Dutch producers at or below 50,000 kg are exempt from the fee, from the notification obligation and from the reporting obligation. The threshold is measured per legal entity across all channels, so a company with two webshops and a Bol.com seller account adds all three flows together.

The Dutch threshold has two carve-outs. Verpact states that single-use plastic (SUP) packaging and deposit-bearing packaging (plastic water and soft drink bottles, and beverage cans) have no threshold and must be declared from the first unit placed on the Dutch market.

Key Verpact mechanics for 2026:

• Annual declaration to Verpact covering the previous calendar year, by material type in kilograms, due by 31 March.
• Fee differentiation by material, with Verpact publishing a separate tariff differentiation scheme for plastic packaging for 2026.
• Deposit (statiegeld) overlay: Rijkswaterstaat lists minimum Dutch deposits of EUR 0.15 on metal beverage cans up to 3 litres and on plastic water and soft drink bottles under 1 litre, and EUR 0.25 on such plastic bottles from 1 litre up to 3 litres. The Dutch deposit system is run by Verpact and sits on top of the packaging fee, not instead of it.
• Producer organisation reporting: under Dutch UPV verpakkingen rules, the producer organisation notifies Rijkswaterstaat on the producer's behalf within six weeks of the rules applying to it, and the producer organisation reports to Rijkswaterstaat before 1 August each year.

What the PPWR adds from 12 August 2026

Regulation (EU) 2025/40 applies from 12 August 2026 (Article 71). Under its Article 3(1)(15)(c) and (d), a manufacturer, importer or distributor established in one member state or in a third country that makes packaged products available directly to end users in another member state is a producer in that other member state. PPWR Article 45(3) requires such a producer to appoint, by written mandate, an authorised representative for extended producer responsibility in each member state where it makes packaging available for the first time, other than its own. PPWR Article 44 obliges producers to register in a national register of producers, which each member state must set up within 18 months of the Commission's first implementing act on the register format.

Verpact wrote on 17 August 2026 that the Dutch 50,000 kg threshold still applies after the PPWR, that EU-based companies not required to register in the Netherlands do not need an authorised representative for EPR, and that discussions between member states and the European Parliament on the representative requirement are ongoing, with a decision expected by the end of 2026.

WEEE Netherlands: Stichting OPEN and the Nationaal (W)EEE Register

Electrical and electronic equipment runs on a parallel Dutch track. The register is the Nationaal (W)EEE Register, and the producer organisation is Stichting OPEN (Organisatie Producentenverantwoordelijkheid E-waste Nederland). The Nationaal (W)EEE Register states that producers and importers of EEE join Stichting OPEN and that registration with OPEN also fulfils registration with the register. The Dutch Ministry of Infrastructure and Water Management declared OPEN's waste management fee agreement for e-waste generally binding from 1 January 2026 to 31 December 2030 (Staatscourant 2026, nr. 77). Producers placing EEE on the Dutch market must:

• Join Stichting OPEN, which covers registration with the Nationaal (W)EEE Register.
• Pay the Dutch waste management fee and report the equipment placed on the Dutch market.
• Mark equipment with the crossed-out wheeled bin symbol required by Article 14(4) of the WEEE Directive 2012/19/EU.

Neither Directive 2012/19/EU nor the Nationaal (W)EEE Register sets a volume threshold, so a single charger placed on the Dutch market brings its producer into scope. On representation, Article 17(2) of Directive 2012/19/EU requires a producer that sells EEE by distance directly to users in a member state where it is not established to appoint an authorised representative there by written mandate. The Nationaal (W)EEE Register adds that any foreign producer or importer can authorise a legal entity in the Netherlands under Article 21 of the Regeling AEEA to handle registration, collection obligations and annual reporting.

Batteries: a third stream with its own registration

Dutch battery EPR is organised per battery category. Rijkswaterstaat lists Stichting OPEN as the producer organisation for portable batteries (OPEN continues the tasks previously carried out by Stibat, Stichting Batterijen), Stichting EPAC, part of Stichting OPEN, for e-bike batteries, and ARN (Autorecycling Nederland) for vehicle batteries, where membership is voluntary. The Dutch generally binding declaration for portable batteries runs until 31 December 2028. Dutch battery producers report annually before 1 July on the previous calendar year.

The legal basis is Regulation (EU) 2023/1542. Its Chapter VIII on extended producer responsibility, including producer registration in Article 55, has applied since 18 August 2025 (Article 96). The Dutch implementation is not finished: as of September 2026 the Uitvoeringsbesluit hoofdstuk VIII EU-verordening batterijen is shown on the Dutch government legislative calendar as not yet published, and Rijkswaterstaat states that its producer register for batteries is still being built. The removability requirement for portable batteries in appliances under Article 11 of Regulation (EU) 2023/1542 applies from 18 February 2027.

A common trap: Article 55(2) of Regulation (EU) 2023/1542 covers batteries "including those incorporated in appliances", so a product that contains a battery (a wireless mouse, a Bluetooth speaker, a toy with a button cell) brings its producer under both Dutch WEEE and Dutch battery EPR at the same time.

Textiles: UPV textiel

UPV textiel has applied in the Netherlands since 1 July 2023 to consumer clothing, workwear and household textiles. Producers and importers notify Rijkswaterstaat within six weeks of the rules applying to them and report to Rijkswaterstaat every year before 1 August. For 2025, at least 50 percent of the weight placed on the Dutch market in the previous year must be prepared for reuse or recycled, rising to 75 percent in 2030; fibre-to-fibre recycling of collected textile must reach 25 percent in 2025 and 33 percent in 2030. Rijkswaterstaat lists three UPV textiel producer organisations: Stichting UPV Textiel, European Recycling Platform Netherlands B.V. and Collectief Circulair Textiel. The Dutch inspectorate ILT reported on 27 February 2026 that over 80 percent of the textile businesses it spoke to during an inspection week did not know UPV textiel.

What Bol.com and Amazon.nl verify

Marketplace checks now rest on EU law. Article 62(6) of the Battery Regulation (EU) 2023/1542, applying since 18 August 2025, and Article 45(4) of the PPWR (EU) 2025/40, applying since 12 August 2026, require online platforms within Section 4 of Chapter III of the Digital Services Act (EU) 2022/2065 to obtain, before a producer uses their service, the producer's registration details and registration number in the member state where the consumer is located, plus a self-certification that it complies with EPR there.

Bol.com states in its EPR policy that partners may only sell in the affected categories in the Netherlands and Belgium if they comply with EPR, and that non-compliant assortment is taken offline. Its current category list for the Netherlands names batteries; for Belgium it lists electrical and electronic equipment, batteries, car tyres, hybrid vehicle batteries, mattresses and solar panels. The evidence Bol.com asks for depends on the seller type, ranging from proof of registration with a producer organisation to a purchase invoice for sellers that are not themselves EPR-obligated.

Amazon.nl is subject to the same Battery Regulation and PPWR platform obligations. Missing Dutch numbers affect offers to Dutch consumers while other EU storefronts can keep selling, which makes the gap easy to miss in EU-wide revenue figures.

Who must register, and who is genuinely exempt

• Packaging: file with Verpact if your legal entity places more than 50,000 kg of packaging on the Dutch market per calendar year, regardless of channel, and from the first unit for single-use plastic and deposit-bearing packaging.
• Electronics (WEEE): join Stichting OPEN from the first unit. Distance sellers established in another member state appoint a Dutch authorised representative under Article 17(2) of Directive 2012/19/EU.
• Batteries: in scope from the first unit under Regulation (EU) 2023/1542, for standalone batteries and battery-containing products.
• Textiles: notify Rijkswaterstaat under UPV textiel within six weeks.
• Out of scope: pure service businesses with no physical product flow into the Netherlands, and goods that never reach Dutch end users. A Dutch company 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 to Dutch customers from a foreign warehouse exempts the seller. It does not: PPWR Article 3(1)(15)(d) and WEEE Directive Article 3(1)(f)(iv) both make a distance seller supplying end users in the Netherlands a producer there, wherever the stock sits.

Practical rhythm of staying compliant

A well-run Dutch EPR setup follows the statutory calendar: the Verpact declaration for the previous year by 31 March, the battery annual report before 1 July, and the UPV textiel report to Rijkswaterstaat before 1 August. Between those dates, reconcile packaging weights from actual purchase orders rather than averages, keep registration numbers and self-certifications current in the Bol.com and Amazon.nl seller portals, and track the two open Dutch items: the battery implementing decree and producer register, and the EU decision on the PPWR authorised representative rule that Verpact expects by the end of 2026.

An EU-established consumer electronics seller shipping to Dutch households typically sits inside three Dutch streams at once (packaging, WEEE and batteries), while an apparel brand adds UPV textiel to Dutch packaging EPR.

How to register for Dutch EPR, step by step

1. Map your Dutch streams per legal entity. List every product your legal entity makes available to Dutch end users and tag each for packaging, electrical and electronic equipment, batteries (including built-in batteries) and textiles.
2. Weigh packaging and check the Verpact threshold. Measure packaging weight per material for the calendar year. Register with Verpact if the total exceeds 50,000 kg, or from the first unit for single-use plastic packaging and deposit-bearing bottles and cans.
3. Join Stichting OPEN for electronics. Join Stichting OPEN, which covers registration with the Nationaal (W)EEE Register. A producer established in another EU member state selling by distance to Dutch users appoints a Dutch authorised representative under Article 17(2) of Directive 2012/19/EU.
4. Register batteries with the right producer organisation. Register portable batteries through Stichting OPEN, e-bike batteries through Stichting EPAC and vehicle batteries through ARN, as listed by Rijkswaterstaat for Regulation (EU) 2023/1542.
5. Notify textiles to Rijkswaterstaat. If you place consumer clothing, workwear or household textiles on the Dutch market, submit the UPV textiel notification to Rijkswaterstaat within six weeks of the rules applying to you.
6. Check PPWR authorised representative duties. If your entity sells packaged products directly to Dutch end users without being established in the Netherlands and must register, appoint an authorised representative for EPR under Article 45(3) of Regulation (EU) 2025/40.
7. Give marketplaces your numbers and self-certification. Enter your Dutch registration numbers and self-certification in the Bol.com and Amazon.nl seller portals, as online platforms must collect them under Regulation (EU) 2023/1542 Article 62(6) and Regulation (EU) 2025/40 Article 45(4).
8. File the annual reports on time. Submit the Verpact declaration for the previous year by 31 March, the battery annual report before 1 July and the UPV textiel report to Rijkswaterstaat before 1 August.

Frequently asked questions

Do I need to register with Verpact to sell into the Netherlands?

Under Dutch packaging EPR, a producer or importer placing more than 50,000 kg of packaging on the Dutch market in a calendar year must file a Verpact declaration and pay the waste management fee. At or below 50,000 kg there is no fee, notification or annual report, except for single-use plastic packaging and deposit-bearing plastic bottles and cans, which Verpact requires to be declared from the first unit.

What changed for Dutch packaging EPR on 12 August 2026?

Regulation (EU) 2025/40 (PPWR) began to apply on 12 August 2026. Its Article 45(3) requires a producer selling packaged products directly to end users in a member state where it is not established to appoint an authorised representative for EPR there. Verpact wrote on 17 August 2026 that the Dutch 50,000 kg threshold still applies, that EU-based companies not required to register in the Netherlands do not need an authorised representative for EPR either, and that a final decision on whether the representative requirement stays is expected by the end of 2026.

Is there a minimum threshold for WEEE registration in the Netherlands?

No. Neither the WEEE Directive 2012/19/EU nor the Nationaal (W)EEE Register sets a volume threshold, so a single charger placed on the Dutch market brings its producer into scope. Producers register by joining Stichting OPEN, which automatically covers registration with the Nationaal (W)EEE Register, and pay the waste management fee under OPEN's generally binding declaration running from 1 January 2026 to 31 December 2030.

Do I need a Dutch authorised representative for WEEE?

It depends where you are established. Under Article 17(2) of the WEEE Directive 2012/19/EU, a producer established in another EU member state that sells electronics by distance directly to Dutch users must appoint an authorised representative in the Netherlands by written mandate. Other foreign producers may authorise a Dutch legal entity under Article 21 of the Regeling AEEA, which then handles registration, collection obligations and annual reporting for the Nationaal (W)EEE Register.

Why do Bol.com and Amazon.nl ask for EPR registration numbers?

Article 62(6) of the EU Battery Regulation (EU) 2023/1542, applying since 18 August 2025, and Article 45(4) of the PPWR (EU) 2025/40, applying since 12 August 2026, require online platforms to obtain a producer's registration number and a self-certification before letting it sell to EU consumers. Bol.com's own EPR policy currently lists batteries as the Dutch category needing proof and states that non-compliant assortment is taken offline.

What happens if I sell into the Netherlands without EPR compliance?

Two consequences run in parallel. Bol.com states that it takes non-compliant assortment offline, and EU platform rules oblige marketplaces to collect registration details before a producer sells. The Dutch Inspectie Leefomgeving en Transport (ILT) supervises UPV compliance: it visited more than 260 businesses in an inspection week reported on 27 February 2026, and in July 2024 it imposed five orders subject to a penalty on Verpact over plastic bottle collection.

Who carries Dutch EPR obligations when a Merchant of Record is the seller?

Dutch EPR attaches to the producer, the party that first makes the product or its packaging available on the Dutch market. Where a Merchant of Record sells the goods as the legal seller, that entity is the one placing them on the Dutch market and registers accordingly. Registrations do not transfer between legal entities, and CE marking and the EU Declaration of Conformity stay with the manufacturer under Regulation (EC) 765/2008.

Does selling from a warehouse outside the Netherlands exempt me from Dutch EPR?

No. Under Article 3(1)(15)(d) of the PPWR (EU) 2025/40, a company established in another member state or a third country that makes packaged products available directly to end users in the Netherlands is a producer there, wherever the stock sits. Article 3(1)(f)(iv) of the WEEE Directive 2012/19/EU treats distance sellers of electronics the same way. Stock shipped from Germany to a German buyer is a German EPR case.

Does the Netherlands have a separate EPR scheme for textiles?

Yes. UPV textiel has applied in the Netherlands since 1 July 2023 to consumer clothing, workwear and household textiles. Producers notify Rijkswaterstaat within six weeks of the rules applying to them and report every year before 1 August. For 2025, at least 50 percent of the weight placed on the Dutch market must be prepared for reuse or recycled, rising to 75 percent in 2030, with fibre-to-fibre recycling at 25 percent.

Where a Merchant of Record carries the Dutch EPR obligation

Dutch packaging, WEEE, battery and textile EPR attach to the producer: the legal entity that first makes the product or its packaging available on the Dutch market. Where a Merchant of Record such as Operator One sells the goods as the legal seller, that entity places them on the Dutch market and carries the registrations that follow from it; where it imports goods into the EU, it is also the importer and responsible economic operator under Regulation (EU) 2019/1020. EPR registrations are per country and per stream and do not transfer between legal entities, and a locally established authorised representative is arranged only where a market requires one. CE marking, the conformity assessment, the technical file and the EU Declaration of Conformity remain with the manufacturer under Regulation (EC) 765/2008. On Bol.com and Amazon.nl the brand remains the client's, with Operator One shown as the seller. Terms used here are explained in the compliance glossary.

Sources: Regulation (EU) 2025/40 (PPWR), EUR-Lex; Regulation (EU) 2023/1542 (Batteries), EUR-Lex; Directive 2012/19/EU (WEEE), EUR-Lex; Rijkswaterstaat, UPV verpakkingen; Rijkswaterstaat, UPV batterijen; Rijkswaterstaat, UPV textiel; Rijkswaterstaat, AVVs in force; Nationaal (W)EEE Register; Verpact, Moet ik aangifte doen?; Verpact, registration since the PPWR; Bol.com Partnerplatform, EPR; ILT, inspection week 27 February 2026; ILT, five orders subject to a penalty for Verpact, 12 July 2024; Wetgevingskalender, Uitvoeringsbesluit hoofdstuk VIII EU-verordening batterijen.