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Packaging registration under PPWR: Thresholds in Ireland, Belgium and the Netherlands to be abolished

The EU Packaging and Packaging Waste Regulation (PPWR) does not provide for any thresholds for producer registration in the Member States. In Ireland, the existing thresholds – which have so far exempted many companies from the registration requirement – will be abolished on 12 August 2026. Ireland is thus bringing producer responsibility into line with the PPWR requirements. In Belgium, too, the long-existing threshold has been abolished. In the Netherlands, this is planned for 1 January 2027. take-e-way reported informed you about this in February 2026.

In other countries, however, thresholds or other country-specific requirements for producers will remain in place for some more time.

What thresholds have applied to date in Ireland, Belgium and the Netherlands?

Until now, only companies with a turnover of at least 1 million euros in Ireland and placing at least 10 tonnes of packaging on the market annually were required to register as packaging producers in Ireland. Furthermore, only companies holding an Irish VAT number were eligible to register.  

In Belgium, a minimum threshold of 300 kg of packaging placed on the market per year previously applied, below which no packaging registration was required. Furthermore, for professional packaging, only companies selling under a Belgian VAT number were eligible to register.  

In the Netherlands, the registration requirement previously applied only to companies placing 50 tonnes or more of packaging on the market annually within the Netherlands, excluding single-use plastic (SUP) items.

What do producers need to do? 

The requirement to hold an Irish VAT number has already been scrapped. From 12 August 2026, the turnover and quantity thresholds will be abolished. Producers can join an Irish producer responsibility organisation (PRO) as of now. 

In Belgium, too, registration has recently become available to all producers, regardless of the quantities placed on the market. 

For the Netherlands, where the threshold will not be lowered until 2027, we are happy to accept registration requests already now.

Thresholds and other requirements in other European countries 

In some other European countries, the local thresholds continue to apply until national implementing legislation amends the local requirements. This is the case, for example, in the Czech Republic, where a turnover and quantity threshold for packaging continues to apply. 

In Lithuania and Romania, for example, packaging registration with a PRO is still only possible when holding a local VAT number.

In Italy, until further notice, only businesses that sell directly to Italian end-users via online marketplaces – and which are not micro-enterprises – are required to register for packaging. 

If you have any questions regarding the implementation of the new regulations in Ireland, the Netherlands or Belgium, or if you do not yet have packaging registration in these countries and would like to register through us, please contact consulting@take-e-way.de.

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Sebastian Siebert
Contact

Sebastian Siebert
Head of Advisory services

Phone: +49 40 750687-0

consulting@take-e-way.de

Christoph Brellinger
Contact

Christoph Brellinger
Head of Marketing & Public Relations

Phone: +49 40 750687-0

pr@take-e-way.de

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