Many small webshops and importers knew Verpact mainly from the exemption: if you placed packaging material below a certain amount per year on the Dutch market, you did not need to register and did not have to contribute. That threshold has been abolished. Anyone who places packaging material on the Dutch market is now in principle subject to Verpact registration, regardless of the quantity.
In practice, this means that businesses that were previously excluded — a sole trader shipping a limited number of packages per year, an importer with a small range — must now check whether registration applies to them. Whether it does depends on your role in the supply chain and the type of packaging you use. You can have this determined in a few questions, without needing an account first.
Why this threshold has disappeared
The European packaging regulation aims to create a more complete picture of which packaging is placed on the market in each member state, so that recycling targets and producer responsibility actually apply to all packaging and not just larger volumes. A national threshold that excludes small quantities does not fit well with this. The Netherlands has therefore removed its own threshold, which means the registration obligation now applies in principle to a broader range of businesses than before.
It is important to distinguish this from the so-called micro-exemption in the regulation itself, which addresses something different and is subject to other conditions. The abolished Dutch threshold concerned the notification requirement at the national register; the micro-exemption addresses a specific category of small businesses under the European rules. Both topics often overlap in practice, and the precise conditions are set out in the knowledge base by topic.
What practically changes
If you previously fell below the threshold and have never reported anything to Verpact, something may now change for you: registration, annual reporting of quantities, and depending on your situation a contribution. If you were already above the old threshold, little changes for the registration obligation itself; the way you report may be tightened as the broader PPWR requirements are further implemented.
It is important to note that the abolition of the threshold itself says nothing about what role you have — manufacturer, importer or distributor — and that your role determines exactly what is required of you. A webshop that packages and ships itself is often treated differently than a shop that resells ready-made products from a European supplier.
Who can fall outside this
Not every business that ships something automatically falls under the registration obligation. Those who exclusively use third-party packaging without bearing responsibility for it, or who fall under one of the exemptions in the regulation, can remain outside the registration requirement. This is precisely why a generic rule of thumb does not suffice here: the outcome differs per business and per packaging type, and the guide is built to show that outcome per situation rather than speak in generalities.
What you can do now
The abolition of the threshold is for many businesses above all a reason to check again whether registration applies to them, not to take action immediately without knowing. Start with the question of what role you have per packaging type; that determines whether, and where, you must register. If you subsequently want to know how such registration works and what documents are needed, you can read on how the guidance is structured where the underlying information comes from.
Epria will not become a waste management organisation in this process, will not collect contributions on your behalf, and will not issue a legal judgment in cases of doubt — instead we cite the guidelines and refer you to the competent authority or a lawyer. What we do is guide you through registration in each country and maintain an overview of what applies where, including the costs associated with it on the pricing page.
Are you curious whether the removal of the threshold changes anything for your business? Take the free quick-scan or go through the role finder — within a few minutes you'll know where you stand, without needing to create an account.