+49 6196 5835357

info@ecopv-eu.com

🇧🇪 EPR Compliance for WEEE in Belgium |
Guide and Checklist 2026

Extended Producer Responsibility (EPR) for Electrical and Electronic Equipment – 7 Steps to Compliance + Step-by-Step Checklist

Anyone who sells electrical or electronic equipment (EEE) in Belgium is familiar with the topic: Extended Producer Responsibility (EPR) makes companies jointly responsible for the end-of-life of their products. Belgium has one of the most restrictive WEEE regimes in the EU – with a single, state-approved take-back system, three regional supervisory authorities, and clear penalties for non-compliance.

What does this mean specifically for your company?

Here are the 7 most important steps – including a checklist to get you started.

🇧🇪 EPR Compliance for WEEE in Belgium | Guide and Checklist 2026

Extended Producer Responsibility (EPR) for Electrical and Electronic Equipment – 7 Steps to Compliance + Step-by-Step Checklist

Anyone who sells electrical or electronic equipment (EEE) in Belgium is familiar with the topic: Extended Producer Responsibility (EPR) makes companies jointly responsible for the end-of-life of their products. Belgium has one of the most restrictive WEEE regimes in the EU – with a single, state-approved take-back system, three regional supervisory authorities, and clear penalties for non-compliance.

What does this mean specifically for your company?

Here are the 7 most important steps – including a checklist to get you started.

Who is considered a “producer”?

Under Belgian WEEE regulations, a producer is any company that places electrical and electronic equipment (EEE) on the market for the first time within Belgian territory – regardless of where the company is headquartered.

Specifically, this applies to:

  • Domestic producers – those who manufacture EEE domestically and market it for the first time in Belgium under their own name or brand
  • Importers – those who commercially import EEE into Belgium from other EU member states or third countries
  • EU-based companies operating abroad in distance selling  – those who sell directly to Belgian end consumers via an online store without being established in Belgium
  • Non-EU companies – those who deliver directly to Belgian end customers via e-commerce; in traditional B2B supply chains, the first buyer or importer established in the country is legally considered the manufacturer
  • White-label / private labels – those who have devices manufactured by third parties and place them on the market in Belgium under their own brand name

Practical example: A German company operates an online store and delivers electrical appliances directly to Belgian end customers → is considered a producer under the WEEE Directive → must appoint an authorized representative based in Belgium → requires Recupel membership → must report quantities monthly and pay Recupel fees → must provide Recupel proof on marketplaces (e.g., Amazon.be, Bol.com) to avoid account suspensions.

The 7 Key Steps to EPR Compliance in Belgium

Step 1: Appoint an Authorized Representative (for foreign companies)

Companies not headquartered in Belgium that sell directly to Belgian end consumers via distance selling (B2C or B2B) are legally required to appoint an authorized representative based in Belgium.

The authorized representative assumes full, joint and several financial and administrative liability for all WEEE obligations of the foreign manufacturer toward the Belgian authorities and Recupel.

Requirements for the power of attorney documentation:

  • Written power of attorney agreement (power of attorney / procuration) in one of Belgium’s official languages (Dutch or French) or in English
  • Proof of identity of the foreign company (e.g., extract from the commercial register) – validated digitally
  • A Hague Apostille is not required as a standard

Step 2: Membership in Recupel (the only authorized eco-organization)

Membership in a government-approved take-back organization is mandatory in Belgium. Unlike in many other EU countries, there is no competition between parallel systems in the Belgian WEEE sector – Recupel is the only government-recognized, nationwide collective take-back organization for all WEEE categories throughout Belgium.

OrganizationResponsibility
Recupel vzwOnly authorized PRO (Producer Responsibility Organization) – all WEEE categories, all regions

Recupel handles collection, sorting, recycling, and automated data transfer to all three regional authorities. The joint commission comprising OVAM, SPW, and Bruxelles Environnement oversees Recupel.

Theoretical alternative: Manufacturers can submit an individual waste management plan to the three regional authorities. However, the requirements are extremely restrictive (including proof of a comprehensive, free take-back system in all Belgian municipalities, and astronomical bank guarantees). In the B2C sector, this route is practically irrelevant for mass-market products.

Step 3: Registration with the regional authorities via Recupel

Due to Belgium’s federal structure, three regional authorities are legally responsible for market surveillance:

  1. Flanders: OVAM – Openbare Vlaamse Afvalstoffenmaatschappij
  2. Wallonia: SPW – Service Public de Wallonie, Département du Sol et des Déchets
  3. Brussels-Capital Region: Bruxelles Environnement / Leefmilieu Brussel

Practical procedure:

  1. Join Recupel via the online portal (sign the membership agreement)
  2. Recupel automatically transmits the data to all three regional authorities
  3. Recupel assigns a unique Recupel membership number, which also serves as proof of compliance

The membership number must then be displayed prominently: in the Terms and Conditions, legal notice, marketplace profiles (Amazon.be, Bol.com, etc.), and on the website.

Step 4: Collect device data and report it monthly

Annual or monthly volume reporting is mandatory – broken down by device category and quantity. Reports are submitted digitally via the Recupel reporting portal.

What must be reported?

  • Exact number of units placed on the market in Belgium per equipment category
  • Classification according to the official Recupel equipment categories (WEEE categories in accordance with the EU Directive)

Deadlines:

  • Monthly report (standard): No later than the 18th of the following month
  • Annual report: Available to small businesses with low volumes – requires written approval from Recupel

Step 5: Calculate and pay Recupel fees

The fee is calculated per appliance placed on the Belgian market. The exact amounts depend on the appliance category as specified in the official Recupel fee schedule.

Eco-modulation: Recupel applies criteria for eco-modulation. Appliances for which it can be demonstrated that they:

  • are easy to repair,
  • have a modular design, or
  • can be recycled with minimal release of harmful substances,

 

are classified into lower-cost tariff categories. Those who prioritize eco-design pay less.

Transparency requirement on invoices: The Recupel fee must be clearly stated on all Belgian B2C invoices.

Step 6: Comply with labeling requirements

The following labels are mandatory for all EEE placed on the Belgian market:

  • Crossed-out wheelie bin (WEEE symbol): Must be clearly visible and permanently affixed to the device. May be placed on the packaging if there is insufficient space on the device.
  • Manufacturer information: The brand name, logo, or registered company name must be permanently displayed on the product.

Step 7: Ensure marketplace compliance

Belgium has tightened its Extended Producer Responsibility (EPR) regulations for online marketplaces. Amazon.be, Bol.com, and similar platforms are legally required to verify WEEE compliance for third-party sellers who do not have a permanent establishment or authorized representative in Belgium. If sellers cannot provide this proof, the marketplaces must suspend their accounts.

Consequences for sellers without valid Recupel certification:

  • Automatic account suspension by the platform
  • API-based compliance checks run continuously in the background
  • No Recupel certification = no active seller account

Recommended action: Proactively upload your Recupel membership number to the seller backend of the respective marketplace – before making your first sale.

Who is considered a “producer”?

Under Belgian WEEE regulations, a producer is any company that places electrical and electronic equipment (EEE) on the market for the first time within Belgian territory – regardless of where the company is headquartered.

Specifically, this applies to:

  • Domestic producers – those who manufacture EEE domestically and market it for the first time in Belgium under their own name or brand
  • Importers – those who commercially import EEE into Belgium from other EU member states or third countries
  • EU-based companies operating abroad in distance selling  – those who sell directly to Belgian end consumers via an online store without being established in Belgium
  • Non-EU companies – those who deliver directly to Belgian end customers via e-commerce; in traditional B2B supply chains, the first buyer or importer established in the country is legally considered the manufacturer
  • White-label / private labels – those who have devices manufactured by third parties and place them on the market in Belgium under their own brand name

Practical example: A German company operates an online store and delivers electrical appliances directly to Belgian end customers → is considered a producer under the WEEE Directive → must appoint an authorized representative based in Belgium → requires Recupel membership → must report quantities monthly and pay Recupel fees → must provide Recupel proof on marketplaces (e.g., Amazon.be, Bol.com) to avoid account suspensions.

The 7 Key Steps to EPR Compliance in Belgium

Step 1: Appoint an Authorized Representative (for foreign companies)

Companies not headquartered in Belgium that sell directly to Belgian end consumers via distance selling (B2C or B2B) are legally required to appoint an authorized representative based in Belgium.

The authorized representative assumes full, joint and several financial and administrative liability for all WEEE obligations of the foreign manufacturer toward the Belgian authorities and Recupel.

Requirements for the power of attorney documentation:

  • Written power of attorney agreement (power of attorney / procuration) in one of Belgium’s official languages (Dutch or French) or in English
  • Proof of identity of the foreign company (e.g., extract from the commercial register) – validated digitally
  • A Hague Apostille is not required as a standard

Step 2: Membership in Recupel (the only authorized eco-organization)

Membership in a government-approved take-back organization is mandatory in Belgium. Unlike in many other EU countries, there is no competition between parallel systems in the Belgian WEEE sector – Recupel is the only government-recognized, nationwide collective take-back organization for all WEEE categories throughout Belgium.

OrganizationResponsibility
Recupel vzwOnly authorized PRO (Producer Responsibility Organization) – all WEEE categories, all regions

Recupel handles collection, sorting, recycling, and automated data transfer to all three regional authorities. The joint commission comprising OVAM, SPW, and Bruxelles Environnement oversees Recupel.

Theoretical alternative: Manufacturers can submit an individual waste management plan to the three regional authorities. However, the requirements are extremely restrictive (including proof of a comprehensive, free take-back system in all Belgian municipalities, and astronomical bank guarantees). In the B2C sector, this route is practically irrelevant for mass-market products.

Step 3: Registration with the regional authorities via Recupel

Due to Belgium’s federal structure, three regional authorities are legally responsible for market surveillance:

  1. Flanders: OVAM – Openbare Vlaamse Afvalstoffenmaatschappij
  2. Wallonia: SPW – Service Public de Wallonie, Département du Sol et des Déchets
  3. Brussels-Capital Region: Bruxelles Environnement / Leefmilieu Brussel

Practical procedure:

  1. Join Recupel via the online portal (sign the membership agreement)
  2. Recupel automatically transmits the data to all three regional authorities
  3. Recupel assigns a unique Recupel membership number, which also serves as proof of compliance

The membership number must then be displayed prominently: in the Terms and Conditions, legal notice, marketplace profiles (Amazon.be, Bol.com, etc.), and on the website.

Step 4: Collect device data and report it monthly

Annual or monthly volume reporting is mandatory – broken down by device category and quantity. Reports are submitted digitally via the Recupel reporting portal.

What must be reported?

  • Exact number of units placed on the market in Belgium per equipment category
  • Classification according to the official Recupel equipment categories (WEEE categories in accordance with the EU Directive)

Deadlines:

  • Monthly report (standard): No later than the 18th of the following month
  • Annual report: Available to small businesses with low volumes – requires written approval from Recupel

Step 5: Calculate and pay Recupel fees

The fee is calculated per appliance placed on the Belgian market. The exact amounts depend on the appliance category as specified in the official Recupel fee schedule.

Eco-modulation: Recupel applies criteria for eco-modulation. Appliances for which it can be demonstrated that they:

  • are easy to repair,
  • have a modular design, or
  • can be recycled with minimal release of harmful substances,

 

are classified into lower-cost tariff categories. Those who prioritize eco-design pay less.

Transparency requirement on invoices: The Recupel fee must be clearly stated on all Belgian B2C invoices.

Step 6: Comply with labeling requirements

The following labels are mandatory for all EEE placed on the Belgian market:

  • Crossed-out wheelie bin (WEEE symbol): Must be clearly visible and permanently affixed to the device. May be placed on the packaging if there is insufficient space on the device.
  • Manufacturer information: The brand name, logo, or registered company name must be permanently displayed on the product.

Step 7: Ensure marketplace compliance

Belgium has tightened its Extended Producer Responsibility (EPR) regulations for online marketplaces. Amazon.be, Bol.com, and similar platforms are legally required to verify WEEE compliance for third-party sellers who do not have a permanent establishment or authorized representative in Belgium. If sellers cannot provide this proof, the marketplaces must suspend their accounts.

Consequences for sellers without valid Recupel certification:

  • Automatic account suspension by the platform
  • API-based compliance checks run continuously in the background
  • No Recupel certification = no active seller account

Recommended action: Proactively upload your Recupel membership number to the seller backend of the respective marketplace – before making your first sale.

Step-by-Step Checklist

(a) Companies based in Belgium

1. Assign devices to the correct categories in the Recupel device list

2. Sign the membership agreement on the Recupel vzw online portal

3. Include the Recupel membership number in the Terms and Conditions, Legal Notice, and website

4. Update ERP/invoicing system: Include the Recupel fee on all Belgian B2C invoices

5. Set up monthly volume reporting (deadline: the 18th of the following month)

6. Verify the WEEE symbol and manufacturer information on all products

(b) Companies from other EU countries

1. Check the sales channel: Are direct sales made to Belgian end consumers via an online store? If yes → proceed to step 2

2. Appoint an authorized representative based in Belgium and sign a power of attorney agreement

3. Register with Recupel through the authorized representative (Collective agreement on behalf of the foreign manufacturer)

4. Provide the Recupel membership number to all Belgian marketplaces and trading partners

5. Upload the Recupel certificate to the merchant backend of Amazon.be, Bol.com, etc.

6. Prepare the annual volume report (unit counts by device category)

7. Ensure the WEEE symbol and manufacturer information are displayed on all products

(c) Companies from third countries (outside the EU)

1. Check the supply chain: Delivery to a Belgian importer → legal responsibility lies with the importer; submit all volume and weight data in a timely manner

2. Direct shipment to end consumers (without a Belgian intermediary) → handle all steps listed in (b) through an authorized representative in Belgium

3. Provide your Recupel membership number to all Belgian marketplaces

4. Prepare an annual volume report (unit counts by appliance category)

Step-by-Step Checklist

(a) Companies based in Belgium

1. Assign devices to the correct categories in the Recupel device list

2. Sign the membership agreement on the Recupel vzw online portal

3. Include the Recupel membership number in the Terms and Conditions, Legal Notice, and website

4. Update ERP/invoicing system: Include the Recupel fee on all Belgian B2C invoices

5. Set up monthly volume reporting (deadline: the 18th of the following month)

6. Verify the WEEE symbol and manufacturer information on all products

(b) Companies from other EU countries

1. Check the sales channel: Are direct sales made to Belgian end consumers via an online store? If yes → proceed to step 2

2. Appoint an authorized representative based in Belgium and sign a power of attorney agreement

3. Register with Recupel through the authorized representative (Collective agreement on behalf of the foreign manufacturer)

4. Provide the Recupel membership number to all Belgian marketplaces and trading partners

5. Upload the Recupel certificate to the merchant backend of Amazon.be, Bol.com, etc.

6. Prepare the annual volume report (unit counts by device category)

7. Ensure the WEEE symbol and manufacturer information are displayed on all products

(c) Companies from third countries (outside the EU)

1. Check the supply chain: Delivery to a Belgian importer → legal responsibility lies with the importer; submit all volume and weight data in a timely manner

2. Direct shipment to end consumers (without a Belgian intermediary) → handle all steps listed in (b) through an authorized representative in Belgium

3. Provide your Recupel membership number to all Belgian marketplaces

4. Prepare an annual volume report (unit counts by appliance category)

Are you planning to sell your products in Belgium?

We’ll help you ensure compliance with Belgium’s WEEE EPR regulations so you can get started with legal certainty.

Are you planning to sell your products in Belgium?

We’ll help you ensure compliance with Belgium’s WEEE EPR regulations so you can get started with legal certainty.

Contact

We look forward to your message!

info@ecopv-eu.com

+49 6196 5835357

Frankfurter Str. 70-72
65760 Eschborn

Contact

We look forward to your message!

info@ecopv-eu.com

+49 6196 5835357

Frankfurter Str. 70-72
65760 Eschborn