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

Extended Producer Responsibility (EPR) for Packaging – 7 Steps to Compliance + Step-by-Step Checklist

Anyone selling packaged products in Belgium has a legal obligation: Extended Producer Responsibility (EPR) makes companies jointly responsible for the end-of-life of their packaging. Belgium operates one of the strictest and most differentiated packaging EPR systems in Europe – with a clear legal distinction between household and commercial waste streams, two separate take-back organizations, and a joint interregional supervisory authority.

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 Packaging in Belgium |
Guide and Checklist 2026

Extended Producer Responsibility (EPR) for Packaging – 7 Steps to Compliance + Step-by-Step Checklist

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 packaging regulations, the responsible party is not the manufacturer of the packaging material, but rather the company that first places the packaged products on the market in Belgium.

Specifically, this applies to:

Brand owners – those who fill, package, or have products packaged under their own brand in Belgium
Importers – those who import packaged goods into Belgium from the EU or third countries, provided the brand does not belong to a brand owner based in Belgium
Manufacturers of service packaging – those who manufacture or import service packaging (carry bags, cups, gift wrap) in Belgium and supply it to retail stores; The obligation is intentionally placed on the first party to place the empty packaging on the market
EU-based companies engaged in distance selling – those who sell packaged goods directly to Belgian end consumers (B2C) via an online store; the responsibility covers both the product packaging and the shipping packaging used
Non-EU companies – those who deliver directly to Belgian private customers via B2C direct shipping; in traditional B2B supply chains, responsibility passes to the Belgian first importer

Important: Volume Thresholds

Packaging Type	Threshold
Household packaging (B2C)	Exempt for total quantities under 300 kg per year. For quantities of 300 kg or more, full licensing and reporting requirements apply.
Commercial packaging (B2B)	Exempt for total quantities under 300 kg per year. For quantities of 300 kg or more, full licensing and reporting requirements apply.

Please note: With the entry into force of the European PPWR (Packaging and Packaging Waste Regulation), the rules are changing fundamentally.

Threshold eliminated: The Belgian 300-kg de minimis threshold is being eliminated without replacement, and the requirement applies starting from the first gram.

Practical example: A Dutch company operates an online store and delivers packaged cosmetic products directly to Belgian private customers → is considered a producer under the Packaging EPR → must appoint an authorized representative based in Belgium → requires a Fost -Plus membership → must report weights by material fraction annually and pay fees → must include shipping cartons and filling material in the quantity report → must store Fost-Plus proof in marketplace backends (Amazon.be, Bol.com).

The 7 Key Steps to EPR Compliance in Belgium

Step 1: Appoint an Authorized Representative (for Foreign Companies)

Foreign online retailers without a physical presence in Belgium that sell directly to Belgian consumers must appoint an authorized representative based in Belgium as part of the ongoing alignment with European EPR standards.

The authorized representative acts on behalf of the company in dealings with the supervisory authority IVK-CIE and the take-back systems. They are jointly and severally liable for the accuracy of data transmission and the timely payment of material fees.

Requirements for the power of attorney documentation:

A bilingual or English-language power of attorney, signed by the authorized representatives of both parties
A notarized Hague Apostille is not required by Belgian law as a standard procedure

Step 2: Joining the Right Take-Back Organization

In Belgium, there are two government-approved systems that are strictly divided based on the end-use of the packaging. Free competition within the same market segment is prohibited. Choosing the right system is therefore not a matter of choice but is required by law.

Organization	Responsibility
Fost Plus	The only authorized PRO for household packaging (B2C) – organizes nationwide collection (blue PMD bin, glass, waste paper)
Valipac	The only authorized PRO for commercial and industrial packaging (B2B) – organizes the recycling of transport packaging in businesses

Who needs which system?

Exclusively B2C packaging → Fost Plus only
Exclusively B2B packaging (≥ 300 kg/year) → Valipac only
Mixed use (e.g., cleaning products for households and businesses) → both systems, with a calculated allocation of quantities

Voluntary commitment: Theoretically permissible by submitting a waste management plan to the IVK. Practically impossible for B2C (proof of household collection required). Usable for B2B within closed pallet deposit systems – but requires an annual IVK audit.

Step 3: Registration with the regulatory authority IVK-CIE

The competent regulatory authority for packaging is the Interregional Packaging Commission (IVK) / Interrégionale de l’Emballage (CIE) – the joint authority of all three Belgian regions (Flanders, Wallonia, Brussels-Capital).

Practical procedure:

Join Fost Plus (B2C) via the MyFost portal and/or Valipac (B2B) via the Valipac portal
The systems automatically and directly transmit the registration data to the IVK-CIE database
As a result, separate registration by the company on the IVK-CIE online portal is generally not required

The compliance confirmation is considered officially valid from the moment the system transaction is completed.

Step 4: Record packaging data and submit an annual report

Submitting an annual report on quantities is mandatory – broken down by material category and weight. Reports are submitted digitally via the respective platforms (MyFost for Fost Plus, Valipac Portal for Valipac).

What must be reported?

Exact weight figures in kg, broken down by material fractions:
- Plastics: PET, PP, PE, PS, others
- Paper / Cardboard
- Glass
- Metal: Aluminum, Steel
- Wood

Clear allocation of each material quantity to household (B2C) or commercial (B2B) quotas
For mixed use: calculated allocation of quantities to both systems

Deadlines:

Annual report (standard): Submission by February 28 for the previous calendar year
Quarterly advance payment reports: Mandatory for large retailers

Step 5: Calculate and pay fees

Fees are based on the net weight of the packaging materials, multiplied by the material-specific rates (in euros per kilogram).

Eco-modulation: Belgium operates one of the strictest eco-modulation systems in Europe. Contributions are significantly influenced by the following parameters:

Bonuses (reduced rates):

Mono-materials (e.g., clear PET, unpigmented HDPE)
Packaging with a certified proportion of recycled material

Penalty surcharges – “Undesirable Packaging” category:

PET bottles with full-surface, non-removable PVC sleeves
Multilayer plastics with non-separable material composites
Plastics colored with carbon black (black plastic packaging)

Packaging in the penalty category is subject to a rate many times higher than the base rate. The choice of packaging design thus has direct financial implications.

Step 6: Comply with labeling requirements

Material labeling:

The Europe-wide harmonized recycling codes apply (e.g., PET 01, HDPE 02, PP 05)
Sorting instructions:

Sorting instructions:

Vague environmental claims (e.g., “eco-friendly,” “green packaging”) are prohibited
Fost Plus recommends using standardized Belgian-Scandinavian pictograms that indicate to consumers:
- Does this item belong in the blue PMD bag?
- Does this item belong in paper recycling?
- Or in the general waste?

Step 7: Ensure marketplace compliance

Online marketplaces (Amazon.be, Bol.com) actively check their sellers’ EPR compliance. Without valid Fost-Plus certification, automatic account suspension may occur.

Recommendation:

Proactively upload the Fost-Plus certificate to the merchant backend of the respective marketplace—before making your first sale
For mixed
B2C/B2B operations: keep both certificates (Fost-Plus + Valipac) on hand

Who is considered a “producer”?

Specifically, this applies to:

Brand owners – those who fill, package, or have products packaged under their own brand in Belgium
Importers – those who import packaged goods into Belgium from the EU or third countries, provided the brand does not belong to a brand owner based in Belgium
Manufacturers of service packaging – those who manufacture or import service packaging (carry bags, cups, gift wrap) in Belgium and supply it to retail stores; The obligation is intentionally placed on the first party to place the empty packaging on the market
EU-based companies engaged in distance selling – those who sell packaged goods directly to Belgian end consumers (B2C) via an online store; the responsibility covers both the product packaging and the shipping packaging used
Non-EU companies – those who deliver directly to Belgian private customers via B2C direct shipping; in traditional B2B supply chains, responsibility passes to the Belgian first importer

Important: Volume Thresholds

Packaging Type	Threshold
Household packaging (B2C)	Exempt for total quantities under 300 kg per year. For quantities of 300 kg or more, full licensing and reporting requirements apply.
Commercial packaging (B2B)	Exempt for total quantities under 300 kg per year. For quantities of 300 kg or more, full licensing and reporting requirements apply.

Please note: With the entry into force of the European PPWR (Packaging and Packaging Waste Regulation), the rules are changing fundamentally.

Threshold eliminated: The Belgian 300-kg de minimis threshold is being eliminated without replacement, and the requirement applies starting from the first gram.

The 7 Key Steps to EPR Compliance in Belgium

Step 1: Appoint an Authorized Representative (for Foreign Companies)

Requirements for the power of attorney documentation:

A bilingual or English-language power of attorney, signed by the authorized representatives of both parties
A notarized Hague Apostille is not required by Belgian law as a standard procedure

Step 2: Joining the Right Take-Back Organization

Organization	Responsibility
Fost Plus	The only authorized PRO for household packaging (B2C) – organizes nationwide collection (blue PMD bin, glass, waste paper)
Valipac	The only authorized PRO for commercial and industrial packaging (B2B) – organizes the recycling of transport packaging in businesses

Who needs which system?

Exclusively B2C packaging → Fost Plus only
Exclusively B2B packaging (≥ 300 kg/year) → Valipac only
Mixed use (e.g., cleaning products for households and businesses) → both systems, with a calculated allocation of quantities

Step 3: Registration with the regulatory authority IVK-CIE

Practical procedure:

Join Fost Plus (B2C) via the MyFost portal and/or Valipac (B2B) via the Valipac portal
The systems automatically and directly transmit the registration data to the IVK-CIE database
As a result, separate registration by the company on the IVK-CIE online portal is generally not required

The compliance confirmation is considered officially valid from the moment the system transaction is completed.

Step 4: Record packaging data and submit an annual report

What must be reported?

Exact weight figures in kg, broken down by material fractions:
- Plastics: PET, PP, PE, PS, others
- Paper / Cardboard
- Glass
- Metal: Aluminum, Steel
- Wood

Clear allocation of each material quantity to household (B2C) or commercial (B2B) quotas
For mixed use: calculated allocation of quantities to both systems

Deadlines:

Annual report (standard): Submission by February 28 for the previous calendar year
Quarterly advance payment reports: Mandatory for large retailers

Step 5: Calculate and pay fees

Fees are based on the net weight of the packaging materials, multiplied by the material-specific rates (in euros per kilogram).

Eco-modulation: Belgium operates one of the strictest eco-modulation systems in Europe. Contributions are significantly influenced by the following parameters:

Bonuses (reduced rates):

Mono-materials (e.g., clear PET, unpigmented HDPE)
Packaging with a certified proportion of recycled material

Penalty surcharges – “Undesirable Packaging” category:

PET bottles with full-surface, non-removable PVC sleeves
Multilayer plastics with non-separable material composites
Plastics colored with carbon black (black plastic packaging)

Packaging in the penalty category is subject to a rate many times higher than the base rate. The choice of packaging design thus has direct financial implications.

Step 6: Comply with labeling requirements

Material labeling:

The Europe-wide harmonized recycling codes apply (e.g., PET 01, HDPE 02, PP 05)

Sorting instructions:

Vague environmental claims (e.g., “eco-friendly,” “green packaging”) are prohibited
Fost Plus recommends using standardized Belgian-Scandinavian pictograms that indicate to consumers:
- Does this item belong in the blue PMD bag?
- Does this item belong in paper recycling?
- Or in the general waste?

Step 7: Ensure marketplace compliance

Online marketplaces (Amazon.be, Bol.com) actively check their sellers’ EPR compliance. Without valid Fost-Plus certification, automatic account suspension may occur.

Recommendation:

Proactively upload the Fost-Plus certificate to the merchant backend of the respective marketplace—before making your first sale
For mixed
B2C/B2B operations: keep both certificates (Fost-Plus + Valipac) on hand

Step-by-Step Checklist

(a) Companies based in Belgium

1. Packaging audit: Separate all packaging into B2C (household) and B2B (transport/commercial) categories

2. Check the commercial threshold: Do B2B volumes exceed 300 kg/year? If so → Sign a Valipac contract

3. B2C registration: Mandatory membership with Fost Plus starting from the first gram via the MyFost portal

4. Automatic IVK-CIE compliance is activated upon system completion

5. Adapt ERP/warehouse system: Record weights by material fraction and B2C/B2B classification

6. Submit annual report with exact weight details by February 28

7. Check packaging design for eco-modulation criteria (single material, no PVC, no carbon black)

8. Check labeling: Recycling codes + sorting instructions on all packaging

(b) Companies from other EU countries

1. Analyze e-commerce volume: Determine the total amount of product packaging and shipping cartons for deliveries to Belgium

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

3. Join Fost Plus through the authorized representative (MyFost portal)

4. Check Valipac: Do B2B volumes to Belgium exceed 300 kg/year? If so → join via the authorized representative as well

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

6. Prepare the annual volume report (weight by material fraction, B2C/B2B separated)

7. Don’t forget to include shipping boxes and packing materials in the volume report

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

1. Check the supply chain: Delivery to a Belgian B2B customer → this customer is considered the importer and responsible party; submit material and weight data in a timely and accurate manner

2. Direct shipment to Belgian private customers → all steps listed in (b) must be handled through a representative based in Belgium

3. Provide Fost-Plus proof to all Belgian marketplaces

4. Prepare an annual volume report (weight by material category)