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Belgium EPR

Provinces

Packaging

Provinces

Packaging

About

Packaging

About

Packaging

What is Belgium EPR packaging?

EPR (Extended Producer Responsibility) in Belgium is a legal obligation requiring companies that place packaging on the Belgian market to finance and organize its collection, sorting, and recycling. In practice, compliance is managed mainly through two Producer Responsibility Organizations (PROs):

Fost Plus (household packaging / consumer packaging)

Valipac (industrial & commercial packaging)

Companies must:

submit packaging declarations

pay eco-fees (contributions)

Does this apply to e-commerce & online sales?

Yes. Belgian packaging EPR fully applies to e-commerce and online sales. If you sell products online to Belgian customers, you are considered to be placing packaging on the Belgian market even if:

you have no establishment in Belgium

your warehouse is located in another EU country

goods are shipped cross-border directly to Belgian consumers

This is especially relevant for:

Amazon sellers

Shopify / WooCommerce stores

D2C brands

Who is the “producer” under Belgium EPR

In Belgium, the “producer” is the company that first places packaged goods or packaging on the Belgian market. In most cases, the producer is:

a Belgian manufacturer

a Belgian importer

a foreign seller shipping directly to Belgian end customers

Who must register for EPR packaging in Belgium

Registration is mandatory for any company that:

sells packaged products in Belgium

imports packaged goods into Belgium

supplies packaging materials to Belgian customers

ships parcels containing packaging to Belgian consumers (e-commerce)

Even minimal packaging (a cardboard box, plastic film, tape, fillers) is covered.

Belgium EPR packaging registration threshold

Belgium generally does not have a meaningful “small seller exemption threshold” like some other countries. If you place packaging on the Belgian market, obligations apply. Depending on volume, simplified reporting options may exist, but the principle remains: packaging placed on the market = EPR obligation.

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Packaging covered (and excluded)

Covered packaging Belgian EPR applies broadly to all packaging, including:

primary packaging (bottles, jars, pouches)

secondary packaging (boxes, wraps)

transport packaging (pallet wrap, cartons)

e-commerce shipping packaging (shipping boxes, fillers, bubble wrap)

labels, stickers, tapes

Materials covered include:

plastic

paper/cardboard

metal

glass

wood

composite materials

Excluded packaging Exclusions exist but are limited and depend on interpretation. For example:

packaging not placed on the Belgian market

transit packaging (not remaining in Belgium)

Producer Responsibility Organization (PRO)

Belgium’s packaging EPR system relies heavily on PROs. Key PROs

Fost Plus

household packaging (consumer/B2C waste stream)

almost always relevant for e-commerce

Valipac

industrial and commercial packaging (B2B stream)

pallets, stretch film, transport boxes, etc.

Some companies must join both systems depending on packaging flows.

EPR Registrationin Belgium

Typical registration steps: Step 1: Identify packaging type

household packaging (Fost Plus)

industrial packaging (Valipac)

or both

Step 2: Sign an agreement with the PRO A contract is signed with Fost Plus and/or Valipac. Step 3: Receive a membership / participant number The PRO provides an ID number and access to the reporting platform. Step 4: Start reporting and compliance After registration, the company must submit declarations and pay eco-fees.

Authorized representative

Foreign companies can sometimes register directly, but in many cases they use an authorized representative. An authorized representative is often used to:

manage communication with PROs

handle French/Dutch language requirements

ensure reporting is accurate
reduce compliance risk

What data must be reported

Typically, companies must report: 1) Packaging material type For example:

plastic

paper/cardboard

glass

aluminium/steel

wood

composites

2) Packaging flow type

household packaging (B2C)

industrial packaging (B2B)

3) Weight of packaging Reporting is usually required in kilograms per material category. 4) Additional details (sometimes) Certain packaging types may require more specific reporting.

First reporting period

The first reporting period typically starts:

from the date you began selling into Belgium, or

from the registration date

Important: registration does not automatically remove past obligations. If sales occurred earlier, retroactive reporting may be required.

EPR reporting deadlines

Deadlines depend on the PRO and the size of the company. Most commonly:

reporting is annual

large producers may report more frequently

Usually, declarations are submitted for the previous calendar year.

Labels & marketing claims

In Belgium, companies must be cautious when using environmental marketing claims such as:

“eco-friendly”

“100% recyclable”

“green packaging”

If such claims are misleading, they may be considered greenwashing. Also, certain symbols (such as the “Green Dot”) require licensing rules and may only be used under specific conditions. Being registered with Fost Plus does not automatically mean all eco-labels are permitted.

EPR ecofees & eco-modulation

Companies pay eco-fees, typically calculated based on:

packaging weight

packaging material (plastic is often more expensive)

recyclability

packaging stream (household vs industrial)

Eco-modulation

Belgium uses eco-modulation principles where:

recyclable packaging = lower fees

complex / composite materials = higher fees

This encourages companies to reduce plastic use and move toward mono-material packaging.

Risks,penalties & common mistakes

Key risks

fines for non-registration

penalties for inaccurate reporting

retroactive payment obligations

potential marketplace compliance issues (future risk)

Common mistakes

assuming EPR does not apply if the warehouse is outside Belgium
excluding shipping packaging (boxes, fillers, tape)
incorrect split between B2B and B2C packaging streams
failing to classify composite packaging correctly
assuming PRO membership = full legal registration in all cases

What e-commerce sellers should do now

A practical action checklist: Step 1: Review your supply chain

identify who is the first entity placing packaging on the Belgian market

Step 2: Identify packaging types placed on the market

product packaging

shipping packaging

promotional packaging

Step 3: Estimate packaging volumes At minimum, calculate approximate weights for:

boxes

plastic films

tapes

fillers

internal packaging components

Step 4: Select the correct PRO

B2C packaging → usually Fost Plus

B2B packaging → Valipac

Step 5: Register and set up reporting processes

prepare SKU lists

create packaging BOMs (bill of materials)

set up internal tracking and reporting

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FAQ for Belgium EPR Packaging

Do I need EPR if sales volumes are small

Yes. In general, obligations apply as soon as packaging is placed on the Belgian market.

If I sell via Amazon FBA into Belgium, who is the producer

In most cases, the seller remains the producer, not Amazon. However, the exact responsibility may depend on the supply chain and contractual model.

Do I need to report marketplace shipping packaging

If the marketplace repackages goods, responsibility can become complex. Usually, product packaging remains the seller’s responsibility, while shipping packaging may fall under the logistics operator, but this must be verified case by case.

Can I register without a Belgian legal entity

Yes, often possible, but an authorized representative may be required.

What happens if I do not register

Risks include:

fines

retroactive eco-fees

compliance issues with marketplaces or audits

Is special packaging labeling mandatory in Belgium

Belgium does not currently have a universal mandatory labeling scheme like France (Triman), but rules may apply depending on claims and packaging type.

February 12, 2026 82

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