Belgium EPR Explained: Fost Plus, Valipac, and WEEE BE for Marketplace Sellers

By Operator One Editorial — 2026-06-14

Key takeaways

• Regulation (EU) 2025/40 (PPWR) applies from 12 August 2026, and Fost Plus states that from that date a producer not established in Belgium must be represented by an authorised representative that is established in Belgium and registered with EPRiBEL.
• Belgium splits packaging EPR by waste stream: Fost Plus covers household packaging and Valipac covers commercial and industrial packaging, and a company with both types needs membership of both.
• The Fost Plus annual declaration is due 28 February for packaging placed on the Belgian market in the previous year, and Fost Plus warns that a late filing risks a fine of 1% of the previous declaration's contribution per month of delay.
• Fost Plus 2026 rates run from EUR 0.1052 per kg for glass and EUR 0.1503 per kg for paper-cardboard to EUR 2.2095 per kg for PP and other plastic films and EUR 4.4190 per kg for obstructive packaging, with a minimum annual contribution of EUR 100 (EUR 250 for obstructive or household hazardous waste packaging).
• Recupel members in Belgium declare electrical and electronic equipment quarterly or monthly, and Bebat charges a EUR 60 annual flat fee with annual battery declarations below 10,000 batteries a year and monthly declarations above that.
• Belgium's cooperation agreement of 4 November 2008 provides administrative fines of EUR 500 per tonne not recovered and EUR 1,000 per tonne not recycled, capped at EUR 25,000, and criminal fines of EUR 1,000 to EUR 2,000,000 with one to twelve months' imprisonment.

Belgium is one of the more procedurally demanding EPR jurisdictions in the EU. The schemes are not harder than France's or Germany's, but Belgium runs a genuine dual-track system for packaging, produces most official documents in Dutch or French, and from 12 August 2026 layers the EU Packaging and Packaging Waste Regulation (PPWR) on top of its own interregional rules. This piece walks through what marketplace sellers need to register in Belgium, who verifies what, and what changed in 2026.

Two packaging schemes, one country, one decision

Belgium splits packaging EPR by waste stream, not by product type. The same SKU can fall under either scheme depending on where the packaging is discarded.

• Fost Plus handles household packaging in Belgium: packaging that ends up in a consumer's PMD bag, paper bin or glass container. This is the scheme that applies to almost every B2C marketplace sale into Belgium.
• Valipac handles commercial and industrial packaging in Belgium: pallets, stretch film, large outer cartons and other packaging discarded at business premises.

For a brand selling to Belgian consumers via Bol.com or Amazon.be, Fost Plus is the relevant packaging scheme. Valipac becomes relevant when the same business also ships pallets or B2B volumes into Belgium. According to Valipac, companies with both household and industrial packaging need membership of both organisations. The two schemes run separate contracts, separate tariffs and separate declarations, and both declarations are due by 28 February each year. There is no single Belgian packaging registration that covers both streams.

The public authority above both schemes is the Interregional Packaging Commission (IVC/CIE), set up jointly by the Flemish, Walloon and Brussels-Capital regions under the cooperation agreement of 4 November 2008 on the prevention and management of packaging waste. It is becoming the Interregional Commission for EPR, EPRiBEL, and its website moves from ivcie.be to epribel.be. Under that agreement, companies placing more than 300 kg of packaging on the Belgian market per year carry a take-back obligation, which they can discharge by joining an accredited organisation such as Fost Plus or Valipac.

Fost Plus 2026 rates (EUR per kg, excluding VAT)

Material (Fost Plus 2026)	Rate EUR/kg
Glass	0.1052
Paper-cardboard	0.1503
Steel (at least 50%)	0.1864
Aluminium, 50 micrometres or thicker	0.0491
PET bottles, transparent colourless	0.3604
PE films	1.0804
PP films and other plastic films	2.2095
Household hazardous waste packaging	1.3784
Obstructive packaging	4.4190

Fost Plus sets a minimum annual contribution of EUR 100, rising to EUR 250 for companies placing obstructive packaging or household hazardous waste packaging on the Belgian market. Its 2026 rate sheet also adds new PPWR packaging categories from 12 August 2026, such as beverage capsules (EUR 3.5525 per kg for aluminium, EUR 3.8414 per kg for plastic).

What changed on 12 August 2026: PPWR in Belgium

Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation, applies from 12 August 2026 under its Article 71 and is directly applicable in Belgium. Four points matter most for marketplace sellers:

• Producer registration. PPWR Article 44(2) requires producers to register in the national producer register of each member state where they first make packaging or packaged products available, and Article 44(4) bars them from doing so if they, or their authorised representative, are not registered there. Fost Plus states that it registers its members collectively at no extra cost, with register fees charged only from 2027.
• Authorised representative. PPWR Article 45(3) requires producers that sell directly into a member state where they are not established to appoint an authorised representative for EPR by written mandate. Fost Plus states that for Belgium this representative must be established in Belgium and registered with EPRiBEL. An EU entity established elsewhere does not meet that requirement.
• Who is the producer. The IVC/CIE explains that the Belgian term "packaging responsible company" is replaced by the PPWR term "producer". Importers that unpack goods in Belgium (former type C) will in most cases no longer be producers, because their foreign supplier becomes the producer. Importers that sell packaged goods on without unpacking them (type B) mostly remain producers.
• Split 2026 declaration. The IVC/CIE states that for 2026 both the former responsible company and the new producer declare: the former up to 11 August 2026 and the new producer from 12 August 2026.

Separately, PPWR Article 45(4) requires online platforms that let consumers conclude distance contracts with producers to obtain EPR information from those producers, which reinforces the marketplace checks described below.

WEEE and batteries in Belgium: Recupel and Bebat

For electrical and electronic equipment (EEE), Recupel is the producer responsibility organisation that manufacturers and importers join in Belgium. Recupel members declare appliances placed on the Belgian market by category, quarterly by default or monthly if they prefer. Recupel states that a seller with its registered office outside Belgium that serves Belgian customers online must still register as a Recupel member or submit an individual waste management plan, must appoint an authorised representative in Belgium, and that Recupel can act as that representative free of charge.

Batteries, including cells built into devices, fall under Regulation (EU) 2023/1542, supplemented by Belgian federal and regional law, and producers join Bebat. Bebat charges an annual flat-rate contribution of EUR 60 plus a contribution per battery depending on battery type. Bebat participants placing fewer than 10,000 batteries a year on the Belgian market may declare once a year, by 28 February of the following year; above 10,000 batteries a year, declarations are monthly, due by the last calendar day of the following month.

Because packaging EPR is charged by material weight while Recupel and Bebat declarations are made by product category and battery type, an electronics seller in Belgium typically runs three different declaration mechanics at the same time.

Marketplace verification on Bol.com and Amazon.be

Marketplaces operating in Belgium now have their own legal duties to check seller EPR compliance.

• EEE from 29 March 2025. Recupel states that since 29 March 2025 online marketplace operators in Belgium must inform sellers in writing of their EPR obligations and verify compliance, for example Recupel membership. For non-compliant sellers they must either refuse access or take on those sellers' EPR obligations themselves.
• Bol.com. Bol's partner platform states that in Belgium the EPR obligation applies to all regulated categories, that sellers must join an accredited producer responsibility organisation, and that bol refuses selling rights to partners who fall under an EPR scheme and do not contribute, taking the relevant range offline.
• Amazon.be. Amazon asks sellers subject to Belgian EPR to submit their registration numbers in Seller Central. Check the current Amazon.be EPR help page for the exact categories and enforcement steps, because Amazon changes these pages frequently.

The point that catches sellers out: a French Citeo UIN does not satisfy Belgium, a German LUCID registration does not satisfy Belgium, and Fost Plus membership does not satisfy France. EPR registration is per country and per stream, and it does not transfer between legal entities.

Registering as a non-EU brand

For packaging, a producer not established in Belgium needs an authorised representative that is established in Belgium and registered with EPRiBEL from 12 August 2026 (PPWR Article 45(3), as applied by Fost Plus). For EEE, Recupel requires online sellers based outside Belgium to register as members and appoint a Belgian authorised representative, a role Recupel offers to fill free of charge. The representative acts under a written mandate and handles the membership, declarations and register entries on the producer's behalf.

The practical sequence for a non-EU brand is set out step by step below. A key point first: decide who the legal seller and importer into Belgium is before signing anything, because that entity is the producer, and every registration must be in its name.

The bilingual document reality

Belgium's schemes work in Dutch and French. Fost Plus, Recupel and Bebat also publish English-language member pages. In Operator One's experience, invoices, contracts and authority correspondence are mostly in Dutch or French, and a non-EU brand without Dutch- or French-speaking finance staff needs two things in place:

• A translation workflow for declaration and audit correspondence. Machine translation is fine for triage, but replies to Fost Plus, Valipac or EPRiBEL queries should be prepared carefully in the original language.
• A clear rule on which entity signs which document, so the producer of record, its authorised representative and the marketplace account all use the same legal name and registration numbers.

In Operator One's experience, it also pays to reconcile Belgian VAT data, marketplace sales data and declared EPR volumes against each other before filing, so that discrepancies surface internally rather than in an EPRiBEL or tax authority query.

Practical sequencing for a marketplace launch

In Operator One's experience, brands planning a Bol.com and Amazon.be launch in the same quarter should start Fost Plus and Recupel (and Bebat for battery products) roughly eight to twelve weeks before go-live. Add Valipac only if B2B shipments to Belgium are in scope, and treat the marketplace EPR check as the last checkpoint rather than the first. Under PPWR, Fost Plus issues the official register number to members through the MyFost portal once the authorities confirm registration, so allow time for that step. Existing Fost Plus members can amend their 2025 declarations until 15 September 2026.

See the compliance glossary for the scheme acronyms used above, and marketplaces for platform-by-platform information.

How to register for Belgian EPR, step by step

1. Map products to Belgian streams. Split packaging into household (Fost Plus) and commercial or industrial (Valipac), list EEE categories for Recupel and battery types for Bebat.
2. Identify the producer. Determine which legal entity first makes the goods available in Belgium under PPWR from 12 August 2026: the brand selling directly from abroad, or an importer and legal seller.
3. Appoint a Belgian authorised representative if needed. A producer not established in Belgium needs a representative established in Belgium and registered with EPRiBEL for packaging; Recupel can act as representative for EEE free of charge.
4. Join the schemes. Sign membership with Fost Plus, Valipac, Recupel and Bebat as applicable; Fost Plus registers members in the national producer register.
5. Load numbers into marketplaces. Enter the Belgian registration numbers in Bol.com and Amazon.be seller accounts before listing products for Belgian buyers.
6. File declarations on schedule. Fost Plus, Valipac and annual Bebat declarations by 28 February; Recupel quarterly or monthly; Bebat monthly above 10,000 batteries a year.

Frequently asked questions

Do I need both Fost Plus and Valipac to sell in Belgium?

Only if you place both types of packaging on the Belgian market. Belgium splits packaging EPR by waste stream: Fost Plus covers household packaging and Valipac covers commercial and industrial packaging such as pallets and stretch film. Valipac states that companies with both household and industrial packaging need membership of both. They are separate contracts with separate tariffs and declarations, so a pure B2C marketplace seller usually needs Fost Plus only.

What is the Fost Plus declaration deadline and what happens if I miss it?

The Fost Plus annual declaration in Belgium is always due 28 February, covering packaging placed on the Belgian market in the previous calendar year, and it is filed through the MyFost portal. Fost Plus states that missing the deadline risks a fine of 1% of the contribution from your previous declaration for each month of delay. For 2025 declarations, Fost Plus allows amendments until 15 September 2026.

Is there still a 300 kg packaging threshold in Belgium?

Belgium's cooperation agreement of 4 November 2008 applies the take-back obligation to companies placing more than 300 kg of packaging on the Belgian market per year. However, Regulation (EU) 2025/40 (PPWR) Article 44, applicable from 12 August 2026, requires producers to register in each member state where they first make packaging available and sets no weight threshold for that registration. Treat registration as required from the first unit.

Can a non-EU brand register with Fost Plus or Recupel directly?

Not on its own for packaging. Under Regulation (EU) 2025/40 (PPWR) Article 45(3), from 12 August 2026 a producer selling into Belgium without being established there must appoint an authorised representative, and Fost Plus states that representative must be established in Belgium and registered with EPRiBEL. For electrical equipment, Recupel requires online sellers based outside Belgium to register and appoint a Belgian representative, and offers to act as that representative free of charge.

What are the Fost Plus packaging rates for 2026?

Fost Plus publishes 2026 rates in EUR per kilogram, excluding VAT, for household packaging placed on the Belgian market: glass 0.1052, paper-cardboard 0.1503, steel 0.1864, transparent colourless PET bottles 0.3604, PE films 1.0804, PP and other plastic films 2.2095, and obstructive packaging 4.4190. The minimum annual Fost Plus contribution is EUR 100, or EUR 250 for obstructive or household hazardous waste packaging.

Do I need Recupel and Bebat if my product has a built-in battery?

Usually yes in Belgium. The appliance is electrical and electronic equipment declared through Recupel, quarterly by default or monthly by choice, while the battery falls under Regulation (EU) 2023/1542 and is declared through Bebat. Bebat charges a EUR 60 annual flat-rate contribution plus a per-battery contribution, allows one annual declaration below 10,000 batteries a year and requires monthly declarations above that.

What happens if I sell into Belgium with no EPR registration?

Under Belgium's cooperation agreement of 4 November 2008, administrative fines are EUR 500 per tonne of packaging waste not recovered and EUR 1,000 per tonne not recycled, capped at EUR 25,000, and the most serious offences carry criminal fines of EUR 1,000 to EUR 2,000,000 and one to twelve months' imprisonment. PPWR Article 44(4) also bars unregistered producers from making packaging available, and Bol.com takes non-compliant ranges offline.

Who carries the Belgian EPR obligation when a Merchant of Record is the seller?

The producer is the entity that first makes goods available in Belgium. Where a Merchant of Record imports the goods and sells them as legal seller, it is typically the producer under PPWR and Belgian practice, so registrations with Fost Plus, Recupel or Bebat sit in its own name, because EPR registrations do not transfer between entities. If the brand ships to Belgian consumers from its own stock abroad, the brand is the producer and needs its own Belgian authorised representative.

Who declares Belgian packaging for 2026 after the PPWR change?

Both parties may have to. The Belgian Interregional Packaging Commission (IVC/CIE, becoming EPRiBEL) states that for 2026 the former packaging responsible company declares packaging placed on the market up to 11 August 2026, and the new PPWR producer declares from 12 August 2026 onward. Importers that unpack goods in Belgium are most affected, because their foreign supplier usually becomes the producer under Regulation (EU) 2025/40.

Where a Merchant of Record carries the obligation

When Operator One acts as Merchant of Record, it is the legal seller and, where it imports goods into the EU, the importer, so Belgian EPR obligations for the goods it places on the market attach to its own registrations. Belgian EPR registration is per country and per stream and does not transfer from the brand. Where a market requires a locally established authorised representative, Operator One commonly arranges one as part of onboarding, but not in every market. CE marking, conformity assessment, the technical file and the EU Declaration of Conformity stay with the manufacturer; as importer, Operator One verifies they exist, adds its name and address, and keeps the documentation available to authorities. Listings show the client as Brand and Operator One as seller. Scheme names and acronyms are explained in the compliance glossary.

Sources: Regulation (EU) 2025/40 (PPWR), EUR-Lex; Fost Plus, PPWR Insights 8; Fost Plus, Declaration; Fost Plus, Green Dot rates 2026; IVC/CIE, PPWR change from 12 August 2026; IVC/CIE, Take-back obligation; IVC/CIE, Sanctions; Recupel, Legal obligations; Bebat, Becoming a participant; Bebat, Monthly or annual declaration; Valipac, Explanatory note on the declaration; Valipac, FAQ on Fost Plus and Valipac; bol Partner Platform, EPR.