The direct answer
Review your Dutch-market role, OPEN membership and NWR evidence together. Prepare equipment unit counts and the appropriate net weight; assess packaging and batteries separately.
What to check
Who is responsible?
RVO identifies first supply under your name or brand, first import, and direct sales from abroad to Dutch end users as relevant cases. RVO · Dutch electrical equipment producer duties
Current collective framework
The official notice makes the AEEA waste-management contribution agreement generally binding for 1 January 2026 through 31 December 2030. The old 2025 end date is outdated. Staatscourant 2026, 77 · AEEA agreement 2026–2030
Distinguish OPEN and NWR
NWR states that producers register through Stichting OPEN, which also registers them nationally. Check membership and registry evidence rather than assuming two independent applications. NWR · producing or importing equipment
Foreign sellers
OPEN describes direct membership for foreign sellers and its representative role under the AVV; home-country requirements still need review. Obtain confirmation of your specific coverage. Stichting OPEN · foreign producers and representation
Classify products
The 2026 OPEN list contains six main EEE categories and product codes. Match function and dimensions to the appropriate entry; resolve unclear products with OPEN. Stichting OPEN · 2026 product classification
Equipment weight basis
OPEN requires units and net weight: include electrical accessories, exclude packaging, manuals and supplied or integrated batteries. Report batteries separately; reporting is annual or quarterly. Stichting OPEN · reporting quantities and net weight
| Review field | Our working recommendation |
|---|---|
| Sales and entity | Document the supply chain and contracting entity; flag first supply and direct sales. |
| Product code and dimensions | Keep the photo, function, dimensions and reviewed OPEN code together. |
| Separate weight records | Prepare separate equipment, battery and packaging rows; leave unknown values blank. |
| Period and evidence | Link the reporting period, source records, approval and receipt confirmation. |
Your action plan
The following steps are our suggested way to organise your project.
- Describe who supplies which equipment to which Dutch customers.
- Review OPEN membership, NWR evidence and any representation coverage.
- Assign each SKU a reviewed code and documented weight basis.
- Use the data template for preparation; confirm format and deadlines with OPEN.
- Review discrepancies before submission and retain the evidence.
Prepare your records
Our working list: entity details, sales routes, SKU photos, dimensions, weight evidence, OPEN and NWR records, and existing reports. German registration is not evidence of the Dutch process.
Frequently asked questions
Must I apply to OPEN and NWR separately?
NWR describes producer registration through OPEN. Check the evidence actually received.
Does the integrated battery belong in equipment weight?
OPEN’s instructions exclude it and require separate reporting.
Does every foreign seller need an additional representative?
Not as a blanket rule. Review OPEN’s stated coverage and home-country requirements.
Does the packaging threshold also apply to WEEE?
Do not transfer a packaging rule to equipment. Review each product stream separately.
Sources and scope
- RVO · Dutch electrical equipment producer duties
- Staatscourant 2026, 77 · AEEA agreement 2026–2030
- NWR · producing or importing equipment
- Stichting OPEN · foreign producers and representation
- Stichting OPEN · 2026 product classification
- Stichting OPEN · reporting quantities and net weight
This guide covers the product stream described. Check other EPR streams separately; your supply chain and sales model determine the specific obligations.