Does the PPWR apply to me if I sell to Dutch customers from abroad?
Yes, in many cases it does. The packaging regulation does not look at the country where your company is established, but at the country where the packaging reaches the end user. If you sell products from Belgium, Germany, Poland or another EU country to customers in the Netherlands, you are in practice placing that packaging on the Dutch market. That is the moment that counts, not your business address.
Whether this actually applies to your specific situation depends on a few things: who in the chain first places the packaging on the market, whether you pack yourself or whether another company does that for you, and what type of packaging is involved. These are precisely the questions that the guidelines distinguish, and what supervisory authorities look at in practice.
Why place of establishment is not the starting point
The regulation is built around the concept of "placing on the market": the moment when a packaged product is first made available on the market of a member state. A German webshop that ships directly to Dutch consumers is thus placing the packaging on the market in the Netherlands, even though the company itself is based in Cologne or Berlin. The same applies in reverse: a Dutch company that supplies French customers will have to deal with French obligations, in addition to or instead of the Dutch ones.
This principle explains why cross-border sales quickly lead to multiple registrations. Not because the rules are fundamentally different from country to country, but because each country has its own register and its own contribution system. If you sell to consumers in five member states, you can in principle be faced with five registrations.
When it probably does not affect you
There are situations where the obligation lies not with you, but with another party in the supply chain. For example, if you sell through a marketplace or distributor that already acts as a producer and has the packaging registered, the obligation may already be placed there. Similarly, pure B2B supplies to another business that subsequently puts the packaging back on the market itself may differ from direct sales to consumers. And for small volumes, some countries have an exception, with specific conditions per country.
None of these exceptions apply automatically. They depend on the precise allocation of roles in your supply chain, and this differs per packaging type and per country where you supply. That is also why a simple checklist is not sufficient here: the same webshop may have a different role for the shipping box than for the product packaging inside it.
What this means in practice
If you sell to Dutch customers from abroad and determine the packaging yourself (the brand on it, the choice of material, the filling), there is a real chance that you will be classified as a producer in the Netherlands and must register with the national register. If you are not established in the Netherlands, that register typically works with an authorised representative who handles the registration on your behalf. That is a separate step, separate from the question of whether you fall under the obligation.
Conversely: if you only sell to other businesses that resell the packaging themselves, or if you supply purely incidentally and on a very small scale, it is quite possible that the obligation does not (yet) apply to you. Determining that does require a look per country and per packaging type, as the thresholds and exceptions vary.
How to assess this for your own situation
Because the outcome depends on your role, your packaging type and the specific country, a general answer is not sufficient here. In a few questions you can see in which country you have which role provides an immediate indication, including the associated register and first steps. If you first want to understand how the role determination works precisely and what the indication is based on, you can read that in the explanation about where our information comes from.
For businesses that already know they need to register in multiple countries, the follow-up question is usually practical: how do you set up the packaging dossier, and who guides the registration per country. That overview can be found in the knowledge base with explanation per subject, and what it costs to have registration handled for you, you can see on the page with the subscription rates.
If you are uncertain about your own role in a cross-border situation, that is exactly what the guidelines and the competent supervisory authority in the country concerned are there for. We cite those guidelines and refer you through where it concerns an individual assessment; we do not provide legal advice ourselves on borderline cases.
Are you curious whether this affects your business? Do the free quick-scan or browse through the knowledge bank to first get a broader picture of what applies per country and per packaging type.