Selling in the Netherlands under GPSR: NVWA, Verpact and Stichting OPEN

Updated 29 October 2026

The Netherlands applies the GPSR directly; the NVWA enforces it through the Commodities Act (Warenwet). What is specific to the Dutch market is how the language rule is worded, what a recall notice must contain, and two organisations that handle producer responsibility.

Language: “a language Dutch consumers understand”

The NVWA (Netherlands Food and Consumer Product Safety Authority) supervises non-food consumer products. Its guidance for manufacturers asks for clear instructions and safety information in a language Dutch consumers understand, and for the manufacturer’s name, trade name, address and contact details on the product. It does not name Dutch as the only possible language, but Dutch is the safe choice for warnings and instructions.

Recall notices: Dutch is required

If you have to recall a product, the NVWA lists what the notice must contain, and here Dutch is explicit: the information on where consumers can get more details must be in Dutch. The notice also needs:

• a heading that says it is a product safety recall;
• a clear photo or drawing of the product;
• details to recognise it: name, brand, EAN code, batch or serial number, and where, when and by whom it was sold;
• the defect and the risk, without words that play the risk down such as “voluntary” or “in rare cases”;
• what consumers should do, starting with stopping use;
• the remedies offered under GPSR Article 37 — usually at least two of repair, replacement or refund;
• your company name and contact details.

Packaging: Verpact

Producers register and report packaging through Verpact, the producer responsibility organisation for packaging in the Netherlands. According to the Netherlands Chamber of Commerce (KVK):

• A waste management contribution is due above 50,000 kg of packaging a year; from 2028 it also applies to smaller volumes.
• If you sell directly to consumers in another EU country, you are the producer there under the PPWR and must register in that country too.

Under PPWR Article 45(3), a seller based outside the Netherlands who ships packaged goods directly to Dutch consumers must appoint an EPR authorised representative in the Netherlands.

Electrical equipment and batteries: Stichting OPEN

For electrical and electronic equipment, lamps and batteries, Stichting OPEN carries out producer responsibility for everyone who places these products on the Dutch market for the first time. A foreign producer, distributor or webshop can join OPEN directly. Because its waste management contribution agreement is generally binding, OPEN says it fulfils the role of authorised representative, so you do not need to appoint your own — unless the law of your own country requires it. That is the opposite of Germany, where a foreign company must use a German representative for WEEE.

Checklist for the Netherlands

1. An EU responsible person named on the product and in the listing — compare published provider prices.
2. Instructions, warnings and safety information in a language Dutch consumers understand (in practice, Dutch).
3. Packaging reported through Verpact, and an EPR authorised representative if you ship to Dutch consumers from abroad.
4. Electrical equipment, lamps and batteries registered with Stichting OPEN.
5. A recall template that meets the NVWA list, in Dutch.

Make Dutch warnings with the GPSR label generator, and run the compliance checker for the full list.

Sources

• NVWA: GPSR rules for manufacturers
• NVWA: recall of a non-food product, content and communication
• NVWA: about the GPSR
• KVK: PPWR, what the new EU packaging rules mean for your business
• Stichting OPEN: arranging producer responsibility as a foreign producer
• Regulation (EU) 2023/988 (GPSR), Articles 9 and 36
• Regulation (EU) 2025/40 (PPWR), Article 45

ohdock provides software tools and general information, not legal advice. Check the official texts, or ask a qualified adviser, for your situation.