Starting on January 1, 2023, the application of the terms ‘producer’ and ‘importer’ will change in the Netherlands. This adjustment will have consequences for a lot of companies, specially brand owners that previously had no producer responsibility for packaging. If the contractor or client (brand owner) is involved in the manufacturing of a product whose brand does not belong to the manufacturer, for example under private label, the contractor or client is now expected to declare packaging with Afvalfonds Verpakkingen.
This applies when company A (the client) instructs company B (the contractor) to manufacture a product and to provide it with packaging bearing the name, logo and/or mark of the client (company A).
Current situation: The contractor pays the contribution to Afvalfonds Verpakkingen.
Situation from 1 January 2023: The client, for example the owner of a private label product, pays the contribution to Afvalfonds Verpakkingen.
Threshold does apply in the Netherlands. Total packaging weight up to 50.000 kilos in total is not eligible for declaration; when your company produces more packaging waste then 50.000 kilos a declaration is mandatory.
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Source: Afvalfonds Verpakkingen
Joris te Pas
Environmental Compliance Specialist
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