EPR Obligations EU → 🇧🇪 Belgium
EPR in Belgium 2026: Packaging, WEEE & Batteries
Fost Plus, Valipac, Recupel, Bebat and EPRiBEL explained — and why foreign producers need a Belgian authorised representative since 12 August 2026.
Last reviewed: · Sources linked below
Short answer: if you place packaged goods on the Belgian market, you must be in the national producer register kept through EPRiBEL (formerly IVC-CIE) — usually via Fost Plus for household packaging or Valipac for industrial packaging. Since 12 August 2026, foreign producers also need an authorised representative established in Belgium and registered with EPRiBEL. Electrical equipment is a separate stream (Recupel), as are batteries (Bebat).
At a glance
- Packaging register / scheme
- National producer register (EPRiBEL). Household packaging: Fost Plus. Industrial/commercial packaging: Valipac. Fost Plus registers members collectively.
- Authorised representative
- Required for foreign producers since 12 Aug 2026; must be established in Belgium and registered with EPRiBEL.
- WEEE
- Recupel (electrical and electronic equipment).
- Batteries
- Bebat; EU Battery Regulation EPR regime since 18 Aug 2025.
- Thresholds
- According to the Austrian Economic Chamber (WKO), the former 300 kg threshold no longer applies under the PPWR, so small volumes can now be in scope.
- Penalties
- Regional. Flanders: exclusive administrative fines up to €400,000; alternative fines up to €2,000,000.
- Marketplace checks
- Amazon names Belgium in its EU packaging EPR notice (from 12 Aug 2026); eBay may hide listings without a valid number.
- What changed in 2026
- PPWR applies; IVC-CIE became EPRiBEL; AR mandatory; annual registration fees from 2027. Cooperation agreement amendment pending Proposal – not yet law
Who is who in Belgian EPR
Belgium splits producer responsibility by waste stream, and each stream has its own organisation. Recupel and Bebat do not handle packaging.
| Stream | Organisation | Role |
|---|---|---|
| Packaging (authority) | EPRiBEL (formerly IVC-CIE) | Interregional authority; coordinates and supervises packaging obligations in all three regions; producer register |
| Household packaging | Fost Plus | Approved scheme; registers its members collectively in the producer register |
| Industrial / commercial packaging | Valipac | Approved scheme for industrial packaging; similar collective approach |
| Electrical and electronic equipment | Recupel | WEEE producer responsibility |
| Batteries | Bebat | Battery producer responsibility |
What changed in 2026
The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) has applied directly in Belgium and every other member state since 12 August 2026. It entered into force on 11 February 2025 and replaced most of the old Packaging Directive 94/62/EC, which was generally repealed on 12 August 2026 (some provisions continue). National registers and schemes still exist — the PPWR sits on top of them. Read the full overview on our PPWR 2026 page.
- Authorised representative (Art. 45): producers that sell packaged products directly to end users in another member state — whether established in the EU or outside it — must appoint an authorised representative in each member state where they first make packaging available, other than their own. For other non-EU producers, member states may require one.
- Pragmatic enforcement: the European Commission has asked member states to enforce the authorised-representative duty in a "constructive and pragmatic" way while an exemption is being negotiated.
- Penalties: member states must lay down their PPWR penalty rules by 12 February 2027 (Art. 68).
- Fees and labels: EU-harmonised fee modulation by recyclability grade is expected from around 2028–2030; harmonised packaging labelling applies from 12 August 2028 or 24 months after the implementing acts, which had not been adopted as of September 2026.
Proposal – not yet law EU omnibus and the AR exemption. The Environmental Omnibus (COM(2025) 982, 10 December 2025) proposes suspending the authorised-representative duty for EU-established producers. The European Parliament adopted its position on 20 October 2026 (exemption for EU micro and small enterprises until 2035, as reported). The Council agreed its negotiating position on 21 October 2026: EU-established producers placing less than 1 tonne of packaging per year in another member state would not need an authorised representative there, until 2032. Trilogue negotiations follow. This is not law yet, and it does not cover sellers established outside the EU.
Belgium: EPRiBEL, mandatory representative and the pending amendment
- New name: the Interregional Packaging Commission (IVC-CIE) now operates as EPRiBEL.
- Authorised representative: from 12 August 2026, foreign producers must have an authorised representative that is established in Belgium and registered with EPRiBEL.
- Registration fees: any annual registration fee will only be charged from calendar year 2027.
- Cooperation agreement: the amendment of the Belgian cooperation agreement on packaging waste has not yet been approved. Fost Plus notes that this leaves open how sellers on e-commerce platforms will have to register; under the PPWR, sellers may give platforms a written mandate to meet their EPR obligations.
Proposal – not yet law Draft amendment of the cooperation agreement. The draft under discussion would, among other things, create a public producer register and add new fee and penalty rules. These are draft provisions; they may change before adoption.
Packaging obligations in Belgium
A packaging producer in Belgium is a business that places packaging or packaged products on the Belgian market, including a seller who ships packaged goods directly to Belgian end users from another country. Every producer must be in the national producer register, which applies to all household packaging placed on the Belgian market.
- Classify your packaging. As a rule of thumb, packaging that ends up with consumers is household packaging (Fost Plus) and packaging that ends up with businesses is industrial packaging (Valipac). Check borderline cases with the scheme.
- Join the right scheme or register directly. Fost Plus members are registered collectively in the producer register at no additional cost; after confirmation by the authorities, Fost Plus provides the official registration number in its MyFost portal. Non-members register directly through EPRiBEL.
- Appoint a Belgian authorised representative if you are a foreign producer. The representative must be established in Belgium and registered with EPRiBEL.
- Declare your quantities. Scheme contributions depend on the material and quantity of packaging placed on the market; your scheme sets the declaration rhythm and rates.
- Show your number to marketplaces. Amazon and eBay ask for packaging EPR numbers per country.
WEEE obligations in Belgium (Recupel)
Electrical and electronic equipment is handled by Recupel, not by the packaging schemes. If you sell electronics into Belgium, you have a separate WEEE obligation in addition to packaging: producers finance the collection and treatment of waste equipment and report the quantities they place on the market. Whether a foreign distance seller registers directly or through a Belgian representative for WEEE should be checked for the specific product and sales model — we do this in the free obligation check.
Battery obligations in Belgium (Bebat)
Batteries are handled by Bebat. This is a third, separate obligation next to packaging and WEEE; if your products contain batteries, we check how they are covered in the free obligation check.
On top of national rules, the EU Battery Regulation (EU) 2023/1542 has applied its extended producer responsibility regime since 18 August 2025. Further steps are scheduled from 18 February 2027: a QR code on all batteries, removability and replaceability rules, and a battery passport for EV, LMT and industrial batteries above 2 kWh. Battery due-diligence obligations have been postponed to 18 August 2027 (Regulation (EU) 2025/1561).
Proposal – not yet law The EU omnibus would also suspend the authorised-representative duty for batteries (European Parliament vote on 20 October 2026; Council position pending).
Authorised representative in Belgium
An authorised representative (AR) is a Belgium-established company that fulfils a foreign producer's packaging EPR obligations in Belgium and is registered with EPRiBEL. Belgium has required one for foreign producers since 12 August 2026. This is consistent with the EU rule that distance sellers to end users in another member state — EU or non-EU — need an AR there.
The proposed EU exemption (EU-established producers below 1 tonne per year, per the Council position of 21 October 2026) is not law yet and would not cover sellers established outside the EU. Background: authorised representative explained on register-epr.com.
How Certify helps
- Free obligation check. Tell us what you sell into Belgium, through which channels (Amazon, eBay, your own shop) and roughly in what volumes. We map which registers, schemes and representative duties apply to you.
- Registration and representation. Certify prepares the registrations and, where the law requires it, acts as your authorised representative. Certify offers an authorized representative in all EU member states.
- Ongoing compliance. Certify supports the recurring declarations and reports, so your registration numbers stay valid for marketplaces and authorities.
Deadlines for Belgium and the EU
The key Belgian dates are 12 August 2026 (authorised representative mandatory) and 1 January 2027 (annual registration fees can be charged). Full calendar: EPR deadlines.
| Date | Scope | What happens |
|---|---|---|
| 12 Aug 2026 | Belgium | Foreign producers need a Belgian AR registered with EPRiBEL |
| 1 Jan 2027 | Belgium | EPRiBEL annual registration fees start (earliest) |
| 12 Aug 2026 | EU | PPWR applies; authorised-representative duty for distance sellers (Art. 45) |
| 20–21 Oct 2026 | EU | Parliament (20 Oct) and Council (21 Oct) positions on the AR exemption; trilogue next Proposal – not yet law |
| 12 Feb 2027 | EU | Member states must have PPWR penalty rules in place |
| 18 Feb 2027 | EU batteries | QR code on all batteries, removability rules, battery passport (EV, LMT, industrial >2 kWh) |
| 18 Aug 2027 | EU batteries | Battery due-diligence obligations start (postponed) |
| 12 Aug 2028 | EU | Harmonised packaging labelling (or 24 months after implementing acts) |
| Pending | Belgium | Amendment of the cooperation agreement on packaging waste Proposal – not yet law |
Penalties in Belgium
Environmental enforcement in Belgium is regional, so fine levels depend on the region. In Flanders, the environmental enforcement rules provide for exclusive administrative fines of up to €400,000 and alternative administrative fines of up to €2,000,000. The draft amendment of the cooperation agreement would add further penalty rules, but it is not yet law. At EU level, member states must have PPWR penalty rules in place by 12 February 2027.
Marketplaces check EPR numbers. In its notice of 25 March 2026, Amazon announced packaging EPR compliance checks across the EU from 12 August 2026 and named Belgium among the countries concerned; Amazon "may need to stop selling your non-compliant products". eBay requires packaging EPR numbers from 12 August 2026 for each country in which the seller is a producer, and listings may be hidden from buyers in that country. See also our sister site's guide to the Amazon EPR number.
FAQ: EPR in Belgium
Do foreign sellers need an authorised representative in Belgium?
Yes. Since 12 August 2026, foreign producers need an authorised representative for packaging EPR in Belgium. The representative must be established in Belgium and registered with EPRiBEL. A proposed EU exemption for small EU-established producers is not law yet and would not cover non-EU sellers.
What is EPRiBEL?
EPRiBEL is the Belgian interregional authority for packaging producer responsibility, formerly known as the Interregional Packaging Commission (IVC-CIE). It coordinates and supervises packaging obligations across Belgium's three regions. Producers that are not members of Fost Plus can register directly through EPRiBEL.
Fost Plus or Valipac: which scheme do I need?
Fost Plus covers household packaging, which is what most online sellers to consumers place on the market. Valipac covers industrial and commercial packaging. Fost Plus registers its members collectively in the national producer register at no additional cost, and Valipac takes a similar approach for industrial packaging.
Are Recupel and Bebat packaging schemes?
No. Recupel is the organisation for electrical and electronic equipment (WEEE) and Bebat is the organisation for batteries. Packaging is handled by Fost Plus for household packaging and Valipac for industrial packaging.
What fees apply to the Belgian producer register?
Any annual registration fee will only be charged from calendar year 2027. A draft amendment of the Belgian cooperation agreement would also introduce new fee rules. That amendment has not been approved yet, so the draft provisions may still change.
What fines apply for EPR breaches in Belgium?
Enforcement is regional. In Flanders, environmental enforcement rules provide for exclusive administrative fines of up to 400,000 euros and alternative administrative fines of up to 2,000,000 euros. A draft amendment of the cooperation agreement would add further penalty rules; it is not yet law.
Does Amazon check EPR compliance for Belgium?
Yes. In its notice of 25 March 2026, Amazon announced packaging EPR compliance checks across the EU from 12 August 2026 and named Belgium among the countries concerned. Amazon may need to stop selling non-compliant products, and eBay may hide listings in countries where the seller lacks the required EPR number.
- Fost Plus: PPWR insights 8 – mandatory registration in the producer register
- WKO (Austrian Economic Chamber): PPWR in Belgium
- Regulation (EU) 2025/40 (PPWR) on EUR-Lex
- European Commission: EPR for packaging and small businesses
- Council of the EU press release, 21 October 2026
- Amazon Global Selling notice, 25 March 2026
This page is general information, not legal advice. Last reviewed 27 October 2026.
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