EPR in the Netherlands: What Will Change in 2025 and What Companies Need to Know Now
As an EU member state, the Netherlands is required to transpose EU EPR directives into national law. This results in specific obligations for companies across multiple areas of Extended Producer Responsibility (EPR). As of 2025, four EPR schemes apply in the Netherlands:
- Packaging & Deposit Systems
- Electrical and Electronic Equipment (WEEE)
- Batteries
- Textiles
In this article, we summarize the current obligations for companies, highlight recent changes (e.g., due to the new EU Battery Regulation 2023/1542), and provide practical implementation tips.
For Quick Readers
- Who is affected? Manufacturers, retailers, and importers placing products on the Dutch market.
- What needs to be done? Registration, reporting of placed quantities, payment of fees, and in some cases, take-back and information obligations.
- New in 2025: The EU Battery Regulation introduces new requirements on carbon footprint, battery passport, recycling targets, and more.
Key Information on EPR for Packaging in the Netherlands
Since 2014, the Packaging Management Decree (Besluit Beheer Verpakkingen) has applied. It covers various packaging categories such as beverage cartons, composite packaging, reusable packaging, and packaging components (labels, etc.). All companies placing over 50,000 kg of packaging material on the Dutch market must:
- Register with Afvalfonds Verpakkingen
- Report packaging quantities for the previous year annually
- Pay an annual packaging fee (consisting of an advance estimate and final settlement)
Reporting is done electronically via the Afvalfonds portal. Companies receive an initial invoice based on an estimated amount for the current year. A final invoice is issued based on the actual quantities placed on the market.
Additional Obligations
- Reporting to the Ministry of Infrastructure and Water Management: In addition to reporting to Afvalfonds, a separate notification is required.
- Product labeling requirements: For certain packaging types, indicating material composition and recycling instructions is mandatory.
- Design requirements: Packaging must be designed for recycling. This includes avoiding black plastics and using mono-materials.
- Documentation: Companies must document all relevant records and calculations and be able to present them during audits.
Furthermore, companies are expected to contribute to the financing of collection, sorting, and recycling infrastructure—e.g., via licensing fees managed by Afvalfonds.
EPR for Electrical and Electronic Equipment in the Netherlands
The implementation of the EU WEEE Directive in the Netherlands is managed by the OPEN Foundation, which acts as the central organization for producer responsibility in the EEE sector.
Summary of obligations:
- Registration: Companies must register with the OPEN Foundation before placing electrical and electronic equipment on the Dutch market.
- Reporting: Annual quantity reporting is done via the OPEN portal.
- Reporting duties: Legally required reports are submitted through OPEN and forwarded to the Ministry of Infrastructure and Water Management.
- Take-back obligations: End users must be able to return old devices free of charge. Companies must create a take-back concept for commercial customers.
- Information obligations: Producers and importers must inform end users about disposal and recycling options. There is no universal labeling requirement, but symbols like the crossed-out wheeled bin are common.
EPR for Batteries in the Netherlands
Since February 2024, the new EU Battery Regulation replaces the previous directive and applies directly in all member states. It introduces major changes:
New obligations starting in 2025 and beyond
- CO₂ footprint: Disclosure from 2025, limits from 2027
- Recycling targets: Increasing quotas by 2030 (e.g., lithium batteries: 70%)
- Recycled content: Minimum thresholds for cobalt, lithium, nickel, and lead from 2031
- Battery passport & QR code: Digital product passport for industrial, traction, and e-bike batteries from 2026
- Removability: Batteries must be easily replaceable by 2027 (including for consumers)
- Due diligence: Environmental and human rights standards along the supply chain
What companies need to consider
- Registration, e.g., through organizations like Stibat
- Take-back systems and consumer information are mandatory
- Applies also to built-in batteries in devices
EPR for Textiles in the Netherlands
The Netherlands was a pioneer: since mid-2023, a national-level EPR scheme for textiles is in place. Companies must:
- Register with a recognized EPR system
- Report expected quantities
- Provide collection containers
- Offer take-back options for online customers
An EU-wide regulation is in planning but has not yet been adopted.
As experts in international EPR compliance, we support you with fulfilling your obligations in the Netherlands and beyond. Contact us for individual consulting, a compliance check, or hands-on management of your registrations.
