Extended producer responsibility — EPR — has existed for years. What the PPWR changes is not the principle but the scope, the enforcement and the price.
From 12 August 2026: no registration, no market access. And you register per member state where you sell.
Where you have to register
Netherlands: with Verpact.
Germany: in the LUCID register at the Stiftung Zentrale Stelle Verpackungsregister, plus enrolment in a dual system.
If you place packaging on the market in a member state where you are not established, you appoint an authorised representative there. In Germany this role is called a Bevollmächtigter. It handles registration and fees on your behalf.
This is not a formality. Germany has no threshold: a single shipment to a German consumer without LUCID registration results in a sales ban and a fine of up to €200,000. See Netherlands and Germany.
Who is the producer? The definition shifts
This is the part that actually changes on 12 August 2026, and that is missing from most summaries.
The producer is whoever first places a packaging or packaged product on the market in a member state. Not whoever makes it — that is the manufacturer. See roles under the PPWR.
Three consequences:
1. The declaration on import shifts. The “disposal on import” stream is no longer declared by the Dutch company that unpacks the goods, but by the foreign sender or the logistics service provider. This ties in with the rule that whoever supplies an end user counts as the producer in that end user’s country.
2. Contract packing is no longer exempt. A logistics service provider that unpacks and discards packaging must declare that packaging — even if the goods are not its own. A fulfilment party that unpacks a shipment from abroad and repackages it for distribution in the Netherlands declares the unpacked packaging.
3. Shipping, e-commerce, service and primary production packaging get a manufacturer, and on sale in the Netherlands thereby also a producer. Whoever produces that packaging declares for the period from 12 August 2026, after the end of that calendar year.
Stock that fell under the old definition before 12 August is still declared for calendar year 2026 by the original producer or importer — even after that date.
Not sure whether this applies to your packaging? The PPWR Check walks through your role, market and material in eight questions and shows per pillar what applies to you. Take the PPWR Check →
The scope widens
Under the PPWR all packaging falls under EPR: primary, secondary, tertiary, transport, e-commerce. Also wood, glass and industrial transport packaging.
For companies that until now only declared their consumer packaging, this means a larger declaration and a higher fee.
Eco-modulation: your rate will soon hang on your design
This is the provision with the most financial impact and the least attention.
The EPR rates are mandatorily modulated based on the recyclability grade of your packaging. Poorly recyclable packaging becomes more expensive; classes A and B get a discount. The rollout is phased and must be fully harmonised around 2029.
That means you must be able to show your recyclability grade not only to the market surveillance authority, but also to Verpact — annually, per packaging type.
The incentive is already working ahead. Verpact doubled the recyclate discount to €0.20 per kilo, against a plastic rate of €1.22 per kilo and a paper-and-cardboard rate of €0.017 per kilo. Those were the 2025 rates; they are revised annually and are published on verpact.nl.
So the difference between plastic and cardboard is roughly a factor of seventy. For those who can switch, it pays for itself long before a delegated act forces anything.
The Dutch threshold of 50,000 kg
Below 50,000 kg of packaging per year you do not have to pay a waste management fee. Three things that structurally go wrong here:
- It is a total threshold across all materials combined.
- Below the threshold the fee lapses, not the administration.
- The SUP levy has no threshold. Single-use plastic packaging you pay from the first kilo.
And above all: it is an EPR threshold. It says nothing about the PPWR. The substance restrictions, the traceability obligation and the declaration of conformity apply regardless of your volume. See PPWR and SMEs.
What is still to come
In the Netherlands a national producer register is being set up in which all producers must register. Expected 2027 or 2028; the exact date and form have not yet been established. Keep an eye on AfvalCirculair and Verpact.
In addition, the Besluit beheer verpakkingen 2014 (the Dutch packaging decree) and the existing EPR system are being revised to comply with the PPWR frameworks. Expect adjustment or repeal between 2026 and 2028.
What you can do now
- Check that your registration matches your new role. The definition shifts on 12 August; your current declaration may be incorrect afterwards.
- Map your declarable streams, including transport and e-commerce packaging you never declared before.
- Do you supply abroad? Arrange the representative now. In Germany there is no threshold below which you can postpone it.
- Calculate what eco-modulation will cost you at your current material mix. That figure makes the internal conversation about redesign easier than a reference to 2030.