What is the new Extended Producer Responsibility (EPR) requirement in Belgium and what do I need to do?
Belgium is rolling out EPR requirements. In order to be compliant, partners selling in Belgium must follow the guidelines explained below.
Disclaimer
This information does not constitute legal or Extended Producer Responsibility (EPR) compliance advice from us. It’s your sole responsibility to ensure that your articles, packaging, offers and sales comply with all relevant laws, including EPR obligations. As a selling partner, you are required to understand and adhere to all applicable laws, standards, regulations and our applicable policies.
In March 2025, the Belgian government placed new EPR obligations on producers and online marketplaces for Waste Electrical and Electronic Equipment (WEEE).
As a Zalando partner, if you sell or plan to sell Electrical and Electronic Equipment (EEE) in Belgium, you must be EPR-registered for EEE. You can find the details for how to do this below. We are required to verify your compliance by collecting and checking your EPR details.
Impacted Electrical and Electronic Equipment (EEE) assortment
The EPR requirements cover waste generated by EEE including, but not limited to:
Temperature exchange equipment
Screens, monitors and equipment containing screens having a surface greater than 100 cm2
Lamps
Equipment with any external dimension more than 50 cm (large equipment)
Equipment with no external dimension more than 50 cm (small equipment)
Small IT and telecommunication equipment with no external dimension more than 50 cm
Please find an exhaustive and searchable list here.
Actions you need to take
To ensure your continued compliance and prevent any disruption to your business, please complete the following actions:
1. Register with a Producer Responsibility Organisation (PRO)
If you have not already done so, please register with Recupel, the local PRO for EEE in Belgium, immediately.
Important
If you don’t have a registered address in Belgium, you must first appoint an authorised representative. Recupel can act as such so we recommend reaching out to them directly for further information.
2. Prepare your EPR registration details
Ensure your registration details, including your EPR ID (referred to by Recupel as a "member code"), are ready for submission.
3. Submit your details in zDirect Once the technical solution is live in zDirect, you must submit your EPR EEE details for Belgium via your Business profile in the tool.
We’ll launch the feature to collect this information in zDirect later this year. Please prepare your data ahead of time so that you can act quickly once you’re able to submit your EPR EEE details for Belgium.
What happens if I don’t comply with these regulations?
Providing a valid EPR registration number will be mandatory once the collection feature is live. We are obliged to ensure all assortments on our platform meet local legislative requirements. In case of non-compliance, we reserve the right to deactivate your EEE assortment in Belgium until your EPR details are collected and verified.
Additional EPR product categories in Belgium
If you sell or plan to sell in Belgium, you must register for EPR for packaging. You can find further details about those requirements here:
If any of your assortment contains batteries, you must also register for EPR for batteries. You can find further details about those requirements here:
What is the EU Extended Producer Responsibility (EPR) battery regulation and what do I need to do?
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What is the EU Extended Producer Responsibility (EPR) Battery Regulation and what do I need to do?
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FAQs
What is Extended Producer Responsibility (EPR)?
EPR is a policy approach whereby producers take physical or financial responsibility for the end-of-life management of their products and their packaging. EPR is one of the most important pillars to ensure circularity in the EU.
Every company that puts certain products, including Electrical and Electronic Equipment (EEE) on a national market has to ensure its EPR compliance by participating in an EPR system — the so-called Producer Responsibility Organisations (PROs).
PROs manage the process of taking back products and ensuring their proper disposal. This involves setting up recycling infrastructure, which is funded by fees that the producers pay to the PROs, based on the quantity of products they introduce to the market.
In order to ensure that they are EPR compliant, companies therefore register with a PRO, report the quantity of products sold, and pay the respective fee to the PRO.
What is the EPR Electrical and Electronic Equipment (EEE) decree in Belgium?
EPR for Waste Electrical and Electronic Equipment (WEEE) has already been rolled out in many European countries, including Germany, France, and Austria, for several years. The Belgian government has now also placed EPR obligations on producers and online marketplaces for WEEE.
Partners selling EEE must register with the designated PRO in Belgium, Recupel, to ensure that you are compliant and can continue selling on Zalando.
The EPR obligations now also mean that Zalando must check that partners selling in Belgium are compliant by requesting the EPR registration number (“member code”) provided when you register with Recupel.
Who is considered a producer?
A producer is the company that first brings Electrical and Electronic Equipment (EEE) onto the Belgian market. Please note as well that a producer is not the equivalent of a manufacturer.
Regarding EEE, you are considered a producer if at least one of the following applies to you:
You manufacture EEE in Belgium and sell domestically
You import EEE into Belgium
You sell EEE in Belgium, even if you do not have a registered company address in Belgium.
If you are a non-Belgian company selling products online directly to Belgian customers, EPR regulations classify you as a “distant seller”. This means you are legally considered the producer of those products. For our platform, this applies to partner brands as well as most retailers.
However, if a retailer works with an upstream supplier (an importer or a manufacturer) who is already registered as the producer in Belgium, the retailer is not considered the producer.
Please reach out to Recupel directly if you have questions about your specific classification.
Who is considered an upstream supplier?
In the context of EPR for EEE, an upstream supplier refers to a supplier of a retailer that is located in the same country as the retailer, such as an importer or manufacturer. The importer or manufacturer who first brings EEE products onto the Belgian market is therefore considered the producer for EPR purposes.
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