The direct answer
A contribution threshold is not a blanket exemption from all packaging obligations. Check volumes, special categories and producer status separately.
What to check
50,000 kg: contribution and declaration
Verpact specifies over 50,000 kg per calendar year as the general declaration threshold. Foreign online sellers to Dutch consumers can also be covered. Verpact · obligation to contribute
Check SUP and deposit separately
For beverage cans, certain plastic beverage bottles and SUP packaging, Verpact specifies registration even below the general threshold. Verpact · obligation to contribute
Check the broader obligations
ILT describes collection and recycling responsibility and the treatment of logistical aids. Assess contribution liability separately from the regulatory scope. ILT · packaging producer responsibility
Your action plan
The following steps are our suggested way to organise your project.
- Calculate Dutch annual volumes from unit weights and sales.
- Flag SUP, beverage and logistical packaging as separate groups.
- Document the evidence supporting a below-threshold assessment.
- Review current PPWR registration and representation obligations separately.
Prepare your records
Weights by material, annual sales, SUP classification, deposit data and prior Verpact submissions.
Frequently asked questions
Below 50,000 kg: always no action?
No. Special categories and other regulatory obligations need separate checks.
Does this threshold apply to WEEE?
This guide covers packaging. Do not apply its threshold to electrical equipment or batteries.
Sources and scope
This guide covers the product stream described. Check other EPR streams separately; your supply chain and sales model determine the specific obligations.