Administration
Who for: all producers and importers of packaging who are obliged to file a declaration to Verpact
When: starts in 2027 and will grow in step with the data from subsequent legislation
Conformity
All producers and importers must demonstrate that their packaging complies with all PPWR rules with a declaration of conformity.
- On the basis of a conformity assessment, the “manufacturer” assesses whether the packaging is in compliance and subsequently prepares a declaration of conformity. This declaration, including an overview of the materials present in the packaging (incl. weight), must be available for The Human Environment and Transport Inspectorate, in the case they would request this information. Suppliers are obliged to provide information.
- Distributors and retailers are obliged to check whether packaging they import/purchase comes with a declaration of conformity.
Conformity assessment rules can be found in Appendix VII of the PPWR and contain the following, amongst others:
- Description of the packaging and intended use
- Design drawings
- Materials used (including weight)
- Standards/norms used (if applicable)
- Description of how the requirements in Articles 6 (recyclability), 10 (minimisation) and 11 (reusability) have been met.
Declaration
Filing a declaration is mandatory from 2027 for anyone who comes under the definition of “producer” (likely broadly equivalent to the current definition of producer/importer in the Netherlands at present). Packaging administration is divided into 22 different packaging types, plus any SUP packaging, and this includes having to specify the weight (broken down per material).
Smaller businesses (< 10,000 kg packaging on the market annually) are not required to file a declaration for packaging categories but merely specify an overview of the weight of the used materials.
Current packaging administration will be extended to include at least:
- The RPG, also as proof and for inspection for the Dutch Human Environment and Transport Inspectorate (ILT).
- The weight of all separately used materials.
- From 2027, it will be mandatory to provide information in a National Packaging Register (for the time being: organised via Verpact) and information from the register must be sent earlier in the year to the government by Verpact.