Under the threshold? You may owe a number and not be able to get one

By Jarmo Habakuk · 23 August 2026 · Updated 31 August 2026

✓ Last verified against primary sources: 31 August 2026

If an adviser has told you confidently that you are under the threshold and owe nothing, they may be describing something real. They are also probably answering a different question from the one you asked.

Correction, 31 August 2026. This article previously said the Dutch 50,000 kg threshold switches off declaring as well as paying, without qualification. That is true only for ordinary packaging. Verpact’s own guidance is that deposit-return packaging and single-use plastic packaging carry no threshold at all, so a small seller shipping drinks containers or single-use plastic items into the Netherlands owes a declaration from the first unit. The correction is added below and in the country table; nothing else in the article changes.

Two different things get called “EPR registration”, and the threshold answer is different for each.

• The national scheme — Verpact, Repak, Citeo, BDO. These have real thresholds. Below the line they may refuse to take you, and refuse to take your money.
• The producer register the PPWR requires. No volume floor at all. But in most countries it does not exist yet.

So “under the threshold, no number needed” can be literally true at the counter today. It still does not describe what you owe. And it is no help at all when Amazon asks for a number.

What the Regulation actually says about small volumes

Worth getting exactly right, because the ten-tonne figure is the most misquoted number in EU packaging compliance.

Article 44 says producers shall register in each Member State where they first make packaging available. No minimum. It also says producers shall not make packaging available in a Member State if they are not registered there.

The ten tonnes appears somewhere else entirely. A producer under ten tonnes in a calendar year files one set of information to the register. A producer over it files a longer set. That is the whole of the difference.

Both are filings to the register. You cannot file with a register you are not on, so the provision assumes registration rather than excusing it.

The only flexibility it gives Member States runs the other way. A country may set a lower threshold, pulling more producers into full reporting. Never a higher one.

So at EU level there is no small-seller exemption from registration, and there was never meant to be.

Why your adviser says the opposite, and is not simply wrong

Because the register the last section describes is, in most countries, not yet open.

It depends on a Commission implementing act setting the format. Member States then get eighteen months from that act coming into force to build the register, and when we last checked the act was still in draft.

So what exists in most countries today is the older national scheme. Its threshold is a real thing that really does switch duties off.

The Netherlands is the sharpest case. Registration with Verpact is the PPWR registration there — the scheme and the register are the same door. So a producer under the 50,000 kg line, whom Verpact will not take, has nowhere to register.

That seller is not making a mistake. They have a duty with no counter open to discharge it at, and a marketplace asking for a number they cannot get.

But the Dutch line does not cover everything you might ship. Verpact is explicit that the 50,000 kg threshold applies to ordinary packaging only. Deposit-return packaging — drinks containers in the statiegeld system — and single-use plastic packaging have no threshold whatsoever. There you register and declare from the first unit, however small you are. So “I am under fifty tonnes, I am clear in the Netherlands” is right for a seller shipping boxed goods and wrong for one shipping bottles.

Belgium is in the same shape for a different reason. Belgium says there is no de minimis for producer status under the new rules, and its producer register is still being built. A seller asking for a Belgian number today cannot get one at all, above or below any threshold.

Ireland may work like the Netherlands. Providers who sell Irish registration describe the tests as deciding registration itself, not just scheme membership. That is a commercial position rather than the law, and the Irish statute book blocks automated access, so we cannot settle it at source. We do not claim to know.

What each national threshold actually switches off

Four countries read at source, and it is a different duty every time.

Germany, Sweden and France publish no threshold at all. Citeo says you join as soon as you place any packaging on the French market, whatever the volume.

This is not a list of every threshold in the EU. It is the four we have read at source. A missing country means we have not checked it, not that it has none.

Poland, where the saving is smaller than it looks

Poland is the country most often held up as cheap, and the detail matters.

Under one tonne you skip the product fee, the recycling duties and the public education charge.

But that education charge only ever falls on a producer over a tonne who performs the obligation on its own. Go through a recovery organisation and it never arises, threshold or not. So one of the three things the threshold “saves” you was never going to apply to most sellers.

What stays: BDO registration, the annual report by 15 March, and the annual fee — 100 PLN for a micro-enterprise, 300 PLN for everyone else, due by the end of February. It is not charged in the year you paid the registration fee.

And the relief is not automatic. It counts as state aid, so you claim it in the BDO filing by 15 March, capped across three years. Miss the filing and you have not quietly stayed under a line — you have missed a deadline.

What to do with this

• Ask which register. When someone tells you a threshold means no registration, ask whether they mean the national scheme or the producer register. Most confident answers are about the first.
• Keep the numbers that prove where you are. Tonnage per country, turnover, per year. If a scheme refuses you, that evidence is the only thing you will have to show for it.
• Do not treat a threshold as an answer to a marketplace. There is no number that means “under the threshold”, so there is nothing to type into the field.
• Remember the registration is not the whole bill. In any country where you have no company of your own, an authorised representative sits alongside it, and that is usually the larger cost.
• Where a register is genuinely shut, say so in writing to yourself. Date it. A duty you cannot discharge is a very different position from one you ignored, and the difference is worth documenting while it is true.