What do I need to do as a micro-enterprise?

What is a micro-enterprise?

You are classified as a micro-enterprise if you have fewer than 10 employees and an annual turnover or balance sheet total of no more than €2 million.

What does the PPWR mean for you as a micro-enterprise?

Certain exceptions apply to micro-enterprises. However, this does not automatically mean you do not have to take any action. Do you place more than 50,000 kilograms of packaging on the Dutch market annually? If so, you are already required to submit a declaration to Verpact. If you fall below this threshold, you do not need to take any action at this time, provided the Dutch declaration threshold remains in place.

Your role: manufacturer and producer at a glance

The PPWR distinguishes between various roles that may be relevant to you as a micro-enterprise—specifically, manufacturer and producer. The obligations that apply to you depend on your role.

Manufacturer

You are considered a manufacturer if you are responsible for the packaging design. As a micro-enterprise, you are a manufacturer if you:

• design or manufacture your packaging or packaged product yourself;
• purchase components for sales and grouped packaging, then fill and seal them yourself;
• potentially: manufacture (empty) shipping, service, or primary product packaging; please also
• refer to our communications regarding the 'pause button' in this context.

You are *not* a manufacturer if you have your packaging or packaged product designed or manufactured by another company—under your own name or brand—and that company is based in the same country as you. In that case, *that* company is the manufacturer.

Please note:

• Is the contractor also a micro-enterprise? Then they remain the manufacturer.
• Is the contractor based in another country? Then you, as the commissioning party, are the manufacturer.
  

Producer

You are a producer if - acting as a manufacturer, importer, or distributor - you are the first to place packaging or packaged products on the market in a country. The producer submits declarations and contributes to the cost of packaging collection and recycling.

In some situations, you may be both a manufacturer and a producer. Unsure about your role? You can find various examples and diagrams in the factsheet.

What do you need to do? Register first, then submit declarations

First, check whether you are a manufacturer and/or producer. Do you place more than 50,000 kilograms of packaging on the Dutch market annually? If so, you must already submit declarations to Verpact. If you fall below this threshold, you do not need to take any action at this time, provided the threshold remains in place.

Additionally, a producer register is being introduced. You are expected to be able to register in this system starting in 2028. The first reporting is expected to take place from 2029 onwards.

Factsheet

Do you want to know which exemptions apply to micro-enterprises, what your role is, and which obligations apply to your situation? Download the PPWR factsheet on micro-enterprises.

The PPWR does not stand alone. Regulations regarding single-use plastics (SUP) and deposit schemes may also entail obligations for you, independent of the information above. These rules can affect you even if you qualify for an exemption under the PPWR, and may require you to maintain specific records.