Netherlands and Belgium: one threshold under question, one that doesn't exist

Netherlands: Verpact's threshold

Dutch packaging EPR is run by Verpact (formerly Afvalfonds Verpakkingen). Its published guidance: if you can show that you place less than 50,000 kg of packaging a year on the Dutch market, you don't file a declaration and don't pay the contribution.

• You must be able to show it. Keep packaging weight records.
• Exceptions: single-use plastic items and deposit packaging are registered regardless of quantity.

The open question: does it survive the PPWR?

Belgium's regulator states that there is no de minimis in the PPWR itself. If that reading holds EU-wide, the Dutch threshold could narrow to relief from the Dutch contribution, not from being a producer. Verpact had not published a change as of the date above. Keep records either way, and if the Netherlands is a real market for you, ask Verpact directly.

Belgium: no threshold

The 300 kg figure often quoted for Belgium is a scheme screening number, not a legal exemption. A foreign company that sells packaged products directly to Belgian end users is generally the producer there.

• Authorised representative in Belgium, if you have no Belgian establishment.
• Join a scheme: Fost Plus for household packaging (Valipac for industrial packaging).
• Registration is handled through the scheme. Under 10 tonnes a year, the annual report is simplified.