+49 6196 5835357

info@ecopv-eu.com

🇳🇱 EPR Compliance for WEEE in the Netherlands |
Guide and Checklist 2026

Extended Producer Responsibility (EPR) for Electrical and Electronic Equipment (EEE) – 7 Steps to Compliance + Step-by-Step Checklist

The Netherlands has one of the most centralized WEEE systems in Europe: a single authorized organizational framework, a national registry, and a portal – Stichting OPEN is at the heart of Dutch EPR compliance for EEE and lamps. All manufacturers and importers are required to register via Stichting OPEN’s digital portal and submit their volume reports there starting with the first device placed on the market.

What does this mean for your company?

Here are the 7 most important steps – including a checklist to get you started.

🇳🇱 EPR Compliance for WEEE in the Netherlands |
Guide and Checklist 2026

Extended Producer Responsibility (EPR) for Electrical and Electronic Equipment (EEE) – 7 Steps to Compliance + Step-by-Step Checklist

The Netherlands has one of the most centralized WEEE systems in Europe: a single authorized organizational framework, a national registry, and a portal – Stichting OPEN is at the heart of Dutch EPR compliance for EEE and lamps. All manufacturers and importers are required to register via Stichting OPEN’s digital portal and submit their volume reports there starting with the first device placed on the market.

What does this mean for your company?

Here are the 7 most important steps – including a checklist to get you started.

Who is considered a “producer”?

The Dutch regulations are based on the WEEE Directive 2012/19/EU. The following are considered producers:

  • Companies based in the Netherlands: Manufacture EEE domestically and place it on the Dutch market for the first time under their own brand – or import EEE commercially from abroad (EU or third countries) and distribute it in the Netherlands.
  • Companies from other EU countries: Sell EEE via distance selling (online store) directly to Dutch end consumers (B2C) or commercial end users (B2B).
  • Companies outside the EU: Deliver EEE directly to Dutch end users via direct shipping. In traditional B2B supply chains, the first importer based in the Netherlands (with a Dutch KVK/VAT number) is automatically considered the legal manufacturer.
  • White-label/private-label manufacturers: Have devices manufactured by third parties but place them on the market in the Netherlands under their own name or brand – and are thus considered the first entity to place the product on the market.
  • Marketplace operators: Are required to verify the compliance of their third-party sellers. Marketplaces such as Amazon.nl and Bol.com are vicariously liable for unregistered foreign sellers and suspend accounts without proof of compliance.

Practical example: An Austrian company sells smart kitchen appliances directly to Dutch end customers via Amazon.nl → is considered a manufacturer → must register with Stichting OPEN → is automatically entered in the NWR → pays an annual waste disposal fee based on weight and category → reports the quantities placed on the market annually via myOPEN.

The 7 Key Steps to EPR Compliance in the Netherlands

Step 1: Appoint an Authorized Representative (for foreign companies)

For companies outside the EU, appointing an authorized representative based in the Netherlands is mandatory if direct sales to Dutch end-users take place. The authorized representative assumes full civil and administrative liability for registration, reporting quantities, and paying the waste disposal fee.

For companies from other EU countries, appointing an authorized representative in the Netherlands is not required. Thanks to the centralized system, foreign online retailers can register directly on the Stichting OPEN portal for direct sales to Dutch end-users and fulfill their EPR obligations independently there.

Requirements for the authorized representative:

  • Headquarters in the Netherlands
  • Written power of attorney agreement in Dutch or English
  • Signed by authorized representatives of both parties
  • A Hague Apostille is not required as a standard

Step 2: Classify the product into an EEE category

Before registration, the product must be classified into the correct EEE category according to the Stichting OPEN product and tariff list. This list is updated annually and is publicly available on the Stichting OPEN website.

CategoryDescriptionExamples
1Heat exchangersRefrigerators, air conditioners, heat pumps
2Screens & displays (>100 cm²)Televisions, monitors, laptops
3LampsLEDs, fluorescent tubes, energy-saving bulbs
4Large appliances (>50 cm)Washing machines, stoves, large household appliances
5Small appliances (≤50 cm)Coffee makers, tools, vacuum cleaners, toys
6Small IT & telecommunications devices (≤50 cm)Smartphones, tablets, routers, GPS

In addition, Stichting OPEN distinguishes between B2C products (household appliances) and B2B products (professional equipment) when calculating fees – both are reported separately and priced differently.

Step 3: Registration with Stichting OPEN & automatic NWR registration

All manufacturers and importers of EEE in the Netherlands are required to register with the NWR – however, this registration is completed indirectly by joining Stichting OPEN. Membership in Stichting OPEN automatically includes registration with the NWR.

Process:

  1. Registration on the myOPEN portal (online at my.stichting-open.org)
  2. Signing the ABBO (Afvalbeheerbijdrageovereenkomst)
  3. Stichting OPEN automatically transmits registration data to the NWR
  4. Inclusion in the public list of producers on nationaalweeeregister.nl and stichting-open.org

No individual WEEE registration number format: Unlike in some other European countries, the Dutch NWR does not issue individual WEEE registration numbers. To provide proof to marketplaces and trading partners, you can refer to the public manufacturer lists of the NWR and Stichting OPEN – or request an official confirmation letter from Stichting OPEN.

Step 4: Financial Obligations & Contribution Structure

The Afvalbeheerbijdrage (Waste Management Contribution) is the primary financial contribution that manufacturers and importers pay to Stichting OPEN. The rates are set annually based on projected quantities placed on the market and operating costs. They are fixed and can be found in the product and rate lists published annually.

Calculation basis:

Weight in kg (or number of units) × Rate per category

Differentiation criteria:

CriteriaDetails
Equipment category6 EU categories, priced separately
B2C vs. B2BB2C: fixed, linear rates for household recycling; B2B: Often reduced administrative rates; Manufacturers can provide their own certified proof of disposal for physical returns.
Advance paymentThose who pay more than €6,000 in waste management fees annually make monthly advance payments.
Minimum annual fee Foreign companies that sell directly to consumers pay a minimum annual fee of €175.

Eco-modulation: Stichting OPEN applies eco-design criteria as part of its tariff system. Devices that are particularly repairable, modular in design, or recycling-friendly can be classified into lower-cost tariff categories – similar to the systems in France and Belgium.

Step 5: Reporting Requirements

As registered members of Stichting OPEN, manufacturers and importers submit their Put on Market (POM) data annually via the myOPEN online portal. Stichting OPEN automatically notifies members by email when the report is ready to be submitted.

Report content:

  • Total weight (kg) and number of units of EEE placed on the market in the Netherlands
  • Breakdown by equipment category (6 EU categories)
  • Separation by B2C and B2B status

Step 6: Labeling requirements

The Netherlands follows the EU-wide WEEE labeling standards without any country-specific additional requirements, such as the French Triman logo. Two elements are mandatory:

  • Crossed-out wheelie bin (WEEE symbol): The EU pictogram must be permanently and clearly visible on the device. If the product is too small, the symbol may appear on the packaging and in the user manual.
  • Manufacturer information on the product: The manufacturer’s brand name, logo, or registered company name must be permanently and clearly affixed to the product – not just on the packaging.

Step 7: Take-back obligations & collection targets

As a member of Stichting OPEN, the manufacturer is indirectly involved in meeting national and EU-wide collection and recycling targets. Stichting OPEN organizes and finances collection through a network of over 13,000 collection points throughout the Netherlands – including container parks, retail locations, and B2B take-back solutions.

Statutory collection target (EU requirement):

  • 65% of the EEE placed on the market in the preceding 3 years must be collected annually.

Who is considered a “producer”?

The Dutch regulations are based on the WEEE Directive 2012/19/EU. The following are considered producers:

  • Companies based in the Netherlands: Manufacture EEE domestically and place it on the Dutch market for the first time under their own brand – or import EEE commercially from abroad (EU or third countries) and distribute it in the Netherlands.
  • Companies from other EU countries: Sell EEE via distance selling (online store) directly to Dutch end consumers (B2C) or commercial end users (B2B).
  • Companies outside the EU: Deliver EEE directly to Dutch end users via direct shipping. In traditional B2B supply chains, the first importer based in the Netherlands (with a Dutch KVK/VAT number) is automatically considered the legal manufacturer.
  • White-label/private-label manufacturers: Have devices manufactured by third parties but place them on the market in the Netherlands under their own name or brand – and are thus considered the first entity to place the product on the market.
  • Marketplace operators: Are required to verify the compliance of their third-party sellers. Marketplaces such as Amazon.nl and Bol.com are vicariously liable for unregistered foreign sellers and suspend accounts without proof of compliance.

Practical example: An Austrian company sells smart kitchen appliances directly to Dutch end customers via Amazon.nl → is considered a manufacturer → must register with Stichting OPEN → is automatically entered in the NWR → pays an annual waste disposal fee based on weight and category → reports the quantities placed on the market annually via myOPEN.

The 7 Key Steps to EPR Compliance in the Netherlands

Step 1: Appoint an Authorized Representative (for foreign companies)

For companies outside the EU, appointing an authorized representative based in the Netherlands is mandatory if direct sales to Dutch end-users take place. The authorized representative assumes full civil and administrative liability for registration, reporting quantities, and paying the waste disposal fee.

For companies from other EU countries, appointing an authorized representative in the Netherlands is not required. Thanks to the centralized system, foreign online retailers can register directly on the Stichting OPEN portal for direct sales to Dutch end-users and fulfill their EPR obligations independently there.

Requirements for the authorized representative:

  • Headquarters in the Netherlands
  • Written power of attorney agreement in Dutch or English
  • Signed by authorized representatives of both parties
  • A Hague Apostille is not required as a standard

Step 2: Classify the product into an EEE category

Before registration, the product must be classified into the correct EEE category according to the Stichting OPEN product and tariff list. This list is updated annually and is publicly available on the Stichting OPEN website.

1. Heat exchangers: Refrigerators, air conditioners, heat pumps

2. Screens & displays (>100 cm²): Televisions, monitors, laptops

3. Lamps: LEDs, fluorescent tubes, energy-saving bulbs

4. Large appliances (>50 cm): Washing machines, stoves, large household appliances

5. Small appliances (≤50 cm): Coffee makers, tools, vacuum cleaners, toys

6. Small IT & telecommunications devices (≤50 cm): Smartphones, tablets, routers, GPS

In addition, Stichting OPEN distinguishes between B2C products (household appliances) and B2B products (professional equipment) when calculating fees – both are reported separately and priced differently.

Step 3: Registration with Stichting OPEN & automatic NWR registration

All manufacturers and importers of EEE in the Netherlands are required to register with the NWR – however, this registration is completed indirectly by joining Stichting OPEN. Membership in Stichting OPEN automatically includes registration with the NWR.

Process:

  1. Registration on the myOPEN portal (online at my.stichting-open.org)
  2. Signing the ABBO (Afvalbeheer
    bijdrageovereenkomst)
  3. Stichting OPEN automatically transmits registration data to the NWR
  4. Inclusion in the public list of producers on nationaalweeeregister.nl and stichting-open.org

No individual WEEE registration number format: Unlike in some other European countries, the Dutch NWR does not issue individual WEEE registration numbers. To provide proof to marketplaces and trading partners, you can refer to the public manufacturer lists of the NWR and Stichting OPEN – or request an official confirmation letter from Stichting OPEN.

Step 4: Financial Obligations & Contribution Structure

The Afvalbeheerbijdrage (Waste Management Contribution) is the primary financial contribution that manufacturers and importers pay to Stichting OPEN. The rates are set annually based on projected quantities placed on the market and operating costs. They are fixed and can be found in the product and rate lists published annually.

Calculation basis:

Weight in kg (or number of units) × Rate per category

Equipment category: 6 EU categories, priced separately

B2C vs. B2B: B2C: fixed, linear rates for household recycling; B2B: Often reduced administrative rates; Manufacturers can provide their own certified proof of disposal for physical returns.

Advance payment: Those who pay more than €6,000 in waste management fees annually make monthly advance payments.

Minimum annual fee: Foreign companies that sell directly to consumers pay a minimum annual fee of €175.

Eco-modulation: Stichting OPEN applies eco-design criteria as part of its tariff system. Devices that are particularly repairable, modular in design, or recycling-friendly can be classified into lower-cost tariff categories – similar to the systems in France and Belgium.

Step 5: Reporting Requirements

As registered members of Stichting OPEN, manufacturers and importers submit their Put on Market (POM) data annually via the myOPEN online portal. Stichting OPEN automatically notifies members by email when the report is ready to be submitted.

Report content:

  • Total weight (kg) and number of units of EEE placed on the market in the Netherlands
  • Breakdown by equipment category (6 EU categories)
  • Separation by B2C and B2B status

Step 6: Labeling requirements

The Netherlands follows the EU-wide WEEE labeling standards without any country-specific additional requirements, such as the French Triman logo. Two elements are mandatory:

  • Crossed-out wheelie bin (WEEE symbol): The EU pictogram must be permanently and clearly visible on the device. If the product is too small, the symbol may appear on the packaging and in the user manual.
  • Manufacturer information on the product: The manufacturer’s brand name, logo, or registered company name must be permanently and clearly affixed to the product – not just on the packaging.

Step 7: Take-back obligations & collection targets

As a member of Stichting OPEN, the manufacturer is indirectly involved in meeting national and EU-wide collection and recycling targets. Stichting OPEN organizes and finances collection through a network of over 13,000 collection points throughout the Netherlands – including container parks, retail locations, and B2B take-back solutions.

Statutory collection target (EU requirement):

  • 65% of the EEE placed on the market in the preceding 3 years must be collected annually.

Step-by-Step Checklist

(a) Companies based in the Netherlands

1. Assign products to the correct EEE categories (consult the Stichting OPEN product and tariff list)

2. Complete registration on the myOPEN portal and sign the ABBO

3. Wait for automatic NWR registration by Stichting OPEN and verify entry in the public manufacturer list

4. Configure ERP/accounting system for tracking quantities by category and B2C/B2B

5. Submit regular POM reports via myOPEN (monthly/quarterly/annually depending on volume threshold)

6. Submit the annual WEEE report via myOPEN

7. Calculate the waste management fee and pay it on time

8. Affix the crossed-out wheelie bin symbol to the device or packaging

9. Ensure the manufacturer’s information is permanently affixed to the device

10. Retain records for 7 years for ILT audits

(b) Companies from other EU countries

1. Check the sales channel: Direct sales to Dutch end consumers (B2C) or business customers (B2B)? → If yes, proceed to step 2

2. Appoint an authorized representative or engage an EPR service provider (agreement in Dutch or English; authorized signatories on both sides)

3. Complete registration with Stichting OPEN (provide foreign VAT ID); registration via an authorized representative or direct registration is possible

4. Confirm NWR registration via Stichting OPEN

5. Submit proof of compliance (public manufacturer list or confirmation from Stichting OPEN) to marketplaces (Amazon.nl, Bol.com) to avoid account suspensions

6. Submit the annual POM report and WEEE annual report via myOPEN by the deadline

7. Check labeling: waste bin symbol and manufacturer information on the device/packaging

(c) Companies from third countries (outside the EU)

1. Option A – Delivery to a Dutch importer (B2B): Provide the Dutch partner with all necessary product data (weight, category, quantity) in a timely manner – the importer becomes the legal manufacturer and assumes compliance obligations toward Stichting OPEN and NWR.

2. Option B – Direct B2C sales without a Dutch intermediary: Appoint an authorized representative in the Netherlands (mandatory); complete all steps from checklist (b) through this representative.

3. In both cases: Ensure proof of compliance with Dutch marketplaces.

4. Customs declaration: Ensure that product data (weight, category) is correctly assigned to the manufacturer’s or importer’s Stichting OPEN member account.

Step-by-Step Checklist

(a) Companies based in the Netherlands

1. Assign products to the correct EEE categories (consult the Stichting OPEN product and tariff list)

2. Complete registration on the myOPEN portal and sign the ABBO

3. Wait for automatic NWR registration by Stichting OPEN and verify entry in the public manufacturer list

4. Configure ERP/accounting system for tracking quantities by category and B2C/B2B

5. Submit regular POM reports via myOPEN (monthly/quarterly/annually depending on volume threshold)

6. Submit the annual WEEE report via myOPEN

7. Calculate the waste management fee and pay it on time

8. Affix the crossed-out wheelie bin symbol to the device or packaging

9. Ensure the manufacturer’s information is permanently affixed to the device

10. Retain records for 7 years for ILT audits

(b) Companies from other EU countries

1. Check the sales channel: Direct sales to Dutch end consumers (B2C) or business customers (B2B)? → If yes, proceed to step 2

2. Appoint an authorized representative or engage an EPR service provider (agreement in Dutch or English; authorized signatories on both sides)

3. Complete registration with Stichting OPEN (provide foreign VAT ID); registration via an authorized representative or direct registration is possible

4. Confirm NWR registration via Stichting OPEN

5. Submit proof of compliance (public manufacturer list or confirmation from Stichting OPEN) to marketplaces (Amazon.nl, Bol.com) to avoid account suspensions

6. Submit the annual POM report and WEEE annual report via myOPEN by the deadline

7. Check labeling: waste bin symbol and manufacturer information on the device/packaging

(c) Companies from third countries (outside the EU)

1. Option A – Delivery to a Dutch importer (B2B): Provide the Dutch partner with all necessary product data (weight, category, quantity) in a timely manner – the importer becomes the legal manufacturer and assumes compliance obligations toward Stichting OPEN and NWR.

2. Option B – Direct B2C sales without a Dutch intermediary: Appoint an authorized representative in the Netherlands (mandatory); complete all steps from checklist (b) through this representative.

3. In both cases: Ensure proof of compliance with Dutch marketplaces.

4. Customs declaration: Ensure that product data (weight, category) is correctly assigned to the manufacturer’s or importer’s Stichting OPEN member account.

Are you planning to sell your products in the Netherlands?

We’ll help you ensure compliance with Dutch EPR regulations for WEEE so you can get started with legal certainty.

Are you planning to sell your products in the Netherlands?

We’ll help you ensure compliance with Dutch EPR regulations for WEEE so you can get started with legal certainty.

Contact

We look forward to your message!

info@ecopv-eu.com

+49 6196 5835357

Frankfurter Str. 70-72
65760 Eschborn

Contact

We look forward to your message!

info@ecopv-eu.com

+49 6196 5835357

Frankfurter Str. 70-72
65760 Eschborn