Frequently asked questions

On the request of submitters, a Ministry declares an agreement generally binding, which means it is applicable to everyone. Incidentally, this also applies to other things than just packaging. Consider for instance a CAO (collective labour agreement) and also, for example, the producer responsibility for electrical appliances, batteries, etc. 

Stichting Afvalfonds Verpakkingen will ask the Ministry of Infrastructure and Water Management to declare the Waste Management Fee Agreement (ABBO) generally binding. The ABBO outlines how producers and importers will implement the waste management structure collectively. This waste management structure must ensure compliance with the producer responsibility that rests with every producer or importer of packaged products.

An AVV issued on the Waste Management Fee Agreement ensures that all companies that release more than 50,000 kilos of packaging on the market are affiliated to Afvalfonds. The AVV hereby ensures a level playing field. 

For all producers and importers in the Netherlands who release packaged products on the Dutch market or who dispose of packaging after importing products. 

Stichting Afvalfonds Verpakkingen in association with Nedvang, Nederland Schoon, KIDV en Statiegeld Nederland. 

The current AVV was issued in 2017 and runs until 31 December 2022. The new AVV runs from 2023 up to and including 2027. 

The AVV ensures that all producers and importers (P/Is) participate and contribute to the financing of the collection and recycling of all packaging that comes onto the market.

Packaging is increasingly coming under the spotlight and the statutory recycling targets for packaging are getting ever more stringent. The focus is on making packaging more sustainable. This increases the interest of business to continue to adopt a concerted approach. With ever increasing targets, the need for collaboration is growing all the time, with the costs being shared. Afvalfonds is a non-profit organisation. We operate on a not-for-profit basis and are, therefore, as efficient as possible when it comes to administering producer responsibility.

The obligation to pay the waste management fee is the responsibility of all producers and importers of packaging that release more than 50,000 kilos of packaging material on the market in a certain calendar year. The first 50,000 kilos are exempt from the fee. The waste management fee is fixed per category of material. From the waste management fee we pay for costs incurred for collection and recycling of packaging.

For a generally binding declaration a significant majority is required. If too many P/Is decide not to support the request, no AVV is possible. 

This means that you will be personally liable for administering producer responsibility. Amongst other things, your company must contribute towards the collection and recycling of packaging you release on the market and report to the government about the recycling results for this packaging. You also have to ensure you tackle any litter caused by your packaging. Failure to comply with these obligations shall result in government enforcement measures and sanctions for your individual company.

The rates for the waste management fee are based on what it costs overall per category of material to comply with the statutory producer responsibility:

• nett costs generated by a category of material in the chain of collection, processing and marketing minus the (positive or negative) return.
• general system costs. These are, for example, costs for monitoring, prevention of litter and the knowledge institute. They are allocated proportionally per kilo across all categories of material.

You pay the corresponding rate per category of material, per kilo for kilogrammes of packaging notified by you. 

This obligation has been implemented in Dutch legislation from European regulations.

In the past, the majority was demonstrated via trade organisations who supported the request. Now it also goes via the companies actually concerned. 

EU rules have been implemented differently in Europe. The Dutch system has produced excellent recycling results in recent years. The Netherlands leads the way in this. 

Companies that release packaged products on the market are legally obliged to contribute to recycling of their packaging (the producer responsibility). The European obligation has been implemented in Dutch legislation and set out in the ‘2014 Dutch Packaging Management Decree’. 

Verpact has assumed responsibility for this obligation. The collection and recycling of packaging is financed by the companies that release packaged products on the Dutch market. They do this by paying a levy (the packaging waste management fee) for their packaging to Verpact, which pays for the costs incurred of household packaging waste collection and recycling.

The rates for the waste management fee are based on the costs we incur per category of material in the chain of collection, processing and marketing. In addition, we apply a fixed amount for general system costs for each category of material. These are, for example, costs for monitoring, prevention of litter (Supporter van Schoon) and The Netherlands Institute for Sustainable Packaging (KIDV). Given that Verpact is a non-profit organisation, this yields the lowest system costs.

You can correct your declaration at any time via PackTool.

You can correct your declaration for up to the last five years via PackTool. 

Are you dealing with an exceptional situation? We are happy to assist. Call Account support 085-401 26 60 or send an e-mail to info@afvalfondsverpakkingen.nl.

Are you dealing with an exceptional situation? We are happy to assist. Call Account support 085-401 26 60 or send an e-mail to info@afvalfondsverpakkingen.nl.

Every year, you can apply for a refund of indirect export for the previous declaration year up until 1 June. For further information, see here

Direct export

These are goods which you produce and export yourself.
These are goods which you import and export again in the same packaging.

You do not have to file a declaration for direct export.

Indirect export
These are packaged products you have bought in the Netherlands and for which the Packaging Waste Management Fee has already been paid by, for example, your supplier or further up in the chain. If you export these goods in the same packaging, you can reclaim the fee for the corresponding packaging.

First availability
You are responsible for the packaging of all goods you make available, for the first time, in the Netherlands because you produce or import these goods.

Disposal when importing
These are all forms of packaging released after importing the products. Here, it is immaterial whether these goods are discarded in your own warehouse or that of your customer.

You add packaging
Do you add packaging, for example during repackaging or production and is it intended for a Dutch consumer? You must include these kilograms in your declaration.

The Packaging Waste Management Fee applies if a packaged product is released on the Dutch market. Does your customer export the goods in the same packaging? If so, your customer can submit a request for refund of indirect export up to 1 June of the following year.

No distinction in terms of rates is made between packaging ending up with the consumer or removed via a waste collector. All packaging comes under the producer responsibility. By sharing the costs we incur for collection and processing of packaging across all packaging materials, the average rate lowers. That rate would be higher if we were to make a distinction between consumer packaging and packaging companies dispose of themselves, or arrange for such.

You are responsible for correctly determining the weights. The simplest and most reliable method is to weigh the empty packaging yourself, divided up according to the category of material. Your purchaser can help you by setting out in the purchase contract exactly how the products are packaged and the applicable weights, or arranging for such.

Do you use data of third parties? If so, you are obliged to verify this.

Generally, no. Suppliers often use different definitions and their specifications do not contain sufficient detail. You are ultimately responsible for correctly determining the weights. The simplest and most reliable method is to weigh the empty packaging yourself, divided up according to the category of material.

The easiest way of setting up your packing administration depends on your organisation. Via our packaging administration guide, we can help you get started. Prefer personal support? We are at your service. Call Account support 085-401 26 60 or send an e-mail to info@afvalfondsverpakkingen.nl.

Organisations that file a declaration to Verpact are contained in the List of participants.

Verpact actively looks for companies that incorrectly fail to file a declaration and these companies are contacted for a closer investigation. 

Yes. You can notify us anonymously or otherwise. Here, it is important that we have the name and address details of the company. We do not provide any individual feedback about the follow-up and outcome of any notification submitted. You can notify us in writing, e-mail or by phone. 

It is possible that your supplier is on our list under another name than its well-known trading name, that payment was made further up in the chain or that another reason exists. It is important to find out from your supplier if a declaration has been filed for your items and can be verified. If this is the case, you can submit the request for the refund of indirect export. 

You file a declaration about:

•    The packaging around the imported products.
•    The transport packaging you add and/or arrange to be added.

Likely unable to obtain a reliable statement from your suppliers? Identify the weights yourself by weighing the packaging. How many times you have to weigh them and how depends on your packing administration.

For additionally acquired packaging you can conveniently weigh the empty packaging yourself and retrieve the number of units via the annual statement from your supplier. Ensure that this annual statement is part of your file.

You file a declaration for packaging if it is being released on the Dutch market for the first time. Do you use a box twice or more, for example? You are only required to declare the box once. What matters is that the box has entered into free circulation.

So, if you receive import goods in a box and use the same box again to send other goods, you will file a declaration once for this box.

Do you buy second-hand boxes? It is important that you know for definite if they have already entered into free circulation in the Netherlands (if so, you do not have to file a declaration) or that it concerns foreign boxes or stock boxes from a warehouse and, therefore, not yet entered into free circulation (in this case, you will file a declaration).

No. If you release on the market less than 50,000 kilos of packaging you do not have to file a declaration. It is important that you assess on an annual basis whether you still release less than 50,000 kilos of packaging on the market.

You might be contacted to take part in a quick survey which is carried out to generate a full picture of the packaging on the Dutch market.

An exception being the plastic bottles and cans which come under the deposit scheme and packaging that falls under de SUP regulation. 

No. You only file a declaration for packaging you use as such. The empty boxes constitute an end product. The packaging around the boxes (for shipping for example) counts as packaging.

Afvalfonds Verpakkingen has a single declaration entity that corresponds to the VAT grouping. If you are part of a tax entity for VAT, one of the companies of the tax entity will file a declaration for all.

No. All operations carried out by a logistics provider on your behalf are taken into account in your declaration. Therefore, it is important for you to know precisely which packaging your provider adds. Unpacking, repackaging, plastic wrap, etc. also come under your responsibility.

Does it merely concern repackaging and/or labelling of goods? Then the contract packer is your logistics provider and all packaging here is taken into account in your declaration. If your provider does more, assembling goods for example, the provider is a producer and must file the declaration themselves.

Yes. As soon as you file a declaration or notification, an acceptability check is done. In addition, you may be selected for verification. We will come to you and carry out a check often together with an independent accountant. Amongst other things, evidence of your declaration forms part of this inspection and we check the declaration in terms of correctness and completeness. So, it is important that you keep the packing administration in order.

Do you use the pallets once? Then you include this in the declaration but not pay any Packaging Waste Management Fee. Do you use the pallets more than once? If so, you are not obliged to file a declaration. Pallets come under logistics resources. You can use this scheme only if your logistics resource is on this list.

You can log in using the registered e-mail address and the password you have chosen for your registration. If you have forgotten your password, you can re-set it by using the link displayed on the login screen. In case of other problems logging in, please contact us.

You can log in in PackTool using the familiar e-mail address of the first declarer and the password you have created yourself. If you have forgotten your password, you can re-set it via the link you see when you log in.

If you have any other problems when logging in, please contact us.

See the process here. This way you know precisely what you can expect and when.