Overview of Belgium EPR Requirement
Belgium’s Extended Producer Responsibility (EPR) framework requires producers and importers to manage the lifecycle of packaging waste. Companies must register with Fost Plus for household packaging and Valipac for industrial packaging. The legal basis is the Cooperation Agreement, which imposes obligations related to recycling (take-back), reporting, and waste prevention. Companies must annually declare packaging data by February 28th and maintain records to meet regulatory standards. The system distinguishes between household and industrial packaging based on usage and volume, ensuring tailored compliance pathways.
Benefits for Businesses and the Environment
The Belgium EPR system promotes sustainable waste management and circular economy practices. For businesses, compliance enhances brand reputation, opens access to eco-conscious markets, and can yield cost savings via bonuses for using recycled content. Environmentally, it reduces landfill waste, promotes material recovery, and encourages the design of recyclable packaging. Valipac clients, for example, receive a €50/tonne bonus for packaging using 30%+ post-consumer recycled content, fostering greener practices.
What Qualifies as Packaging
In Belgium, packaging is categorized as primary (sales), secondary (grouped), or tertiary (transport). All packaging used to market, protect, deliver, or present products qualifies—whether household or industrial. Classification depends on end-use, volume, and content. For instance, drinks packaging below 20L is household, while packaging above that is industrial. Accessories and service packaging also fall under these regulations, aligning with the main product’s classification.
Exempted Packaging
Certain packaging scenarios are exempt from EPR obligations in Belgium. These include private label products, where the customer—not the manufacturer—is responsible for packaging compliance. Contract packers handling goods without owning them are also exempt. Furthermore, businesses placing less than 300 kg of packaging annually on the market are not obligated to comply with take-back rules, unless they choose to use compliance logos such as the Green Dot.
Special Requirements for Single-Use Plastic (SUP) Packaging
Belgium does not treat single-use plastic (SUP) packaging as a distinct compliance category under EPR, but includes it in the broader scope of household and industrial packaging. However, if a company exceeds 300 tonnes of SUP annually, a triennial prevention plan must be submitted to the IRPC. All packaging, including SUPs, must meet recyclability standards and be declared accordingly in detailed or simplified formats.
Who Must Register for EPR in Belgium
Any company placing packaged goods on the Belgian market—either through manufacturing, importing, or unpacking for business use—must comply with EPR. Four types of responsible parties exist: packagers (Type A), importers (Type B), users (Type C), and service packaging providers (Type D). Registration is done with Fost Plus (household) or Valipac (industrial), based on the type of packaging handled.
Data Management and Record-Keeping
Accurate data management is essential under Belgium’s EPR rules. Companies must submit annual declarations by February 28th, detailing packaging materials, weights, types, and recyclability. Data submission varies by declaration type—detailed, simplified, or sector-specific. Businesses must track both household and industrial packaging separately, maintain documentation for proof of recycling, and report usage of recycled content to qualify for bonuses and ensure compliance.
Common EPR Compliance Challenges in Belgium
Businesses in Belgium often face challenges in classifying packaging correctly, especially when distinguishing between household and industrial use. Navigating multiple declaration types, ensuring timely submission, and maintaining compliance across evolving regulations can be complex. Additionally, tracking recycled content accurately and coordinating declarations across different entities within a corporate group adds layers of difficulty for multinational firms.
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