Due to all the changes and upcoming new EU legislation, the packaging administration has become more complex. Therefore, we have modified the structure of the declaration and declaration form.

Previously, the form had a heading for each material type, and below it, all the types of packaging that could be reported were listed. This made the form very long. From now on, a separate line has been created for each type of packaging. You can specify both the quantity of packaging placed on the market (SUP and deposit) and the weight per material in different columns. For deposit bottles and plastic bottles without a deposit, in the case of PET, you can indicate both the recycled material used as well as the virgin plastic.

To ensure that the declaration is logical for you, it consists of a structure with 3 to 5 fields:

1. A questionnaire screen: Here, we ask, among other things, which packaging you will be declaring to provide you with the most lean form in subsequent screens.

2. The taxed packaging form: All the packaging you, as a producer/importer, place on the market.

3. The indirect export form: All the packaging for which another producer/importer has already declared to us for the same period, and that you have exported.

4. The Fee Modulation form: Here, you can indicate for which packaging you are claiming fee modulation, and on what basis.

5. A summary, in which all declared quantities and weights are listed, the threshold correction is processed, and the waste management contribution to be paid or received is calculated. If this matches your expectations, you can submit the declaration.

To prevent some common mistakes, several adjustments have been made:

• Combinations of packaging types and material types that cannot occur are no longer allowed to be declared. There is no longer a field for this. An example is "other material types" for beverage cartons.
• For some packaging types, filling in certain material types is mandatory because they always occur. Examples include:
  • For beverage cartons: paper and cardboard, plus plastic.
  • For packaging covered by the SUP legislation: plastic (rigid, flexible, or both).
• For reusable packaging, you are required to report both the first use and the total sales (this includes the initial use, but you do not pay again for this). We calculate the final reuse.

Which properties of your packaging do you register?

For each packaging, you register the materials consumed and the weight of each of these materials. You also do this when the materials are inseparably connected (such as in the case of a beverage carton). Multiplied by the quantity of packaging placed on the market in a calendar year, this forms the basis for your declaration. The aforementioned information is obtained from your packaging designer or supplier, your foreign supplier (in the case of imports) from the bill of materials (BOM, in the case of purchasing packaging that you add for transport), or from your waste processor (for the packaging from which you dispose when imported).

The weight of the packaging, multiplied by the rates per kg established by us, forms the basis for the amount of the waste management contribution we charge.

For invoicing, we use a threshold of 50,000 kg per calendar year. We only invoice when you place more than 50,000 kg of packaging on the market, or the basis for the invoice is reduced by 50,000 kg. This reduction is pro rata to the weight of the declared packaging and materials.

There are some exceptions to these basic rules:

• Some packaging types have a packaging rate and no material rate, such as beverage cartons, reusable packaging, and particularly reusable plastic drink cups. This means that the rate charged for all materials is the same and differs from the regular material rate. However, you must still report these materials separately.
• For packaging falling under the SUP legislation, you must indicate both the weight and the quantity of packaging placed on the market, as required by the legislation. Packaging falling under the SUP legislation is exempt from the threshold correction we apply as described above.
• Plastic beverage bottles and beverage cans up to 3 liters with a deposit must be reported to both us and the Statiegeld Nederland system. Here, you also specify both the weight and the quantity. The rate you pay us is lower and covers our system costs.
• For packaging consisting mainly of plastic, we have introduced Fee Modulation Plastic 2.0, and from 2024, you can receive fee discounts for the plastic used if the packaging demonstrably contributes to increased recycling. Only packaging for which you normally pay the regular material rate for plastic qualifies for this. You can claim the discount in a specific form within the declaration. There are 5 discount steps of 10 cents per kg, based on color, use of mono-material, the effect of the label on recyclability, compliance with the KIDV Recycle Check, and the use of recycled post-consumer material.
• In the past, it was agreed by parties that logistics resources are not subject to charge. For now, we are following this agreement. Because these are considered packaging, we must include them in our reporting and therefore inventory them. Therefore, we ask you to report single-use logistics resources, but you do not pay a fee for these. We inventory reusable logistic aids in collaboration with pool managers.
• Other reusable packaging is reported to us, but at a low rate when you first introduce the packaging to the market. Additionally, you report the total sales of reusable packaging, so we can calculate reuse.

If you purchase packaged products from a Dutch supplier and then export them, this constitutes indirect export. If you can demonstrate that your Dutch supplier has paid the waste management contribution on the packaging to us, you can receive this contribution back from us. You do this in a separate form for "indirect export. NOTE: For plastic, there is a refund rate that is lower than the normal rate for plastic. This is because some packaging qualifies for Fee Modulation. 

Which properties of your packaging do you register?

As a result of various additional legislation, a large number of new packaging types have been added. Additionally, some packaging types have been renamed because they were no longer complete or because the naming could potentially be confusing.

Here is an overview of all combinations of materials and packaging categories that we use for the 2023 declaration, as well as the combinations that will apply in 2024. We have added a description for each packaging category, which you can find here.

Starting from 2024, the material type 'plastic' will be divided into rigid plastic (with a rate of €1.22 per kg) and flexible or unspecified plastic (with a rate of €1.32 per kg). If you are unsure whether your plastic is rigid or flexible, you should classify it as flexible or unspecified plastic. Further explanation to determine whether plastic is rigid or flexible can be found on slides 10 through 12 of this presentation.

• For all packaging falling under the SUP legislation, you must report both the weight (in kilograms) and the number of packaging units marketed (in pieces). Different rules apply to specific sub-types of packaging, such as beverage packaging, certain rigid or flexible food packaging, each with a different rate linked to their unique collection method. Consequently, the number of packaging categories has significantly increased.
• Rigid food packaging, with or without a lid, and drinking cups subject to the SUP legislation must be reported starting from 2022. Food pouches and wraps, beverage packaging, and lightweight plastic carrier bags subject to the SUP legislation should be reported beginning in 2023.
• Specific rules apply to certain packaging types, requiring them to be administratively separated. For instance, when reporting PET bottles, you must specify the weight of recycled materials used.
• Some packaging serves multiple purposes (e.g., beverage cartons used for both beverages and food). Depending on their application, different legal obligations apply, so it's essential to specify the content of the packaging.
• The changing definition of Producer/Importer means that, in certain cases, you may no longer need to report certain packaging, while in others, you will need to start reporting it.

In summary, the most significant change for your administration is the requirement to report both the number of pieces and weight (kg), along with identifying the type of SUP packaging. This ensures compliance with legal obligations related to SUP and helps determine the appropriate rate for your packaging.

In the coming months, our reporting tool PackTool will be made available so that you can fill in the report as easily as possible.

To provide further clarity, the Ministry of Infrastructure and Water Management (IenW) has developed an assessment framework based on an external advisory report, which includes decision trees, definitions, and examples. Further explanation of this assessment framework will be provided in a letter from the State Secretary of IenW to the House of Representatives. 

Beverage cartons
You will be introducing the following drink cartons to the market starting from 2023:

• 500,000 pieces of drink cartons for fresh drinks, weighing 35 grams with 75% paper and 25% plastic; 400,000 pieces of drink cartons for shelf-stable drinks, weighing 37 grams 
• 70% paper, 25% plastic, and 5% aluminum; 700,000 pieces of drink cartons for yogurt and custard, all of 500ml or more (therefore not falling under the SUP), weighing 35 grams
• 75% paper and 25% plastic.

To be indicated as "drink cartons for beverages, SUP."

Quantity: 500,000 pieces + 400,000 pieces = 900,000 pieces, to be reported under the material plastic.

• Weight:
• Paper and cardboard: 500,000 x 0.035 kg x 75% + 400,000 x 0.037 kg x 70% = 13.125 kg + 10.360 kg = 23.485 kg. Plastic: 500,000 x 0.035 kg x 25% + 400,000 x 0.037 kg x 25% = 4.375 kg + 3.700 kg = 8.075 kg.
• Aluminum: Plastic: 500,000 x 0.035 kg x 0% + 400,000 x 0.037 kg x 5% = 0 kg + 740 kg = 740 kg.

To be indicated as "other drink cartons."

• Quantity: not necessary, they are not SUP packaging.
• Weight: Paper and cardboard: 700,000 x 0.035 kg x 75% = 18.375 kg
  
  Plastic: 700,000 x 0.035 kg x 25% = 6.125 kg

For 2023, a declaration must be provided (by March 31, 2024). Here, you specify the weight of the packaging placed on the market for all packaging types. For deposit packaging and packaging falling under the SUP legislation, you additionally specify the quantity of packaging placed on the market.

For Fee modulation, the system currently in place still applies. If you have permission to apply Fee Modulation, you indicate this for the packaging types: other packaging (lower rate), food packaging with a rigid element (lower rate), drink cups, lower rate, or plastic beverage bottles without a deposit, lower rate (applies to PET and non-PET).

There has always been a threshold of 50,000 kg of packaging placed on the market per year for filing a declaration, and this threshold remains largely in place. Only SUP packaging and deposit packaging do not count towards the aforementioned threshold. You must include all packaging placed on the market in your declaration.

Furthermore, the following specifics apply:

• For PET beverage bottles, you report both the recycled material used, derived from so-called "post-consumer" packaging, and the virgin material used. The total weight of the bottles is automatically added up.
• Food packaging: only a portion of food packaging falls under SUP. There is a distinction between packaging with a rigid element (with or without a lower rate) or pouches and wrappers. The packaging in this category that does not fall under SUP legislation is reported in the category "other packaging."
• Food packaging falling under SUP legislation: any other materials used in the packaging and inseparably connected to the plastic part must also be reported.
  
• Deposit cans must be registered separately, and the materials used must be reported separately. However, you only provide the quantity once to avoid double counting.

NOTE: Beverage cans always consist of aluminum (lid and tab). If you have so-called "steel cans," you must report the weight of "other metals" and "aluminum" separately. The quantity of packaging placed on the market is reported under the aluminum material.
NOTE: You must also register with Statiegeld Nederland for operational handling regarding the deposit system.

• Reusable (formerly multi-use) packaging (excluding logistic aids). In 2021, this was requested for glass beverage bottles and is now extended to all other packaging. You must register:

- The weight of the first time the reusable packaging is put into circulation.
- The total weight of reusable packaging made available as if the respective packaging were single-use (total sales). This is untaxed.
- Based on this information, we calculate reuse.
- For reusable packaging, single-use components (which become packaging waste after each use, e.g., caps, labels) must be reported as regular packaging under the relevant material type.

You must report all materials used in the packaging separately. For example, a paper drink cup consists of both paper and cardboard and plastic. Therefore, you must split the total weight into both materials. However, you only provide the quantity once to avoid double counting.

Also for 2024, a declaration will be prepared for you, albeit later, based on the latest declaration or statement known to us. Once this happens, we will inform you about it.

It is important that you carefully check this declaration and adjust it if necessary. The amount we estimate for you for 2024 may not be entirely accurate, so you may end up paying too much or too little. In that case, after the declaration for 2024, a significant correction to the already paid amount will be settled, which could be an unpleasant surprise. We ask you, in particular, to pay attention to:

• For all plastics, it is automatically converted to the material type "flexible or unspecified plastic" because we cannot allocate it to flexible or rigid for you. Given the difference in the rate of €0.10 per kg, this may affect the accuracy of your invoices you receive in 2024.
• Due to the introduction of Fee Modulation 2.0, you can receive discounts on more packaging and in a different way. The old packaging types with the addition of "lower rate" will be discontinued. If you indicate in your declaration which discount (in steps of 10 cents per kg) applies to which packaging, it will be immediately deducted, and you will receive this discount immediately (this will be deducted from the invoices you receive in 2024).

Distinction between rigid and flexible plastic

We specifically ask you to make a distinction between rigid and flexible plastics, where possible. Each of these plastics has a different starting rate per kg (€1.22 and €1.32, respectively). If this is not possible for you, you should report your plastic under the category "flexible or unspecified plastic". Below is an example of how this distinction can be made.

A shampoo bottle consists of a rigid bottle (PET) weighing 20 grams, a rigid cap (PP) weighing 5 grams, and a flexible plastic label (PE) weighing 2 grams. The manufacturer/importer places 2 million bottles on the market in 2024. These would then be reported as:

• Rigid plastic: 2 million x 0.025 kg = 50,000 kg
• Flexible plastic: 2 million x 0.002 kg = 4,000 kg

If Fee Modulation applies (e.g., 30 cents per kg), then you will receive this on all plastic components of the packaging. You will pay for the above bottles (excluding the simplicity threshold correction):

• Rigid plastic: 50,000 kg x (€1.22 - €0.30) = €46,000
• Flexible plastic: 4,000 kg x (€1.32 - €0.30) = €4,080
• Total: €50,080

Because there are legal goals in addition to recycling goals that include reuse, you must declare all packaging that you bring to market more than once (the reusable packaging). In the declaration, we use the term reusable packaging. You report these packages in two phases:

• The first time you introduce a reusable package to the market and declare it, you pay a Waste Management Contribution. In 2022, this is the same rate as previously known; from 2023, you pay only a small contribution.
• Additionally, you report the weight of all reusable packages that you have introduced to the market in the same calendar year (including the weight of the packages that are first put into circulation). Based on this, we calculate the reuse (on an aggregated level for the whole of the Netherlands).

Below is an example:

You have a park of reusable packages, consisting of a total weight of 500,000 kg. In 2022, you have some of these packages collected and processed, and you add 40,000 kg of packages. In total, you have brought 3,000,000 kg of reusable packages to the market.

• The 40,000 kg of packages are reported under the category "Reusable packages, first use (excl. LHM)". You pay a rate for this (in 2022, the regular rate; in 2023, a reduced rate).
• The total of 3,000,000 kg of packages brought to the market is reported under the category "Reusable packages, total output (excl. LHM), untaxed". As the name implies, you do not pay a rate for this.
• We calculate the reuse, which is 3,000,000 kg - 40,000 kg = 2,360,000 kg.
• The total size of your reusable pool (500,000 kg reused) is not relevant.

For almost all packaging, you pay a waste management contribution to us. The rates consist of multiple components:

Existing rates:

• Regular rate, consisting of: System rate: fixed costs divided by the total weight of taxed packaging placed on the market; Material rate: material-specific costs of collection to processing divided by the weight of the packaging on the market (of the same material).
• Deposit (new for beverage cans): a different rate per category based on the costs of collection, counting, sorting, and recycling (to be paid to Statiegeld Nederland) and only the system rate to us.
• SUP: for packaging falling under the SUP legislation. This consists of costs for cleaning up litter from all SUP packaging.

Changed: rate differentiation

The lower rates for packaging with rate differentiation have been discontinued and replaced with a system of rate differentiation for which you do not need prior permission from us (however, we can of course check the accuracy of your declaration). In this case, the rate consists of:

• A base rate for rigid plastic and flexible or unspecified plastic (€1.22 and €1.32 per kg respectively)
• Rate discount of €0.10 per kg per criterion below, provided your packaging meets the conditions for the discount:
  - Color Use of mono-material
  - Size and composition of the label
  - Compliance with the recycling check of the KIDV
  - Demonstrable application of post-consumer recyclate (above certain levels)

More information on this can be found here.