When does the 50,000 kg threshold disappear in the Netherlands?

The threshold is expected to expire from August 2027 onwards

The Dutch threshold of 50,000 kg of packaging per year will expire as soon as the PPWR producer register becomes operational, which is expected to be no earlier than 12 August 2027. Until that date, under Verpact, anyone placing less than 50,000 kg of packaging per year on the Dutch market does not need to register — although record-keeping remains required. Once the new register becomes operational, that threshold will be removed and replaced with a different system: the first reporting year is expected to be 2028, with submission before 1 June 2029. For companies under 10,000 kg, a simplified submission is provided, but this is a lighter form of participation, not an exemption.

It is important to note that this threshold is a Dutch peculiarity, not a European standard. The PPWR itself does not contain a 50,000 kg threshold: packaging may not be placed on the market without the producer being registered in the producer register of each country where they first place it on the market. Until the new register becomes operational, the Netherlands chooses to keep small quantities outside the registration obligation, but in Germany, for example, no threshold applies: whoever sells one package there is a producer from that package onwards and must be listed in LUCID. Anyone staying below the Dutch threshold while also supplying abroad is therefore not automatically exempted everywhere.

Where this is based on: Article 44 and the Verpact overview

The obligation to register in the producer register of each country of first placing on the market follows from Article 44 of Regulation (EU) 2025/40; packaging from an unregistered producer may not be placed on the market. The exact date on which the Dutch threshold expires has not yet been laid down in legislation but follows from the expectation expressed by Verpact itself based on the entry into force of that European register.