Verpact recently published an overview of what changes within the PPWR from 12 August 2026. One change in it deserves extra attention: it shifts the declaration duty onto parties who had nothing to do with it until now. You might be one of them.
What's changing
One of the core changes sits in the "disposal upon import" flow. Until now, the Dutch company that received and unpacked packaged products handled the declaration for it. That's changing. Verpact now designates the foreign sender as responsible, but only under one specific condition.
That condition turns on a single word from the regulation: end user. Article 3(15) of the PPWR sets out the difference — see the full diagram of PPWR roles for how "producer" is determined:
- If you're the end user of the packaged product (you use it yourself, you don't resell it), your foreign supplier becomes the producer in the Netherlands. The declaration duty shifts to them.
- If you unpack it without being the end user (for example, you process the product further, or resell it), the declaration duty stays with you.
So the flow doesn't disappear from your records. It splits, based on a distinction not everyone has sharply in view.
A second change from the same overview (responsibility for transport packaging and primary production packaging, which would shift to the foreign company that places it on the market empty) is on hold for now. Verpact has hit pause on it. That change isn't active yet, but it's worth keeping an eye on.
Why this is more than a legal detail
The pattern behind this whole regulation: the question is rarely what the law literally says. The question is whether you know, per package, per purchasing flow, per supplier, which side of a distinction like this you're on. A conformity declaration per package, evidence of recyclability, the origin of your material data: these are data and organizational questions, wrapped in legal language.
So before you cross "disposal upon import" off your declaration: do you know, per purchasing flow, whether you're the end user or not?
What we keep running into here
In the conversations we have, nine times out of ten the first discovery is that the packaging list isn't complete. That's nothing to be ashamed of. It's the starting point. And it's exactly where Packstract begins: not with the legal question, but with the packaging data underneath it.
Working through 12 August already, or thinking "this doesn't apply to us"? Either one is a good place to start a conversation. Request a free scan and we'll map out where you stand.
