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Packaging obligations in Belgium (2026)

Draft

Verified on: 2026-09-01

EU framework: PPWR (EU) 2025/40, applicable since 12 Aug 2026

National: Interregional Cooperation Agreement of 4 Nov 2008 on the prevention and management of packaging waste (last amended by the agreement of 5 Mar 2020); enforced by the Interregional Packaging Commission (IVC/CIE), which operates as the Interregional Commission for EPR (EPRiBEL); a revision of the cooperation agreement to align it with the PPWR is under way

Belgium separates household packaging (scheme: Fost Plus) and industrial/commercial packaging (scheme: Valipac). Since 12 Aug 2026, the PPWR producer concept has replaced the Belgian concept of the packaging-responsible party; the most important consequence for trade: for industrial/commercial packaging, responsibility shifts from the Belgian unpacker (former category C) to the – possibly foreign – supplier. The national 300 kg de-minimis threshold for the take-back obligation remains in the cooperation agreement, but the PPWR register obligation has no de-minimis threshold (simplified reporting below 10,000 kg/year under Art. 44(6) PPWR). Not covered in this pack: prevention plans every 3 years (from 300 t of single-use packaging placed on the market, or 100 t filled/packed in Belgium) and the planned deposit scheme for beverage packaging.

Packaging EPR for household packaging (Belgium)

Anyone first making packaged goods available on the Belgian market – including foreign online sellers selling directly to Belgian end customers – has counted as a producer under the PPWR since 12 Aug 2026. For household packaging (including shipping packaging in online retail) that means: joining the approved scheme Fost Plus (or self-fulfilment with evidence provided to EPRiBEL), annual volume reporting, payment of the Green Dot fees and an entry in the national producer register.

Authorised representative: 
Since 12 Aug 2026, producers without an establishment in Belgium that first make packaging available there directly to end consumers (distance selling) must appoint an authorised representative for EPR under Art. 45 PPWR; according to Fost Plus, this representative must be established in Belgium and registered with EPRiBEL. Anyone with a Belgian establishment, or whose goods pass through a Belgian importer, does not need their own authorised representative for those products.
Cross-border: 
Foreign distance sellers selling directly to Belgian end customers are themselves the producer and thus subject to registration and contributions – without registration, no packaging may be made available on the Belgian market. Under Art. 45(4) PPWR, online platforms must obtain from third-party sellers proof of registration in the producer register and a self-certification of EPR compliance; for pure platform sellers, Fost Plus says a written mandate to the platform is possible, but the details depend on the still-pending revision of the cooperation agreement.
Costs: 
Green Dot tariff per material (public at Fost Plus, eco-modulated); minimum annual contribution €100 (€50 with direct debit). For the producer register, Fost Plus has announced possible annual registration fees from 2027; registration of members via Fost Plus itself is free.
Deadlines: 
Volume declaration annually by 28 Feb for the previous year (if late: 1% surcharge per month on the previous year's contribution). PPWR obligations (producer concept, authorised representative, register obligation) have applied since 12 Aug 2026; join/register before first placing goods on the market.

Typical steps

  1. Determine which of your packaging ends up as waste in Belgian private households (product, secondary and shipping packaging).
  2. Join Fost Plus online (contract via fostplus.be) – or alternatively declare self-fulfilment with recycling evidence directly to EPRiBEL.
  3. Ensure registration in the national producer register: Fost Plus handles it collectively and free of charge for members; non-members register directly with EPRiBEL.
  4. Without an establishment in Belgium: appoint an authorised representative for EPR (established in Belgium, registered with EPRiBEL).
  5. Submit the annual volume declaration by material via the MyFost portal by 28 Feb for the previous year and pay the Green Dot fees.
  6. Note the 2026 transition year: separate declarations for volumes up to 11 Aug 2026 (old legal regime) and from 12 Aug 2026 (producer concept).
  7. Document your registration number and store it with the marketplaces you use.

Providers for this obligation

Fost Plus

Sources: IVC/CIE (EPRiBEL) – PPWR: Änderungen für verantwortliche Unternehmen ab 12.08.2026 (Produzentenbegriff, Registerpflicht, Übergangsmeldungen 2026) (accessed 2026-09-01) · Fost Plus – PPWR Insights 8: Pflichtregistrierung im Produzentenregister (kollektive Registrierung, Bevollmächtigter für ausländische Produzenten, Gebühren ab 2027) (accessed 2026-09-01) · Fost Plus – Mitglied werden (Zielgruppen, Online-Beitritt, Mindestbeitrag 100 €/50 €) (accessed 2026-09-01) · Fost Plus – Deklaration (Frist 28.02., Verspätungszuschlag 1 %/Monat) (accessed 2026-09-01) · IVC/CIE – Rücknahmepflicht (300-kg-Schwelle, Recyclingziele, Systeme Fost Plus/Valipac) (accessed 2026-09-01) · Fost Plus – Präsentation PPWR: What will change for you? (11/2025; Produzentendefinition, Register, Plattformen, vereinfachte Meldung < 10.000 kg) (accessed 2026-09-01)

Packaging EPR for industrial and commercial packaging (Belgium)

For packaging that ends up with Belgian business customers (transport, secondary and B2B sales packaging), the rule since 12 Aug 2026 is: the – possibly foreign – supplier is the producer and must fulfil the EPR obligations; previously, responsibility mostly lay with the Belgian unpacker (category C). Fulfilment via Valipac, the only approved scheme (or self-fulfilment towards EPRiBEL), including the register entry and annual volume reporting.

Authorised representative: 
Art. 45 PPWR makes the authorised representative mandatory only for distance selling directly to end users; for B2B deliveries into Belgium, Member States may provide for an authorised representative for EPR fulfilment. EPRiBEL calls on foreign suppliers to join an approved Belgian scheme (for commercial packaging: Valipac); the exact authorised-representative mechanics for pure B2B cases depend on the ongoing revision of the cooperation agreement – clarify with Valipac or EPRiBEL.
Cross-border: 
This is the biggest Belgian change brought by the PPWR: Belgian business customers (former category C) are generally no longer themselves responsible for the industrial/commercial packaging of foreign suppliers, but they may no longer source 'illegal' (unregistered) packaging. EPRiBEL expressly advises them to demand Valipac membership or proof of registration from foreign suppliers – without registration, delivery stops by Belgian customers loom.
Costs: 
Valipac contributions 2026 per tonne: €20 (recyclable, non-plastic), €63 (recyclable plastic), €126 (non-recyclable), €0 (reusable); minimum contribution €50, flat-rate retroactive contribution of €250 for late joining.
Deadlines: 
Obligations under the new producer concept have applied since 12 Aug 2026; EPRiBEL advised settling scheme membership before that date. Annual declaration to Valipac at the start of the following year (confirm the exact deadline with Valipac).

Typical steps

  1. Determine which of your packaging ends up with Belgian business customers (transport, secondary and B2B sales packaging, pallets, films).
  2. Request Valipac membership (customer@valipac.be) – Valipac is currently the only approved scheme for industrial/commercial packaging.
  3. Ensure registration in the national producer register (via the scheme or directly with EPRiBEL).
  4. Submit the annual volume declaration by material and recyclability and pay the contributions.
  5. Note the 2026 transition year: volumes up to 11 Aug 2026 are still reported by the previously responsible party, from 12 Aug 2026 by the producer under the PPWR.
  6. Proactively provide Belgian B2B customers with your registration/scheme evidence.

Providers for this obligation

Valipac

Sources: IVC/CIE (EPRiBEL) – PPWR ab 12.08.2026: Verantwortungsübergang bei Industrie-/Gewerbeverpackungen auf (ausländische) Lieferanten, Empfehlung Valipac-Beitritt (accessed 2026-09-01) · Valipac – Noch kein Kunde? (Beitritt, Tarife 2026, Mindestbeitrag 50 €, Rückwirkungspauschale 250 €) (accessed 2026-09-01) · IVC/CIE – Rücknahmepflicht (Valipac als zugelassenes System für Industrie-/Gewerbeverpackungen) (accessed 2026-09-01) · Fost Plus – Präsentation PPWR (Produzentenbegriff, Register of producers via Fost Plus/Valipac) (accessed 2026-09-01)

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Legal information, not legal advice. The linked official sources prevail; data marked “draft” has not been finally verified.