Afvalfonds Verpakkingen: Dutch Packaging Law for Online Sellers

The Netherlands has one of the more unusual packaging compliance structures in the EU. While most countries use a straightforward producer responsibility organisation (PRO) model, the Dutch system involves two separate legal instruments operating in parallel: a Packaging Tax (Verpakkingenbelasting) levied by the Dutch tax authority, and a producer responsibility obligation managed through Afvalfonds Verpakkingen. Understanding which system applies to you, and how they interact, is the starting point for any seller shipping to Dutch consumers.

The Netherlands is the fifth-largest e-commerce market in Europe by revenue, and Dutch consumers are among the highest-spending online shoppers per capita. If you sell to European consumers broadly, there is a high probability that a material share of your orders go to the Netherlands — and that means you have packaging obligations here.

The Two Dutch Packaging Systems

Afvalfonds Verpakkingen (producer responsibility)

Afvalfonds Verpakkingen is the Dutch Producer Responsibility Organisation for packaging. It was established under the Packaging Decree (Besluit beheer verpakkingen, 2014) and is funded by levies from companies that place packaging on the Dutch market. The money collected goes toward financing the collection and recycling of packaging waste from Dutch households.

Afvalfonds does not collect packaging itself. It contracts with municipal waste management systems, provides funding to support kerbside collection, and coordinates the national recycling infrastructure. Your obligation to Afvalfonds is to register, report your packaging volumes, and pay the associated contribution.

Verpakkingenbelasting (Packaging Tax)

The Dutch Packaging Tax is a fiscal instrument, not a PRO levy. It is administered by the Belastingdienst (Dutch Tax and Customs Administration) and was introduced in 2023. The tax applies to companies that place packaging on the Dutch market above a threshold, with the rate varying by material type.

Crucially, the Packaging Tax and the Afvalfonds contribution are separate obligations. Paying one does not satisfy the other. However, there is a mechanism by which participation in the Afvalfonds system (or another approved collective system) can reduce or eliminate your Packaging Tax liability. This offset mechanism is what makes the two systems interact — and it is why understanding both is essential.

Who Must Register with Afvalfonds

The obligation applies to companies that place more than 50,000 kg of packaging on the Dutch market per year. This threshold is significantly higher than the thresholds in most other EU countries, which means that many small-to-mid-size e-commerce brands fall below it.

However, "below the threshold" does not mean no obligation. Companies placing between 50 kg and 50,000 kg of packaging on the Dutch market per year must:

• Register with the Afvalfonds notification system (melding)
• Submit an annual declaration of packaging volumes
• Pay the Packaging Tax to the Belastingdienst if applicable (no Afvalfonds contribution at this scale, but the tax may apply)

Companies below 50 kg per year have no practical reporting obligation, though the legal obligation technically exists.

What counts as "placing on the Dutch market"?

The same broad definition used across the EU applies here: if your packaged product ends up in the hands of a Dutch consumer, you have placed packaging on the Dutch market. This includes:

• Direct-to-consumer shipments from abroad (cross-border e-commerce)
• Sales through Dutch marketplaces (bol.com, Amazon.nl) where you are the seller
• Products sold through Dutch retailers if you are the manufacturer or importer into the Netherlands
• Inventory stored in Dutch fulfillment centers and shipped from there

Registration and Declaration Process

Below 50,000 kg: notification registration

Companies in the 50 kg to 50,000 kg band register through the Afvalfonds notification portal (meldpunt). The process involves:

• Registering your company with your VAT number and company details
• Submitting an annual declaration of the total weight of packaging placed on the Dutch market, by material category
• The deadline for the annual declaration is March 31 for the prior calendar year

Above 50,000 kg: full Afvalfonds participation

Companies placing more than 50,000 kg per year on the Dutch market must participate fully in Afvalfonds Verpakkingen. This involves:

• Full registration as an Afvalfonds participant
• Annual reporting in a more detailed format, with packaging broken down by material type and packaging level
• Payment of the Afvalfonds packaging contribution, calculated at rates set annually
• Optional: participation in an industry collective agreement (brancheovereenkomst) that may provide an offset against the Packaging Tax

The Packaging Tax (Verpakkingenbelasting)

The Packaging Tax applies to companies importing packaging or packaged products into the Netherlands from outside the Netherlands, with an annual packaging volume threshold. For 2026, the relevant threshold is packaging imported above 15,000 kg per year from outside the Netherlands.

The tax rates for 2026 are:

The Packaging Tax is declared and paid through your Dutch VAT return process if you are VAT-registered in the Netherlands, or through a separate filing process if you are not. Non-Dutch companies without a Dutch VAT number may need to appoint a fiscal representative.

The offset mechanism

Here is the key interaction between the two systems: companies that participate in an approved collective packaging agreement (brancheovereenkomst) recognized by the Dutch government can offset their Packaging Tax liability. Participation in Afvalfonds Verpakkingen as a full contributor, or membership in certain industry sector agreements, provides the basis for a full or partial offset.

In practical terms, for large companies placing significant packaging volumes, participation in Afvalfonds and a qualifying sector agreement can neutralize the Packaging Tax entirely. The net cost then becomes only the Afvalfonds packaging contribution. For smaller companies subject to the Packaging Tax but not Afvalfonds participation, the tax must be paid without offset.

Afvalfonds Contribution Rates

For companies that do qualify for full Afvalfonds participation, the 2026 contribution rates are:

Practical Implications for E-commerce Sellers

For most small-to-mid-size e-commerce brands selling to Dutch consumers, the practical reality is:

• Annual packaging below 50 kg: No practical obligation. Keep records in case you grow.
• Annual packaging 50 kg to 15,000 kg: Register with Afvalfonds notification system and submit annual declaration. No Afvalfonds contribution. Packaging Tax may apply depending on import structure.
• Annual packaging 15,000 kg to 50,000 kg: Register with Afvalfonds notification system, submit annual declaration, and assess Packaging Tax liability (file with Belastingdienst).
• Annual packaging above 50,000 kg: Full Afvalfonds participation required, including contributions. Packaging Tax offset may apply through sector agreement.

For most e-commerce sellers, the first step is calculating your actual Dutch packaging volume. If you ship, say, 2,000 orders per year to the Netherlands with an average of 350g of packaging per order, your total is 700 kg — well below the Afvalfonds full-participation threshold but in the notification band. Your obligation is registration and annual reporting, not contribution payments.

Material Categories for Dutch Declarations

Dutch packaging declarations use the following material categories, aligned with EU PPWR categories:

• Paper and cardboard — corrugated boxes, folding cartons, paper bags, paper tape, tissue paper
• Plastic — poly mailers, bubble wrap, plastic film, rigid plastic trays, EPS foam
• Glass — glass bottles, jars
• Metal — ferrous — steel tins, steel closures
• Metal — aluminium — foil, aluminium lids
• Wood — pallets, wooden crates
• Other — composite materials, ceramic, biodegradable plastics

As with other EU markets, you will need accurate packaging BOMs for each product you sell. The packaging BOM guide covers how to build these systematically.

Comparing the Netherlands to Other EU Markets

Marketplace Requirements

bol.com, the dominant Dutch marketplace, has EPR compliance requirements for its sellers. As of 2025, bol.com requests packaging registration information from third-party sellers as part of its seller verification process. Sellers who cannot demonstrate compliance may face restrictions. Amazon.nl operates under the broader Amazon EU compliance framework.

If you sell through bol.com specifically, confirm directly with the platform what documentation they require and in what format — bol.com has its own seller compliance portal separate from Amazon.

Getting Started

The minimum steps to get Dutch packaging compliance in order:

• Calculate your annual Dutch packaging volume by pulling Netherlands order data and multiplying by your packaging BOMs
• Determine which obligation band you fall into (below 50 kg, 50 kg to 50,000 kg, or above 50,000 kg)
• Register with Afvalfonds notification system if you are above 50 kg
• Assess your Packaging Tax liability with the Belastingdienst if your packaging imports exceed 15,000 kg
• Submit your annual declaration by March 31

The Dutch system is genuinely more complex than most EU markets due to the dual-system structure. If the Packaging Tax offset mechanism applies to your situation, working with a Dutch compliance consultant to structure this correctly is worth the cost.

For context on how the Dutch system fits within the broader EU picture, see our guide to EPR compliance for e-commerce and the overview of EPR fees across EU markets. The incoming PPWR regulation will harmonize some of these differences from August 2026, but the dual-system structure of the Netherlands is likely to remain a national peculiarity. If you also register in Belgium (Fost Plus) and France (CITEO), the multi-country EPR strategy guide explains how to sequence those registrations efficiently.