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Netherlands vs Oregon EPR: Rules Compared

Last verified

Netherlands and Oregon both run packaging EPR, but the rules differ. Both require producers to register. Oregon asks for its first annual report earlier, on May 31 against June 1 in Netherlands. Every figure below links to its primary source.

Paired bars comparing how many verified thresholds, deadlines and penalties Netherlands and Oregon publish, and how many columns their report layouts hold.Netherlands / Oregon (published items): Thresholds: Netherlands 2, Oregon 4; Deadlines: Netherlands 3, Oregon 4; Penalties: Netherlands 0, Oregon 1; Report columns: Netherlands 4, Oregon 4NetherlandsOregonpublished items01234Thresholds24Deadlines34Penalties01Report columns44
Source: Netherlands and Oregon primary sources, retrieved 2026-11-05

Netherlands and Oregon side by side

2 of 9 rows have a verified figure on each side of Netherlands and Oregon; a cell reads “not yet published” when a side has none, and an exemption row reads “none recorded; see thresholds” when no exemption is on record.

Netherlands and Oregon: the measures both programmes publish
MeasureNetherlandsOregonStricter
Registration dutyRequiredRequiredSame
Producer organisationone producer responsibility organisationone producer responsibility organisationNot comparable
Lowest revenue exemptionnone recorded; see thresholds$5,000,000Not comparable
Lowest weight exemptionnone recorded; see thresholds1 tonneNot comparable
First annual report dateJune 1May 31Oregon
Published penaltiesnot yet published1 publishedNot comparable
Report filecsvcsvNot comparable
Paper fee, cheapest matched rate0.017 EUR/kg2.0 cents per poundNot comparable
Plastic fee, cheapest matched rate0.87 EUR/kg12.0 cents per poundNot comparable

Both programmes require a producer to register, in Netherlands and in Oregon.

The earliest annual report date is June 1 in Netherlands and May 31 in Oregon, 1 day apart. Oregon leaves less time to prepare, so its data has to be ready first.

Who runs the programme in Netherlands and Oregon

Who collects and who the producer files with, in Netherlands and then Oregon.

Netherlands and Oregon: how each programme is set up
AspectNetherlandsOregon
RegimeBesluit beheer verpakkingen 2014 (Packaging Management Decree) with the Verpact waste-management contributionOregon Recycling Modernization Act, ORS 459A.860 to 459A.975 (SB 582 of 2021)
Regulatornot yet publishedOregon Department of Environmental Quality (DEQ)
Producers obligatedYesYes
RegistrationRequired, Verpact (formerly Afvalfonds Verpakkingen)Required, Circular Action Alliance producer portal (PRO registration); DEQ holds no separate producer registry
Producer organisationone producer responsibility organisation: Verpact; membership requiredone producer responsibility organisation: Circular Action Alliance; membership required
Transfer of responsibilitynot yet publishedAllowed
Revenue counted asnot yet publishedorganisation gross revenue, USD, fiscal year
Who counts as the producerprimary: manufacturer or brand owner, importer, first distributor; secondary: manufacturer or brand owner, importer, first distributor; service: manufacturer or brand owner, importer, first distributor; shipping: online marketplace seller, manufacturer or brand owner; tertiary: manufacturer or brand owner, importer, first distributorother: first distributor; primary: manufacturer or brand owner, brand licensee, importer; secondary: manufacturer or brand owner, brand licensee, importer; service: first distributor; shipping: packer and shipper; tertiary: first distributor

Both programmes organise producer responsibility the same way: one producer responsibility organisation. The practical differences between Netherlands and Oregon therefore sit in thresholds, fees, dates and report formats rather than in whom a producer deals with.

What Netherlands and Oregon cover, side by side

Each row below is one published feature of the two programmes; a cell reads “not yet published” when Netherlands or Oregon has no verified entry for it in the dataset.

Scope, producer duties, categories, labelling and targets, Netherlands and Oregon
AspectNetherlandsOregon
Materials coveredplastic, glass, paper and cardboard, metal, woodpackaging, printing and writing paper, food serviceware
Product classes coveredpackaging placed on the Dutch market or discarded after importpackaging, printing and writing paper, food serviceware
Sales channels addressedproducers and importers established in the Netherlandsphysical retail, remote sale, other distribution
Producer duty: primary packagingmanufacturer_brand_owner; importer; first_distributormanufacturer_brand_owner; licensee; importer
Producer duty: secondary packagingmanufacturer_brand_owner; importer; first_distributormanufacturer_brand_owner; licensee; importer
Producer duty: tertiary packagingmanufacturer_brand_owner; importer; first_distributorfirst_distributor
Producer duty: shipping packagingonline_marketplace_seller; manufacturer_brand_ownerpacker_shipper
Producer duty: service packagingmanufacturer_brand_owner; importer; first_distributorfirst_distributor
LabellingNot required: Optional material identification per Commission Decision 97/129/EC: Marking is optional. If the producer or importer states the packaging material on the packaging or its label using abbreviations and number codes, Decision 97/129/EC applies, and the marking must be clearly visible, legible and durable (Art 2(3)-(4)). Deposit-bearing packaging must carry an indication of the deposit (Art 15(1)).not yet published
Published targetsreuse or recycling, all packaging 74% by 2025-12-31; plastic recycling 50% by 2025-12-31statewide_plastic_recycling_rate 25 by 2028-12-31; statewide_plastic_recycling_rate 50 by 2040-12-31; statewide_plastic_recycling_rate 70 by 2050-12-31
Exemption 1Refund of contribution on indirect export of packaging already charged (application needed)A small producer is exempt from PRO membership. Seven ways to qualify: nonprofit, public body, revenue under $5 million, under 1 metric ton, small beverage manufacturer, restaurant or food cart that is not a food-serviceware producer, single retail establishment with no online sales and no franchise or chain.
Excluded from scopenot yet publishedbeverage containers under bottle bill, bound books, napkins paper towels and cleaning paper, rigid pallets, industrial or manufacturing specialty packaging, drug packaging, items used or sold on a farm, architectural paint containers in paint stewardship, privately recycled material on claim
Producer duty: other packagingnot yet publishedfirst_distributor
Reporting categoriesnot yet published60, covered material type by material class
Exemption 2not yet publishedProduct-specific exclusions from "covered product" listed in ORS 459A.863(6)(b)(A)-(R) and OAR 340-090-0840(2), such as Bottle Bill containers, bound books, drug packaging, farm items and architectural paint containers.
Exemption 3not yet publishedMaterial recycled through a non-Opportunity-to-Recycle collection, not separated at a commingled facility, and disposed to a responsible end market can be exempted if the producer demonstrates it to DEQ. Producers still report gross supply. (application needed)

Thresholds and exemptions in Netherlands and Oregon

Every verified threshold Netherlands and Oregon publish, as each states it.

Verified thresholds in Netherlands and Oregon
PlaceMeasureAmountEffectBasis as published
Netherlandspackaging weight10 tonnes per calendar yearreduced dutypackaging made available for the first time in the Member State
Netherlandspackaging weight50,000 kg per calendar yearregistration triggerpackaging placed on the Dutch market or discarded after import
Oregonrevenue$5,000,000exempt belowgross revenue, most recent fiscal year
Oregonpackaging tonnage1 metric tonexempt belowcovered products sold in or into Oregon, most recent calendar year
Oregonpackaging tonnage5 metric tonsexempt belowcovered products, including secondary and tertiary packaging for beverage containers, most recent calendar year
Oregonrevenue$10,000,000flat-fee bandgross revenue, most recent fiscal year, or under 5 metric tons sold in or into Oregon

Netherlands exemption: Refund of contribution on indirect export of packaging already charged It must be applied for.

Oregon exemption: A small producer is exempt from PRO membership. Seven ways to qualify: nonprofit, public body, revenue under $5 million, under 1 metric ton, small beverage manufacturer, restaurant or food cart that is not a food-serviceware producer, single retail establishment with no online sales and no franchise or chain. It does not have to be applied for.

Oregon exemption: Product-specific exclusions from "covered product" listed in ORS 459A.863(6)(b)(A)-(R) and OAR 340-090-0840(2), such as Bottle Bill containers, bound books, drug packaging, farm items and architectural paint containers. It does not have to be applied for.

Oregon exemption: Material recycled through a non-Opportunity-to-Recycle collection, not separated at a commingled facility, and disposed to a responsible end market can be exempted if the producer demonstrates it to DEQ. Producers still report gross supply. It must be applied for.

Read the basis column first: the same amount can exempt a producer in one programme and only simplify its report in another.

Fees per kilogram for shared materials

4 material classes have a published rate on both sides; each row shows the cheapest rate that fits the class.

Cheapest published rate per kilogram by material class, Netherlands and Oregon
Material classNetherlands (EUR per kg)Oregon (USD per kg)Oregon in EUR, approx.Higher fee
paper and board0.017 EUR/kg2.0 cents per poundnot yet publishedNot comparable
plastic0.87 EUR/kg12.0 cents per poundnot yet publishedNot comparable
glass0.100 EUR/kg0.0 cents per poundnot yet publishedNot comparable
steel0.360 EUR/kg4.0 cents per poundnot yet publishedNot comparable

Scaling the cheapest published rate by weight shows what the gap between Netherlands and Oregon amounts to for a given tonnage of one material. The amounts are the rate times the weight, nothing added.

Fee at the cheapest published rate for 1 to 100,000 kilograms, Netherlands and Oregon
Material classKilogramsNetherlands fee (EUR)Oregon fee (USD)Oregon in EUR, approx.Oregon minus Netherlands (EUR)
paper and board1€0.02$0.04not yet publishednot yet published
paper and board10€0.17$0.44not yet publishednot yet published
paper and board100€1.70$4.41not yet publishednot yet published
paper and board1,000€17.00$44.09not yet publishednot yet published
paper and board10,000€170.00$440.92not yet publishednot yet published
paper and board100,000€1,700.00$4,409.25not yet publishednot yet published
plastic1€0.87$0.26not yet publishednot yet published
plastic10€8.70$2.65not yet publishednot yet published
plastic100€87.00$26.46not yet publishednot yet published
plastic1,000€870.00$264.55not yet publishednot yet published
plastic10,000€8,700.00$2,645.55not yet publishednot yet published
plastic100,000€87,000.00$26,455.47not yet publishednot yet published
glass1€0.10$0.00not yet publishednot yet published
glass10€1.00$0.00not yet publishednot yet published
glass100€10.00$0.00not yet publishednot yet published
glass1,000€100.00$0.00not yet publishednot yet published
glass10,000€1,000.00$0.00not yet publishednot yet published
glass100,000€10,000.00$0.00not yet publishednot yet published
steel1€0.36$0.09not yet publishednot yet published
steel10€3.60$0.88not yet publishednot yet published
steel100€36.00$8.82not yet publishednot yet published
steel1,000€360.00$88.18not yet publishednot yet published
steel10,000€3,600.00$881.85not yet publishednot yet published
steel100,000€36,000.00$8,818.49not yet publishednot yet published

The two schedules are in different currencies (EUR and USD) and the dataset holds no published exchange rate between them, so this page does not rank the fees. Compare them in your own currency before you decide.

Oregon: the 2027 fee schedule of Circular Action Alliance (Oregon PRO), effective January 1, 2027, is the source of the per-kilogram rates used on this page.

Netherlands: the 2027 fee schedule of Verpact (Stichting Afvalfonds Verpakkingen) Afvalbeheerbijdrage Verpakkingen, effective January 1, 2027, is the source of the per-kilogram rates used on this page.

Netherlands 2027: the category “Paper and cardboard” is published at 0.017 EUR/kg.

Netherlands 2027: the category “Plastic, rigid and flexible/unspecified, indirect export (deviating tariff)” is published at 0.87 EUR/kg.

Netherlands 2027: the category “Glass” is published at 0.100 EUR/kg.

Netherlands 2027: the category “Other metals” is published at 0.360 EUR/kg.

Oregon 2027: the category “Kraft Paper” is published at 2.0 cents per pound.

Oregon 2027: the category “HDPE (#2)/LDPE (#4) Flexible and Film Items” is published at 12.0 cents per pound.

Oregon 2027: the category “Glass Bottles and Jars & Other Containers” is published at 0.0 cents per pound.

Oregon 2027: the category “Steel Containers” is published at 4.0 cents per pound.

Real packs usually land in a dearer category, so use the calculator for Netherlands and Oregon.

Deadlines in Netherlands and Oregon

Each verified date, with the period it covers when one is given.

Verified deadlines in Netherlands and Oregon
PlaceKindDateCovers
NetherlandsreportJune 1the previous calendar year
NetherlandsotherAugust 12, 2026not yet published
NetherlandsreportAugust 1the previous calendar year
OregonreportMay 31, 2026calendar year 2025
OregonotherJuly 1, 2025not yet published
OregonotherJanuary 1, 2027not yet published
OregonreportDecember 31, 2026not yet published

The earliest annual report date is June 1 in Netherlands and May 31 in Oregon, 1 day apart. Oregon leaves less time to prepare, so its data has to be ready first.

Penalties in Netherlands and Oregon

What each side has published; a side without an amount says so.

Oregon penalty for failing to register or become a member of a producer responsibility organization: up to $25,000 per day.

Report formats in Netherlands and Oregon

How the report file for Netherlands compares with the one for Oregon.

Report file layouts for Netherlands and Oregon
AspectNetherlandsOregon
LayoutNetherlands packaging declaration (working layout) Working layout, sources reviewed 2026-11-04Oregon producer supply report by material category 2026-09-29 (built from CAA Oregon 2026 fee schedule)
RecipientVerpact / Afvalfonds VerpakkingenCircular Action Alliance (Oregon PRO)
How it is submittedVerpact online portal (aangifte and opgaaf). The customer signs in and submits.CAA producer portal. The customer signs in and submits.
File typecsvcsv
Encodingutf-8utf-8
Delimiter,,
Decimal separator.
Columns44
Required columns4 of 44 of 4
Weight unitkglb
Period basiscalendar yearcalendar year

The two layouts share a file type and a delimiter, but each programme names its own columns and categories, so one file cannot be sent to both programmes. Each report is built from the same underlying measurements and exported separately.

Which to plan for first, Netherlands or Oregon

Plan around the earlier report date first. Oregon asks for its first annual report on May 31, before Netherlands, so its data has to be ready first.

Questions about comparing these two programmes

Is Netherlands or Oregon stricter on packaging EPR?

Both require producers to register. Oregon asks for its first annual report earlier, on May 31 against June 1 in Netherlands.

Do I register in both Netherlands and Oregon?

Netherlands requires producers to register. Oregon requires producers to register.

How do the fees per kilogram compare in Netherlands and Oregon?

The two schedules share material classes but the dataset holds no published exchange rate between EUR and USD, so the fees are shown in each currency without a ranking.

Which deadline comes first, Netherlands or Oregon?

The earliest annual report date is June 1 in Netherlands and May 31 in Oregon, 1 day apart. Oregon leaves less time to prepare, so its data has to be ready first.

How these figures are made

Our reviewers.

Sources

  1. wetten.overheid.nl: BWBR0035711 retrieved
    Original wording: producent of importeur: elke in Nederland gevestigde natuurlijke of rechtspersoon die:
    Original wording: zendt elk jaar voor 1 augustus aan Onze
    Original wording: elke in Nederland gevestigde natuurlijke of rechtspersoon die:
    Original wording: de aard van het verpakkingsmateriaal vermeldt en hierbij afkortingen en cijfercodes gebruikt, is beschikking nr. 97/129/EG van de Commissie
    Original wording: met ingang van 2025: 74 gewichtsprocent
  2. ondernemersplein.overheid.nl: afvalbeheersbijdrage verpakkingen betalen retrieved
    Original wording: Dan moet u een Afvalbeheerbijdrage Verpakkingen betalen aan Verpact
    Original wording: Dan moet u zich eerst aanmelden bij Verpact
    Original wording: u per kalenderjaar meer dan 50.000 kilo verpakkingsmateriaal op de Nederlandse markt brengt of wegdoet na import
    Original wording: kunt u onder voorwaarden de afvalbeheerbijdrage verpakkingen voor indirecte export terugvragen
  3. eur-lex.europa.eu: oj retrieved
    Original wording: makes available for the first time on the territory of another Member State, directly to end users
    Original wording: a quantity of packaging, including packaging of packaged products, of less than 10 tonnes during one calendar year
    Original wording: of Annex IX to the competent authority responsible for the register, by 1 June for each full preceding calendar year.
    Original wording: It shall apply from 12 August 2026.
  4. oregon.gov: producers of covered products retrieved
    Original wording: producers of products covered under Oregon's Recycling Modernization Act (packaging, paper, and food serviceware)
    Original wording: Circular Action Alliance, at present, is Oregon's only approved Producer Responsibility Organization
    Original wording: In order to access CAA's data reporting portal, producers must first sign the Producer Participant Agreement with CAA
    Original wording: was allowed to begin charging fees from member producers on July 1, 2025
    Original wording: Large producer first impact disclosure date of Dec. 31, 2026
    Original wording: is a Class 1 violation that can result in fines of up to $25,000 per day.
  5. oregon.public.law: ors 459A.869 retrieved
    Original wording: each producer must register with and be a member of a producer responsibility organization that administers a producer responsibility program
    Original wording: A producer is not required to be a member of a producer responsibility organization if, for all covered product the producer sells
  6. oregon.public.law: ors 459A.863 retrieved
    Original wording: Has a gross revenue of less than $5 million for the organization's most recent fiscal year
    Original wording: Sold in or into Oregon less than one metric ton of covered products for use in this state in the most recent calendar year
    Original wording: that sold in or into Oregon less than five metric tons of covered products
    Original wording: "Covered product" means: (A) Packaging; (B) Printing and writing paper; and (C) Food serviceware.
  7. oregon.public.law: ors 459A.866 retrieved
    Original wording: the producer of the packaging is the person that manufactures the packaged item
  8. oregon.public.law: ors 459A.884 retrieved
    Original wording: a producer responsibility organization shall establish uniform membership fees for members that had a gross revenue of less than $10 million
  9. oregon.public.law: ors 459A.872 retrieved
    Original wording: A small producer is exempt from the requirement to be a member of a producer responsibility organization
  10. oregon.gov: rma exemptions retrieved
    Original wording: Covered product exemptions, meanwhile, are product-specific exemptions that exclude a given type of packaging
    Original wording: The latest window for producers to submit claims for this exemption was Jan. 6 – March 31, 2026
    Original wording: The next claims window will open in Jan. 2027.
  11. circularactionalliance.org: producer reporting retrieved
    Original wording: Oregon's 2026 Report is due May 31, 2026, based on the 2025 Data Year.
  12. circularactionalliance.org: OR 2026 Fee Schedule Public retrieved
    Original wording: Materials labeled N/A in the following table are not accepted on either the USCL or PRO Recycling Acceptance List.
  13. oregon.public.law: ors 459A.926 retrieved
    Original wording: At least 25 percent by calendar year 2028 and in each subsequent year
  14. verpact.nl: tarieven retrieved
    Original wording: Tarieven Materiaal Tarief 2027 €/kg ex.btw Tarief 2026 €/kg ex.btw Tarief 2025 €/kg ex.btw
    Original wording: Papier en karton € 0,017 € 0,017 € 0,017
    Original wording: tarief voor indirecte export Materiaalsoort 2027 2026 2025 2024 2023 2022 2021 2020 Plastic vormvast en flexibel/ / niet gespecificeerd ** € 0,87 € 0,87
    Original wording: Glas € 0,100 € 0,100 € 0,100
    Original wording: Overige metalen € 0,360 € 0,360 € 0,360
  15. circularactionalliance.org: OR 2027FeeSchedule 100126 retrieved
    Original wording: 2027 Oregon Producer Fees Schedule Fees for Program Year 2027
    Original wording: Kraft Paper USCL 0.07 0.00 -0.05 0.02
    Original wording: HDPE (#2)/LDPE (#4) Flexible and Film Items PRO 0.29 0.00 -0.17 0.12
    Original wording: Glass Bottles and Jars & Other Containers PRO 0.04 -0.01 -0.03 0.00
    Original wording: Steel Containers USCL 0.09 0.00 -0.05 0.04
Model both: Netherlands and OregonCompare another pair

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