What is Belgium EPR EEE

Belgium's EEE EPR framework is governed by regional legislation implementing the EU WEEE Directive (Directive 2012/19/EU). Due to Belgium's constitutional structure, environmental competence is divided between Flanders, Wallonia, and Brussels-Capital, each with their own regional decrees transposing the WEEE Directive. In practice, all three regions operate through a single collective compliance scheme — Recupel — which coordinates EEE take-back, reporting, and recycling obligations across all regions under a unified system. Recupel is the sole authorised Producer Responsibility Organisation (PRO) for EEE and WEEE in Belgium, approved by all three regional environmental authorities. Recupel moved from a 10-category to a 6-category structure in 2022, aligned with the open scope approach of the revised WEEE Directive. The reporting obligation for producers has been in place for over 20 years. Significant changes took effect from 29 March 2025, when new obligations were introduced for operators of online marketplaces requiring them to verify seller EPR compliance.

Does This Apply to E-Commerce & Online Sales

Yes. Belgium's WEEE legislation explicitly captures foreign companies selling EEE directly to Belgian consumers via e-commerce. Foreign distance sellers are treated as producers under Belgian regional legislation and must affiliate with Recupel before selling EEE to Belgian consumers. From 29 March 2025, online marketplace operators are required to:

1. Inform sellers in writing about their EPR obligations under Belgian WEEE legislation
2. Verify whether sellers comply with those obligations — by confirming affiliation with Recupel or the existence of an individual waste management plan in each region
3. Refuse access to non-compliant sellers — or take over EPR obligations themselves

If a marketplace takes over EPR obligations, it must register as an online marketplace with Recupel. Zalando requires sellers to provide their Recupel member code as proof of EEE EPR compliance. Non-compliant sellers have their EEE assortment deactivated in the Belgian market.

Who is the "Producer" under Belgium EPR?

Under Belgian regional WEEE legislation, a producer is the company that first brings EEE onto the Belgian market. The producer is not necessarily the manufacturer. You are considered a producer if:

1. You manufacture EEE in Belgium and sell it domestically under your own name.
2. You import EEE into Belgium from another EU Member State or from outside the EU under your own name.
3. You sell EEE in Belgium under your own brand name, regardless of where it was manufactured.
4. You are a distance seller without a Belgian establishment that sells EEE directly to Belgian consumers or end users via e-commerce.

An important nuance: if you only sell EEE manufactured by a Belgian company and that company carries the take-back responsibility, you may not need to join Recupel separately. When in doubt, Recupel should be contacted directly to confirm the classification.

Who Must Register for EPR EEE in Belgium

All producers placing EEE on the Belgian market must affiliate with Recupel — the sole authorised PRO for all three Belgian regions. There is no separate registration with individual regional authorities — Recupel manages compliance coordination across Flanders, Wallonia, and Brussels-Capital simultaneously. Upon affiliation, producers receive a member code — Belgium's EEE EPR registration number — which must be provided to online marketplaces and used in BeWeee reporting. The member code is what Zalando, Amazon, and other platforms require as proof of EEE EPR compliance in Belgium. Alternatively, producers may comply via an individual waste management plan approved in each region, but this is significantly more complex and rarely used in practice.

Belgium EPR EEE Registration Threshold

Belgium applies no de minimis threshold for EEE EPR registration. Even small volumes of EEE placed on the Belgian market trigger the obligation. All producers — regardless of size, volume, or turnover — must affiliate with Recupel.

EEE Categories Covered (and Excluded)

Belgium moved to a 6-category structure in 2022, aligned with the open scope approach of the revised WEEE Directive. All EEE placing batteries on the Belgian market falls within scope unless specifically excluded. The six categories are: Large household appliances Refrigerators, washing machines, dishwashers, cookers, ovens, electric heaters, air conditioners, and similar large household appliances. Small household appliances and IT and consumer electronics Small appliances (toasters, coffee machines, irons), IT equipment (computers, laptops, tablets, printers), consumer electronics (TVs, audio equipment, cameras, smartphones), and telecommunications equipment. Screens and monitors Televisions, computer monitors, laptops with screens, and digital photo frames. Lamps and lighting Fluorescent lamps, LED lamps, high-intensity discharge lamps, and luminaires. Large cooling and freezing appliances Large refrigerators, freezers, and industrial cooling equipment. Other EEE All remaining EEE not captured in the above categories, consistent with the open scope approach. Key exclusions:

• EEE specifically designed and installed as part of another type of equipment and which can only function as part of that equipment
• Large-scale fixed installations and large-scale stationary industrial tools
• Military or space equipment specifically designed for these purposes
• Implanted or infected medical devices

Producer Responsibility Organization (PRO)

Recupel is the sole authorised PRO for EEE and WEEE across all three Belgian regions. Recupel manages:

• Nationwide EEE take-back infrastructure, coordinating collection points across all three regions
• BeWeee — the Belgian web-based reporting tool for annual EEE placed-on-market and WEEE collected and processed declarations
• Contribution collection from member producers
• Coordination with regional environmental authorities on compliance monitoring

Recupel also manages marketplace obligations from 29 March 2025, registering online marketplace operators that wish to assume EPR on behalf of their sellers. All invoices and commercial communications where the price of an appliance is mentioned must include the statement "Recupel contribution included" to indicate the contribution has been paid and is included in the product price.

EPR Registration in Belgium

The registration process for EEE producers in Belgium is as follows:

1. Determine whether your company qualifies as a producer under Belgian regional WEEE legislation — i.e. whether you are placing EEE on the Belgian market for the first time.
2. If established outside Belgium, appoint an authorised representative with a Belgian establishment before initiating any registration.
3. Affiliate with Recupel (recupel.be) by completing the online registration and signing the membership agreement.
4. Receive your member code — Belgium's EEE EPR registration number.
5. Provide the member code to Zalando, Amazon, and other online marketplaces where you sell EEE in Belgium.
6. Report EEE placed on the Belgian market through BeWeee — quarterly (with optional monthly) for placed-on-market data, and annually for WEEE collected and processed.
7. Pay Recupel contributions based on the weight and category of EEE placed on the Belgian market.
8. Comply with take-back obligations for retailers — including 1:1 take-back and, for stores over 400m² sales area for EEE, acceptance of small appliances without a new purchase requirement.

Authorized Representative

Foreign companies without a Belgian establishment must appoint an authorised representative with a Belgian establishment before affiliating with Recupel. The AR handles registration, reporting through BeWeee, contribution payments, and communication with Recupel and regional authorities. For online marketplaces wishing to assume EPR on behalf of their sellers, the marketplace must either have a Belgian establishment and Belgian VAT number, or have appointed an authorised representative. Important development: In December 2025, the European Commission proposed suspending the authorised representative requirement for EU-established companies until 2035 under Proposal COM(2025) 983 (WEEE). This proposal has not been formally adopted as of May 2026. For non-EU producers, the requirement is not affected and continues to apply.

What Data Must Be Reported

Producers must report the following data through BeWeee: Placed-on-market (EEE) reporting:

• Weight (kilograms) of EEE placed on the Belgian market, by Recupel category — reported quarterly (monthly optional)
• Regional breakdown where applicable (Flanders, Wallonia, Brussels-Capital)

WEEE reporting (annual):

• Weight of waste EEE collected and processed — reported annually in January for the previous year
• Regional deadlines: 1 July for Flanders; 31 May for Brussels and Wallonia

Both Recupel members and non-members fulfil their reporting obligations via BeWeee.

First Reporting Period & EPR Reporting Deadlines

Belgium's WEEE reporting obligation has been in place for producers for over 20 years. Key recurring deadlines:

• Quarterly: Placed-on-market EEE declarations through BeWeee (monthly optional)
• January (annual): WEEE collected and processed report submitted through BeWeee
• 31 May: Annual regional deadline for Brussels-Capital and Wallonia
• 1 July: Annual regional deadline for Flanders
• 29 March 2025: Online marketplace obligations entered into force — marketplaces must verify seller compliance and may assume EPR

Labels & Marketing Claims

Crossed-out wheeled bin symbol All EEE placed on the Belgian market must be marked with the crossed-out wheeled bin symbol, indicating separate collection. The symbol must be visible, legible, and indelible on the product, or — where this is not possible — on the packaging or accompanying documentation. "Recupel contribution included" statement All invoices and commercial communications where the price of an EEE appliance actually purchased by the consumer is mentioned must include the statement "Recupel contribution included". This confirms that the Recupel contribution has been paid and is included in the product price. Online marketplace operators must inform their sellers of this requirement. CE marking Mandatory for applicable EEE categories under EU product safety legislation. RoHS compliance EEE must comply with Directive 2011/65/EU (RoHS) restricting hazardous substances. RoHS compliance documentation is maintained separately from WEEE registration. Language requirements Consumer-facing information must be in the language of the relevant region — Dutch in Flanders, French in Wallonia, and both in Brussels-Capital. Environmental claims The Empowering Consumers for the Green Transition Directive (2024/825/EU) must be transposed by March 2026, after which unsubstantiated green claims will be prohibited across the EU including Belgium.

EPR Eco Fees & Eco-Modulation

Recupel sets contribution rates for member producers based on the weight and category of EEE placed on the Belgian market. Contributions cover the cost of take-back infrastructure, collection, sorting, treatment, and recycling across all three Belgian regions. Specific contribution rates are published by Recupel and should be confirmed at the time of affiliation. Rates are structured by Recupel's 6-category framework. Belgium does not currently apply a formal eco-modulation framework adjusting contributions based on product repairability, recyclability, or eco-design criteria for EEE. As the Ecodesign for Sustainable Products Regulation (ESPR) implementing regulations are adopted for specific EEE categories, eco-design criteria may influence future contribution structures.

Risks, Penalties & Common Mistakes

1. Selling EEE in Belgium without Recupel affiliation. From 29 March 2025, online marketplaces are required to verify seller compliance and refuse access to non-compliant sellers. Zalando deactivates EEE assortments for non-compliant sellers. Regional environmental authorities can impose fines and enforcement actions.
2. Failing to appoint an authorised representative. Foreign companies without a Belgian establishment must appoint an AR before affiliating with Recupel. Without an AR, affiliation cannot be completed.
3. Missing BeWeee reporting deadlines. Placed-on-market declarations are due quarterly; WEEE collected and processed declarations are due annually with different regional deadlines (31 May for Brussels and Wallonia; 1 July for Flanders). Missing deadlines is a compliance breach.
4. Omitting the "Recupel contribution included" statement. Invoices and commercial communications where EEE prices are shown must include this statement. Omission is a breach of Recupel membership obligations.
5. Assuming one EU registration covers Belgium. EEE EPR registration is national. Recupel membership is required separately from WEEE registrations in other EU member states.
6. Missing take-back obligations. EEE sellers must accept 1:1 take-back of equivalent old devices when new ones are sold. Stores over 400m² selling area must accept small appliances free of charge without a new purchase.
7. Incorrect category classification. Belgium moved to a 6-category structure in 2022. Producers must map their products to the correct Recupel categories for accurate reporting.

What E-Commerce Sellers Should Do Now

1. Confirm whether your products qualify as EEE and whether you are placing them on the Belgian market for the first time.
2. If established outside Belgium, appoint an authorised representative with a Belgian establishment.
3. Affiliate with Recupel (recupel.be) and receive your member code.
4. Provide the member code to Zalando, Amazon, and other marketplaces where you sell EEE in Belgium.
5. Set up quarterly BeWeee reporting for EEE placed on the Belgian market, with annual WEEE reporting by the applicable regional deadline.
6. Add the "Recupel contribution included" statement to all invoices and commercial communications where EEE prices appear.
7. Implement 1:1 take-back arrangements for equivalent old devices when new ones are sold to Belgian consumers.
8. Ensure all EEE products carry the crossed-out wheeled bin symbol and comply with RoHS hazardous substance restrictions.

FAQ

Is EEE EPR mandatory in Belgium?

• Yes. Belgium's WEEE legislation has been in force for over 20 years. All producers placing EEE on the Belgian market must affiliate with Recupel — the sole authorised PRO for all three Belgian regions — receive a member code, report placed-on-market quantities through BeWeee, and comply with take-back and recycling obligations. There is no de minimis threshold — even small volumes trigger the obligation.

Do foreign brands selling online into Belgium need to register?

• Yes. Foreign distance sellers are treated as producers and must affiliate with Recupel before selling EEE to Belgian consumers. From 29 March 2025, online marketplaces are required to verify seller compliance and refuse access to non-compliant sellers. Non-compliant sellers have their EEE assortments deactivated on platforms such as Zalando. Foreign companies must appoint an authorised representative with a Belgian establishment before affiliating with Recupel.

What is the member code and where must it be provided?

• The member code is the EEE EPR registration number issued by Recupel upon affiliation. It serves as proof of compliance and must be provided to online marketplaces — Zalando requires it to verify WEEE compliance for Belgian market sales. It is also used for BeWeee reporting submissions.

What is the "Recupel contribution included" requirement?

• All invoices and commercial communications where the price of an EEE appliance actually purchased by a Belgian consumer is mentioned must include the statement "Recupel contribution included". This confirms that the Recupel EPR contribution has been paid and is included in the product price. Online marketplace operators must inform their sellers of this obligation.

Does Belgium require separate regional registrations for Flanders, Wallonia, and Brussels-Capital?

• No. Recupel operates across all three Belgian regions under a single affiliation. One Recupel membership and one member code covers all three regions. However, reporting deadlines differ by region: 31 May for Brussels-Capital and Wallonia, and 1 July for Flanders.

What is Belgium EPR Batteries

Belgium's battery EPR framework is governed by Regulation (EU) 2023/1542 — the EU Battery Regulation — which applies directly in all EU Member States without requiring national transposition. The Regulation entered into force on 18 August 2023, has applied in stages since 18 February 2024, and its EPR and waste management obligations became fully applicable from 18 August 2025. At national level, the Regulation is supplemented by federal and regional legislation in Belgium. Due to Belgium's constitutional structure, environmental policy is a regional competence divided between Flanders, Wallonia, and Brussels-Capital. Registration obligations are fulfilled with the three regional governments — not a single federal authority. Belgium's established PRO, Bebat (Bebat vzw/asbl), manages battery collection and recycling across all three regions on behalf of its participants and registers them automatically with the regional administrations. The EU Battery Regulation replaced the previous Batteries Directive 2006/66/EC in full from 18 August 2025. It covers all battery types regardless of chemistry or form, whether sold separately or incorporated into products or vehicles.

Does This Apply to E-Commerce & Online Sales

Yes. The EU Battery Regulation explicitly captures distance sellers and e-commerce operators as producers. A foreign brand selling batteries or battery-containing products directly to Belgian consumers via an online store — with no physical establishment in Belgium — is treated as a producer and must comply with Belgian battery EPR obligations. From August 2025, online marketplace operators in Belgium are required to ensure that sellers on their platforms can demonstrate compliance with battery EPR. Marketplace administrators must only admit producers who are Bebat participants or who have an approved individual producer responsibility plan. If a producer cannot demonstrate compliance, the marketplace must deny them access. Annually, by 1 March, marketplace operators must provide the regional governments with an overview of all producers active on their platform during the previous year. Producers using marketplaces for sales in Belgium must comply with all EPR obligations directly — marketplace participation does not transfer the producer obligation to the platform.

Who is the "Producer" under Belgium EPR?

Under Regulation (EU) 2023/1542 and Belgian regional legislation, a producer is any company that makes batteries available on the Belgian market for sale, rental, lease, or use — whether or not for payment. This covers:

1. A producer or importer established in Belgium that manufactures batteries, has them manufactured, or purchases them from abroad and makes them available on the Belgian market for the first time.
2. A producer or importer established outside Belgium that makes batteries directly available to professional or private end users on the Belgian market through distance selling, including online sales.
3. Private label owners whose brand name appears on batteries manufactured by third parties.
4. Economic operators who prepare batteries for re-use or repurposing — treated as producers for the second life of the battery.

An important change took effect from August 2025: Belgian professional end users who previously had to register as producers when importing batteries for their own use no longer bear that obligation. The registration responsibility has shifted to the non-Belgian seller supplying those batteries.

Who Must Register for EPR Batteries in Belgium

All producers placing batteries on the Belgian market must register with the three regional governments — Flanders, Wallonia, and Brussels-Capital. The most practical route is to join Bebat, which handles registration with all three regional authorities on behalf of its participants automatically. Producers may alternatively submit their own application for registration and approval directly to the regional authorities and take on all EPR obligations individually, but this is significantly more complex than joining Bebat. The battery register — a new requirement under the EU Battery Regulation — is being developed by Bebat in collaboration with the three regional authorities. It will be accessible on the websites of all three regional administrations. Bebat participants are automatically included in the battery register as long as they continue fulfilling their obligations.

Belgium EPR Battery Registration Threshold

Regulation (EU) 2023/1542 does not establish a minimum volume or turnover threshold below which producers are exempt from EPR obligations. All producers placing batteries on the Belgian market must register and comply, regardless of size or volume. The only exemption in the Regulation concerns batteries used in military or space equipment, which are outside the scope entirely. For due diligence obligations, companies with annual net turnover below €150 million (as adopted under the Omnibus IV package, July 2025) may be exempt — but this does not affect EPR registration and reporting obligations.

Batteries Covered (and Excluded)

Regulation (EU) 2023/1542 defines five battery categories, all within scope for EPR in Belgium. From 1 January 2026, Bebat introduced new codes aligned to these five categories, replacing the previous three-category structure (portable, industrial, automotive): Portable batteries Batteries under 5 kg not designed for industrial or vehicle use. Includes batteries in consumer electronics, power tools, household devices, and toys. The most commonly encountered category for e-commerce sellers. Light Means of Transport (LMT) batteries Batteries used in e-bikes, e-scooters, e-mopeds, and similar light electric vehicles. Automotive (SLI) batteries Starting, lighting, and ignition batteries used in vehicles. Industrial batteries Batteries used in industrial applications and stationary energy storage systems. Those above 2 kWh have additional requirements including battery passports from 2027. Electric vehicle (EV) batteries Batteries used in electric cars and heavy electric vehicles. Subject to carbon footprint declarations, battery passports from 2027, and detailed collection obligations. Key exclusions:

• Batteries designed for military or space equipment — outside scope entirely
• Batteries in nuclear installations — excluded
• Second-life batteries where the operator performing re-use or repurposing becomes the new producer

Producer Responsibility Organization (PRO)

Belgium's established PRO for batteries is Bebat (vzw/asbl), set up by the battery industry and operating across all three regions. Bebat has been collecting and recycling batteries in Belgium for over 30 years and manages a nationwide collection network with ADR-compliant transport. Bebat offers two compliance routes:

• Environmental contribution (collective system): Producers pay an upfront contribution covering full EPR obligations. Bebat handles collection, recycling, reporting, and registration with regional authorities.
• Administrative contribution (individual customised system): For producers with specific requirements or who wish to manage certain obligations separately.

For large lithium-ion batteries, Bebat participates in Reneos, the European network providing services for end-of-life management of large lithium-ion batteries across the EU. Bebat participants are automatically registered in the producer register with the three regional governments. Producers who join Bebat receive access to the MyBebat portal for declarations and reporting.

EPR Registration in Belgium

The registration process for battery producers in Belgium is as follows:

1. Determine whether your business qualifies as a producer under the EU Battery Regulation — i.e. whether you are placing batteries on the Belgian market for the first time.
2. If established outside Belgium, appoint an authorized representative established in Belgium before registering.
3. Join Bebat by registering through the Bebat website (bebat.be) and signing the participation agreement. Bebat registers participants automatically with all three regional governments.
4. Alternatively, submit a direct registration application to the three regional authorities (Flanders, Wallonia, Brussels-Capital) independently and establish your own approved collection system.
5. Declare the batteries you make available on the Belgian market for the first time through the MyBebat portal, using the Bebat codes aligned to the five EU Battery Regulation categories (applicable from 1 January 2026).
6. Pay the applicable environmental contribution to Bebat, based on battery category and volume.
7. Provide proof of Bebat participation or individual producer responsibility approval to marketplaces operating in Belgium.

Authorized Representative

Under Regulation (EU) 2023/1542 and Belgian legislation, producers or importers established outside Belgium are required to appoint a local authorized representative — a natural or legal person established in Belgium — to fulfill their EPR obligations under Chapter VIII of the Regulation. The authorized representative is responsible for registering with regional authorities, joining Bebat or an alternative approved system, submitting declarations, and serving as the point of contact for Belgian authorities. The representative must be appointed in writing. Bebat provides the necessary documents for appointing an authorized representative and is developing a formal arrangement for this in connection with its updated participation agreement. Foreign producers joining Bebat can arrange authorized representative services through Bebat or through accredited compliance service providers. Important development: In December 2025, the European Commission proposed suspending the authorized representative requirement for EU-established companies until 2035. This proposal has not been formally adopted as of April 2026. For non-EU producers, the requirement is not affected and continues to apply.

What Data Must Be Reported

Producers registered in Belgium must declare and report the following data through the MyBebat portal or directly to the regional authorities:

• Total weight (kilograms) of batteries placed on the Belgian market, broken down by the five battery categories (portable, LMT, SLI/automotive, industrial, EV) — applicable from 1 January 2026 under the new Bebat code structure
• Battery chemistry type where relevant to the contribution calculation
• Brand names under which batteries were placed on the market
• Collection and recycling performance data, as required by regional legislation and reported by Bebat on behalf of participants
• For EV and LMT batteries: number of batteries made available and amounts of waste batteries collected and delivered to treatment facilities

First Reporting Period & EPR Reporting Deadlines

Battery EPR has been in place in Belgium for many years under the former Batteries Directive. The new EU Battery Regulation obligations took full effect from 18 August 2025. Key dates:

• 18 February 2024: EU Battery Regulation begins applying. CE marking and substance restrictions in force.
• 18 August 2025: EPR registration, waste management, and labelling obligations fully in force.
• 1 January 2026: New five-category Bebat code structure introduced, replacing the previous three-category structure (portable, industrial, automotive).
• 1 March (annual): Marketplace administrators must provide regional governments with an overview of all producers active on their platforms during the previous year.
• 18 February 2027: Battery passports mandatory for industrial batteries (>2 kWh) and EV batteries. Portable batteries must be removable and replaceable by end users.
• 18 August 2027: Due diligence obligations in force (delayed from 2025 under Omnibus IV).

Annual declaration deadlines for volumes placed on the market are set through the MyBebat portal. Producers should confirm submission schedules with Bebat at the time of registration.

Labels & Marketing Claims

Crossed-out wheeled bin symbol From 18 August 2025, all batteries must display the separate collection symbol. The symbol must cover at least 3% of the area of the largest side of the battery, up to a maximum of 5 × 5 cm. Chemical symbols Batteries containing more than 0.002% cadmium must be marked Cd. Batteries containing more than 0.004% lead must be marked Pb. Capacity marking Portable and rechargeable batteries must display capacity information. QR code From 18 August 2026, all batteries must carry a QR code linking to product information. For LMT, industrial (>2 kWh), and EV batteries, the QR code links to the Digital Battery Passport from 18 February 2027. CE marking Mandatory for all batteries from 18 August 2024. Environmental claims All environmental and sustainability claims must comply with the Unfair Commercial Practices Directive and Belgian consumer protection law. The Empowering Consumers for the Green Transition Directive (2024/825/EU) must be transposed by March 2026, after which unsubstantiated green claims will be prohibited across the EU including Belgium. Labels must comply in the regional language — Dutch in Flanders, French in Wallonia, and both in Brussels-Capital — where language requirements apply to consumer-facing information.

EPR Eco Fees & Eco-Modulation

Bebat's contribution structure is based on:

• Battery category — the five EU Battery Regulation categories each have distinct contribution rates
• Weight (kilograms) of batteries placed on the market
• Chemistry type — different chemistries carry different recycling costs and contribution levels

Bebat operates both an environmental contribution (collective system covering full EPR obligations) and an administrative contribution (for producers managing certain obligations individually). Under Regulation (EU) 2023/1542, financial contributions must cover the costs of separate collection, transport, and treatment of waste batteries. Eco-modulation — adjusting contributions based on battery environmental performance (durability, recyclability, recycled content) — is required by the Regulation and will be implemented by Bebat as the Belgian framework matures. Specific eco-modulation criteria for Belgium have not been published as of April 2026.

Risks, Penalties & Common Mistakes

1. Selling in Belgium without Bebat participation or individual approval. Marketplaces are required to bar producers who cannot demonstrate EPR compliance. Non-compliant producers face loss of access to Belgian online marketplaces and direct enforcement by regional authorities.
2. Failing to appoint an authorized representative. Non-EU and non-Belgian producers must appoint a Belgian-established representative before registering. Without one, registration cannot be completed.
3. Assuming one EU registration covers Belgium. Battery EPR registration is national. Registration in another EU member state does not fulfil Belgian obligations. Belgium's three-region structure means registration must be managed across Flanders, Wallonia, and Brussels-Capital.
4. Missing the 1 March marketplace reporting deadline. Marketplace operators must report all producers active on their platform to regional authorities by 1 March annually. Sellers must ensure their compliance status is current before this deadline.
5. Using outdated Bebat codes after 1 January 2026. The previous three-category structure (portable, industrial, automotive) was replaced by the five-category EU Battery Regulation structure from 1 January 2026. Reporting under old codes after this date is incorrect.
6. Missing labelling requirements. The crossed-out wheeled bin symbol and CE marking are mandatory from August 2025. Non-compliant products are subject to market surveillance action.
7. Missing the QR code deadline of August 2026. Companies should begin QR code implementation well in advance.

What E-Commerce Sellers Should Do Now

1. Confirm whether your products contain batteries — including batteries incorporated into devices — and whether they are being sold to Belgian consumers.
2. If established outside Belgium, identify and appoint an authorized representative established in Belgium.
3. Join Bebat (bebat.be) and sign the participation agreement. Bebat will register you with all three regional governments and provide access to the MyBebat portal.
4. Declare battery volumes by category through the MyBebat portal using the five-category code structure (applicable from 1 January 2026).
5. Provide proof of Bebat participation to all marketplaces operating in Belgium where you sell battery-containing products.
6. Verify that all batteries carry the crossed-out wheeled bin symbol, CE marking, and capacity information as required from August 2025.
7. Plan for the QR code requirement by August 2026 and the Digital Battery Passport for industrial and EV batteries by February 2027.
8. Track the annual 1 March marketplace reporting deadline and ensure your Bebat participation status is current.

FAQ

Is battery EPR mandatory in Belgium?

• Yes. Battery EPR has been mandatory in Belgium for many years under the former Batteries Directive. From 18 August 2025, the new EU Battery Regulation (2023/1542) fully replaced the Directive. All producers placing batteries on the Belgian market must register with the three regional governments — most practically through Bebat — declare volumes, and comply with collection and recycling obligations.

Do foreign brands selling online into Belgium need to register?

• Yes. Distance sellers and e-commerce operators selling batteries or battery-containing products to Belgian consumers are explicitly captured as producers under the EU Battery Regulation. Non-Belgian companies must appoint an authorized representative established in Belgium before registering. Online marketplaces operating in Belgium are required to verify compliance and can bar non-compliant sellers.

Is there a minimum volume threshold below which registration is not required?

• No. The EU Battery Regulation does not establish a minimum volume or turnover exemption for EPR registration. All producers placing batteries on the Belgian market must register and comply regardless of size.

What changed in Belgium from August 2025 regarding professional end users?

• Until August 2025, Belgian professional end users who imported batteries for their own use had to register as producers themselves. From August 2025, this obligation has shifted to the non-Belgian seller supplying those batteries. Foreign sellers who previously relied on Belgian business customers to handle registration must now register directly in Belgium.

Do I need to register separately with Flanders, Wallonia, and Brussels-Capital?

• In practice, no — if you join Bebat. Bebat registers its participants automatically with all three regional governments. If you choose to comply individually without Bebat, you must submit separate registration applications to each of the three regional authorities.