EPR in the Netherlands: Verpact, UPV & 2026 Rules

If you sell products to customers in the Netherlands, you are legally responsible for the waste your products leave behind at the end of their life. Ignoring these Extended Producer Responsibility obligations carries severe consequences for e-commerce merchants: instantly blocked marketplace listings, suspended seller accounts, retroactive fee assessments, and administrative fines from national regulators. You cannot treat Dutch environmental compliance as an afterthought, because marketplaces actively gatekeep access to buyers until your producer status is formally verified.

Unlike many European jurisdictions that run a single, unified environmental agency, the Netherlands takes a fragmented approach. There is no single portal. Compliance is split across several registers depending on the exact products and packaging you place on the market. That structural division means distance sellers must engage multiple authorities at once, which makes the initial setup administrative but strictly necessary to keep your sales channels open.

Which registers apply

Because the Dutch framework relies on specialised organisations for different material streams, you must identify and engage the correct authority for every category of product you sell.

Packaging: Verpact

All commercial and household packaging compliance is managed by Verpact, formerly known as Afvalfonds Verpakkingen, the country's designated collective packaging scheme. A collective scheme means that instead of every merchant building its own recycling infrastructure, producers pool contributions to fund a national network of collection, sorting, and processing. To stay compliant you track and report the exact volume of packaging you place on the Dutch market, categorised by weight and material. The financial structure relies on eco-modulated per-kilogram fees, so your liability is tied to the environmental impact of your packaging design: easily recyclable mono-materials attract lower rates, while complex, hard-to-recycle materials cost more. Data reporting through the Verpact packaging administration portal runs on an annual cadence. For foreign sellers, registration usually cannot be completed directly and runs through an authorised representative who submits to the collective scheme on your behalf.

Electronics (WEEE): Nationaal (W)EEE Register

If your catalogue includes electrical and electronic equipment, you comply through the Nationaal (W)EEE Register operated via Stichting OPEN. This has been mandatory since 1 March 2021, governed domestically under Regeling AEEA article 21. The register ensures the end-of-life costs of electronic components are internalised into the product's market price rather than falling on local taxpayers. The cost model requires producers to calculate the weight and category of electronics placed on the market, which determines your contribution to the collective e-waste infrastructure. As with packaging, foreign online sellers secure their WEEE registration through an authorised representative.

Batteries, textiles, single-use plastics, and fishing gear: RWS UPV

For a diverse set of other regulated streams, the government uses the Rijkswaterstaat RWS UPV register. It covers batteries, textiles, single-use plastics, and fishing gear, though the rules differ for each. The textile scheme has been active since 1 July 2023 under the Besluit UPV textiel. A strict six-week notification window applies to both the textiles and single-use plastics schemes, so you must notify the authority almost immediately on entering the market. For batteries, the framework is anchored by the EU Batteries Regulation 2023/1542, with EPR provisions applying from 18 August 2025. The national implementing decree for batteries is still pending, so the registration process remains somewhat separate while local structures are finalised. Always verify the current status of the battery decree before relying on the portal.

End-of-life vehicles: ARN

While less relevant to standard e-commerce goods, the Dutch system extends to heavy goods. EPR for end-of-life vehicles is managed by ARN, operating under Rijkswaterstaat, and has been established since 2002 under the Besluit beheer autowrakken, requiring producers and importers to fund the dismantling, depollution, and recycling of car wrecks.

Tyres: RecyBEM

Tyre producers and importers are governed by the RecyBEM tyre recycling scheme. Active since 2004 under the Besluit beheer autobanden, it ensures the collection, shredding, and processing of used tyres is financed by the companies that place them on the market.

The authorised-representative rule

The structural complexity of the Dutch system is compounded for international merchants by a strict requirement for local representation. If you are a foreign distance seller operating without a physical, registered establishment in the Netherlands, you cannot manage your environmental compliance directly. You must formally appoint a local authorised representative.

An authorised representative is a designated legal entity based in the Netherlands that takes on formal responsibility for your compliance duties and acts as the mandated liaison between your business and the Dutch registries. The rule exists to stop free-riding by overseas merchants who might otherwise introduce waste into the market and avoid the associated end-of-life costs; it gives the authorities a liable domestic entity to hold accountable.

This requirement spans your entire compliance footprint. You need an authorised representative for your packaging registration with Verpact, your electronics compliance with the Nationaal (W)EEE Register, and any registrations for textiles, batteries, or single-use plastics via the RWS UPV register. Shipping directly to Dutch consumers without an appointed representative leaves your business exposed: marketplaces monitor for valid local EPR registrations and will restrict your ability to trade if your representative is missing. Establishing this local partnership is the first step before you can legally ship a single parcel, device, or garment to a Dutch buyer.

Who has to comply, and the thresholds

For years the Netherlands ran a relatively accommodating system for smaller merchants, particularly those based abroad. Foreign distance sellers benefited from a 50,000 kg per year de-minimis exemption: if the total weight of packaging you shipped to Dutch consumers fell below that threshold, you were exempt from the packaging fees. That let many small and medium e-commerce businesses operate in the Dutch market without the reporting overhead.

This exemption is ending. In alignment with the Packaging and Packaging Waste Regulation 2025/40, the Netherlands removes the 50,000 kg exemption from August 2026. On the day it applies, small and medium sellers shipping into the Netherlands become liable from their very first package, mirroring the zero-threshold regimes already in place in Germany and France.

In practice, if you ship a single box to a buyer in Amsterdam, your compliance infrastructure has to be in place: track the material, report the weight, and pay the fee. Because of the distance-seller rules you cannot do this from abroad alone; you need a local authorised representative to submit the declarations. And do not expect a grace period from the platforms. Major marketplaces act as gatekeepers, verifying that third-party merchants are compliant with national environmental law, and they suppress listings and suspend accounts until your status is proven.

What it costs

When your authorised representative submits your data through the Verpact packaging administration system, your liability is calculated on an eco-modulated, per-kilogram basis. You do not pay a flat rate; your costs are dictated by the materials you use and how easily they can be processed.

The 2026 Verpact rates show why material choice dominates the bill. Paper and cardboard carry a low base rate of EUR 0.017 per kg. Glass is EUR 0.100 per kg and aluminium EUR 0.340 per kg. Rigid plastic, by contrast, is EUR 1.220 per kg.

Because rigid plastic is roughly seventy times the paper rate, the financial logic of packaging design is hard to ignore. A store shipping in heavy rigid plastic faces compliance invoices that eat into margin, while moving the same product into a paper or cardboard format cuts the bill sharply. The system is designed to make poor environmental choices financially painful. On enforcement, the authorities can levy administrative fines and demand retroactive payment for unregistered volumes, but the most immediate pressure comes from the sales channels: unregistered materials get your products pulled from marketplaces before a regulator even issues a fine.

The deposit-return system (statiegeld)

If your catalogue includes beverages, there is an extra layer. The Netherlands runs a statutory deposit-return system known as statiegeld for drinks bottles and cans: a deposit is charged at the point of sale and refunded when the consumer returns the empty container.

Statiegeld is separate from, and additive to, your packaging EPR duties. Paying your Verpact fees on the material weight of bottles and cans does not exempt you from the deposit-return requirements. You participate in both systems at once, managing the deposit logistics alongside your annual material declarations.

Key dates and upcoming changes

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Sources:

• Verpact packaging administration
• Nationaal (W)EEE Register (Stichting OPEN)
• Rijkswaterstaat UPV producer schemes
• RecyBEM tyre recycling scheme
• Packaging and Packaging Waste Regulation 2025/40
• EU Batteries Regulation 2023/1542