The shortest answer to the question of whether the PPWR applies to small businesses: yes, there is no general exemption.
The substance restrictions apply. The traceability obligation applies. The declaration of conformity applies. The recyclability grade applies. The EPR registration applies.
What there is, is a few specific exemptions. They are narrower than they sound.
What counts as a micro-enterprise
The PPWR refers for the definition to Recommendation 2003/361/EC.
| Category | Employees | Turnover or balance sheet total |
|---|---|---|
| Micro | < 10 | ≤ €2 million |
| Small | < 50 | ≤ €10 million |
| Medium | < 250 | ≤ €50 million |
Both conditions must be met, not just one of the two.
Not sure which of these rules apply to you?
Eight questions. No account. You get a scorecard per pillar — green, amber, red — with, for each red pillar, what you concretely need to arrange and which suppliers do it.
Start the PPWR Check →The exemptions that do exist
Reuse targets. Micro-enterprises are exempt from the reuse percentages in Article 29 — the 10% reusable beverage packaging in 2030, the 40% transport and e-commerce packaging. Implementation runs via delegated acts; the precise conditions are not yet fixed. Treat this as provisional.
And possibly something around the manufacturer role. Here we must be careful. The idea circulates that micro-enterprises are, under conditions, exempt from the manufacturer obligations — including the declaration of conformity — provided their packaging supplier is established in the Netherlands. That reading comes from industry information and is not stated in so many words in the regulation text.
Do not assume it applies to you. If you are a micro-enterprise and buy your packaging from a Dutch supplier, this is a question to put to Verpact or to a compliance adviser — not a conclusion on which to base your preparation. The difference between being exempt and not is the difference between packaging that may go on the market on 12 August 2026 and packaging that may not.
That is all there is. And one of those two is not a certainty.
The 50,000 kg threshold is not a PPWR exemption
This is the most persistent misconception among Dutch SMEs.
Below 50,000 kg of packaging per year you do not have to pay a waste management fee to Verpact. Fine. But:
- It is a total threshold across all materials combined — not 50,000 kg per material type.
- Below the threshold the fee lapses, not the administration. You must still know and be able to demonstrate what you place on the market.
- 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 itself.
A company with 20,000 kg of packaging per year pays nothing to Verpact and must nonetheless: use PFAS-free food packaging, put its name and an identification number on the packaging, draw up a declaration of conformity per packaging type, and reach class C in 2030.
See EPR registration under the PPWR.
And then Germany
If there is one thing that gets a small Dutch company into trouble, this is it.
Germany has no threshold whatsoever. Whoever places packaging on the German market that ends up with a private end user registers in LUCID before the first shipment and enrols in a dual system.
One pallet. One trial shipment. One German customer via your webshop. Since 1 July 2022 this expressly also applies to foreign webshops.
If you do not: sales ban, and a fine of up to €200,000.
A sole proprietorship that sends something to Germany once a year falls under this. The Dutch threshold of 50,000 kg plays no role at all. See Netherlands and Germany.
Where SMEs do have room to breathe
Not in the law, but in practice.
Your portfolio is smaller. Inventorying and documenting fifteen packaging types is a matter of weeks, not years. A corporation with two thousand SKUs needs a project organisation; you need a spreadsheet.
You can pivot faster. The material switch that has to go through four departments at a large company, you make in one conversation with your supplier.
Your supplier has to provide you with data. Under the PPWR, suppliers are obliged to provide the information with which the manufacturer can demonstrate conformity. That is a right you can exercise, even as a small buyer.
What you can do now
- Determine your role per packaging. Not per company. Is your logo on it? Then you are the manufacturer. See roles.
- Inventory your packaging types. Material, weight, food contact yes or no.
- Ask your supplier for the data. Material composition, total fluorine at food contact, the standard on which the recyclability claim rests.
- Check whether you supply to Germany. Even once. Even via your webshop.
- Draw up the declarations of conformity. One template, filled in per packaging type.
Anyone who in August 2026 still has to start with step 2 gets stuck — not on the fine, but on a supplier that has itself set up nothing yet and cannot provide data.