What is the new Extended Producer Responsibility (EPR) requirement in Belgium and what do I need to do?

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.

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.

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.

With regards to EEE, you are considered a producer if:

You manufacture EEE in Belgium and sell domestically; 

and/or

You import EEE into Belgium;

and/or

You sell EEE in Belgium, even if you do not have a registered company address in Belgium.

In the case of a non-Belgian company selling its products directly to Belgian end-users, the producer is the distant seller i.e. the company selling online. For Zalando and our partners, this therefore refers to partner brands as well as most retailers. 

However, if a retailer works with an upstream supplier, i.e. an importer or a manufacturer, who is considered a producer in Belgium as defined above, the retailer is not considered a producer.

Please reach out to Recupel directly if the classification between producer/non-producer raises questions.

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.

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.

If you are selling or planning to sell EEE products in Belgium, you should begin registering for an EPR ID (“member code”) for WEEE in Belgium. This will include the following steps: 

1. Register for EPR WEEE with the Belgian PRO Recupel. You will receive an EPR registration number, known as a “member code”. If you do not have a registered address in Belgium, you must first appoint an authorised representative. If you do not have an authorised representative in Belgium, Recupel can act as such so we recommend reaching out to them directly for further information.

2. Once you have received your EPR member code from Recupel, you will need to share it as proof of your EPR compliance when Zalando begins the collection and verification process. We will inform you about the timeline later this year. 

If you have not done so already, we advise you to start your EPR registration with Recupel as soon as possible so you are prepared for the collection process when it begins.

Providing a valid EPR registration number will be mandatory once the collection feature is live. In case of non-compliance, Zalando reserves the right to deactivate your EEE assortment in the Belgian market until your EPR ID is collected and verified.