Key takeaway
What This Development Means
The Netherlands Human Environment and Transport Inspectorate has published a corrected 2027 inspection plan, identifying PFAS, the REACH microplastics restriction, product market surveillance, waste shipments and dangerous goods among its priorities. The plan does not create new statutory duties, but it signals where manufacturers, importers and supply-chain operators can expect greater supervisory attention.
Does the ILT 2027 inspection plan create new legal duties?
No. It is an administrative inspection and enforcement plan, not legislation. Businesses remain subject to existing European Union and Dutch requirements, but the plan helps them anticipate the areas in which evidence and controls may receive greater scrutiny.
Does the plan mean the universal European Union PFAS restriction is now law?
No. The broad PFAS restriction proposal remains within the REACH process. ILT can nevertheless supervise obligations arising from existing substance, emissions, product and waste legislation, so companies should distinguish current enforceable requirements from the wider proposal.
Source basis: Netherlands Government, corrected ILT Annual Plan 2027, published 5 October 2026 and modified 6 October 2026
Netherlands ILT 2027 inspection plan sets enforcement priorities
The Netherlands Human Environment and Transport Inspectorate, known as ILT, has published a corrected 2027 annual plan. The official record was published on 5 October 2026 and modified on 6 October. It describes the Inspectorate's planned work on transport, infrastructure, environmental protection and housing during 2027.
For manufacturing value chains, prominent themes include per- and polyfluoroalkyl substances, known as PFAS, implementation of the European Union restriction on intentionally added microplastics under the Registration, Evaluation, Authorisation and Restriction of Chemicals Regulation, product market surveillance, waste shipments, circular-economy controls, dangerous goods and cybersecurity.
The plan does not create a new prohibition, threshold or application date. Existing European Union and Dutch rules remain the source of legal duties. Its significance is operational: it indicates where ILT intends to deploy inspection, intelligence and enforcement resources, including stronger cooperation with customs and other supervisory authorities.
Importers and online-market participants should note the emphasis on market surveillance and border cooperation. A product's availability through e-commerce does not reduce the responsible economic operator's obligations. Technical documentation, traceability, labelling and evidence supporting chemical compliance need to be accessible when authorities intervene.
PFAS and microplastics evidence moves up the agenda
The PFAS focus should not be read as confirmation that the proposed universal European Union PFAS restriction has been adopted. That restriction remains under the REACH decision-making process. However, duties arising from existing substance restrictions, emissions and waste rules continue to apply, and national authorities can investigate them now.
For intentionally added microplastics, the adopted REACH restriction is already in force, with different application dates and transitional periods for product groups. Companies should identify the specific transition that applies to each use rather than assuming a single 2027 deadline. Records supporting derogations, instructions for use and required reporting will be especially important as implementation matures.
Waste producers, brokers and carriers should also review classification, shipment documentation and end-destination evidence. Circular-economy claims do not displace waste law when a material has not lawfully ceased to be waste. Dangerous-goods consignors and transport operators should ensure that classification, packaging, training and transport documentation remain consistent across contractors.
The analytical value of the plan is its convergence of product, chemical, customs and waste oversight. A discrepancy first identified at the border or in an online listing can expose wider weaknesses in chemical composition, supply-chain records or end-of-life handling. Compliance teams should therefore test connected evidence across the product lifecycle instead of preparing separately for each inspection regime.
Practical call to action: Use the 2027 plan as a risk-based audit checklist, prioritising PFAS and microplastics records, importer documentation, waste-shipment evidence and dangerous-goods controls.
Related Foresight coverage: Netherlands launches PFAS exposure-reduction programme; Greenpeace files PFAS enforcement request against Chemours; Netherlands enacts temporary steel-slag ban.
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