EPR System in Belgium

If you run a business in Belgium, especially one that sells physical products, you’ll quickly discover that waste management and packaging reporting come with their own set of rules. The key thing to understand is that Belgium doesn’t operate under a single, nationwide system. Instead, each of the three regions — Flanders, Wallonia, and the Brussels-Capital Region — manages its own environmental regulations, registration platforms, and reporting procedures.

In practice, that means your environmental obligations depend on where your business is based and, in some cases, where your products are sold or distributed. A company that operates across multiple regions may need to register and report in more than one system.

Why Belgium’s System is Decentralized

Belgium’s administrative structure gives each region autonomy over environmental and waste management policies. Rather than having one central authority, every region defines its own procedures, forms, and platforms for compliance.

In Flanders, the responsible body is OVAM (Public Waste Agency of Flanders). Businesses submit their reports through MATIS, an information platform for materials and waste, and through the e-loket portal. In Wallonia, registration and reporting duties fall under SPW ARNE (Department of Soils and Waste), while in the Brussels-Capital Region, companies use BRUDAWEB, a dedicated online system for submitting annual waste reports in line with the BRUDALEX regulations.

Because of this regional structure, businesses operating in different parts of Belgium can face slightly different obligations. Even cities that are geographically close may require distinct documentation or follow unique procedures, which can be confusing at first.

What This Guide Covers

This guide will help you make sense of the Belgian waste management landscape and understand how to meet your environmental reporting obligations as a business owner. We’ll walk through how the regional registers function, what kind of data needs to be collected, and where it should be reported.

We’ll also explain how Belgium applies the Extended Producer Responsibility (EPR) model, coordinated across regions by the Interregional Packaging Commission (IRPC/IVCIE). Two major organizations manage most business participation: Fost Plus, responsible for consumer packaging, and Valipac, which handles industrial packaging.

Beyond packaging, EPR also extends to other product categories, such as batteries and electrical or electronic devices. Understanding which obligations apply to your business will help you avoid compliance issues and manage waste in a way that aligns with Belgian and EU environmental standards.

By the end of this article, you’ll know exactly how to register, which reports to file, and when to do it. The goal is to stay compliant and avoid penalties — all while keeping your business efficient, sustainable, and free from unnecessary administrative headaches.

The Waste Register in Belgium – Regional Obligations

Belgium’s waste management system can be compared to three separate “mini-countries” operating under one flag. Flanders, Wallonia, and the Brussels-Capital Region each have their own rules, forms, platforms, and reporting deadlines. For companies active in more than one region, this means working with several sets of regulations at once. It might sound complex at first, but with the right plan and understanding of the requirements, you can easily stay organized and avoid compliance headaches.

Flanders

In Flanders, the authority responsible for waste management control and record-keeping is OVAM, the Public Waste Agency of Flanders. OVAM isn’t a reporting platform itself — it’s a public agency that provides online tools for fulfilling registration and reporting duties, most commonly through the e-loket system.

One of the main tools businesses may encounter is the Waste Register, an electronic database where specific categories of companies must record their waste activity. It’s not required for every business in the region — only for those whose operations generate or handle certain types of waste.

Entries in the register typically include details such as the waste code (based on the European Waste Catalogue), the quantity produced, the date it was handed over, and the recipient’s information. For example, if you run an online store in Antwerp and regularly dispose of packaging materials from shipments, or if your business generates hazardous waste during packaging or light manufacturing processes, you may be required to maintain a Waste Register.

Keeping your data up to date is crucial. OVAM has the authority to review records at any time, and incomplete or delayed reporting can lead to penalties. Accuracy and consistency are taken seriously, so it’s best to make updating your register part of your routine operations.

Another key system in Flanders is MATIS, the region’s materials and waste information platform. MATIS is primarily designed for companies involved in waste collection and processing, helping OVAM monitor waste flows across the region and track progress toward circular economy goals.

For instance, if you operate a sorting facility and work with several municipalities, MATIS is where you would report the volumes of paper, plastics, or glass you collect and transfer for recycling. It’s a crucial part of the region’s broader effort to close the loop on materials and promote more sustainable resource use.

Wallonia

In Wallonia, waste management oversight is handled by SPW ARNE, the Department of Soils and Waste within the Service Public de Wallonie. The registration requirement with SPW ARNE applies to businesses that transport, collect, or trade waste — including hazardous and certain types of non-hazardous waste listed in the regional regulations. This obligation can also apply to companies that only transport waste occasionally as part of their business activity.

For example, if you run a renovation business in Charleroi and occasionally transport rubble or other building materials yourself, you may need to register as a waste transporter with SPW ARNE.

Companies that generate hazardous waste or specific special waste streams, such as medical waste, must also submit an annual declaration to SPW ARNE. The deadline for this report is 31 March, covering data from the previous calendar year. The declaration includes details such as the type and quantity of waste produced and how it was managed — whether it was recycled, treated, or incinerated.

Recycling and recovery facilities in Wallonia are required to keep detailed records of all waste they receive and process, and to store this documentation for at least ten years. Because of this long archiving period, it’s best practice to use digital record-keeping systems from the start. Electronic tracking makes it easier to organize data and provide documentation quickly in case of an inspection.

Brussels-Capital Region

In the Brussels-Capital Region, the main tool for waste reporting is BRUDAWEB — an online platform used to submit annual waste reports. The reporting deadline is 15 March, and companies must declare all waste that has been collected, transported, or transferred during the previous year. The report must include detailed information about the type of waste, its mass, and how it was processed.

For instance, if you run a catering business in Brussels and work with a company that collects used cooking oil, you still need to record those quantities in BRUDAWEB — even if the physical transport is handled by someone else.

The registration obligation applies to any business professionally involved in waste management, including transport, collection, and trade. However, even occasional waste transport carried out as part of a company’s operations can trigger a registration requirement with Brussels Environment, via the BrudaLex system. These obligations come from the BRUDALEX regulation, which sets the framework for businesses active in this field.

Regulations in Brussels are strict. Operating without prior registration can lead not only to financial penalties but also to a formal ban on providing certain waste-related services within the region. It’s essential to complete all registration steps before starting any activities that involve waste transport or management.

The EPR System for Packaging in Belgium

In Belgium, packaging obligations are governed by the EPR system — Extended Producer Responsibility. This framework means that any company placing packaged products on the Belgian market is responsible for organizing and financing the collection, processing, and recycling of that packaging once it becomes waste.

The obligation doesn’t apply only to manufacturers in the traditional sense. It also includes importers, first distributors, and e-commerce sellers who ship packaged goods to customers in Belgium. For cross-border e-commerce, the rule applies based on the total weight of all packaging that physically ends up in the hands of Belgian consumers or businesses. Importantly, EPR covers all types of packaging — individual retail packaging, transport packaging used for deliveries, and industrial packaging used in B2B transactions.

The entry threshold for joining the system is clearly defined. Once the total annual weight of packaging placed on the Belgian market exceeds 300 kilograms, regardless of material type, the company must register and report under the EPR framework. This ensures that all businesses, from small online shops to large importers, contribute fairly to recycling and waste management costs.

The Role of the Interregional Packaging Commission (IRPC / IVCIE)

Oversight of the EPR system in Belgium falls under the Interregional Packaging Commission (IRPC / IVCIE) — a joint institution created by the three regions of the country. Its main role is to coordinate EPR rules nationwide, monitor compliance, and verify whether companies meet their recycling and recovery targets.

Although the IRPC sets the legal framework and conducts audits, it doesn’t handle company declarations directly. That task is carried out by authorized Producer Responsibility Organizations (PROs) — primarily Fost Plus and Valipac.

The IRPC sets unified criteria for all of Belgium, checks reports submitted through the PROs, and may request supporting documentation even several years after a declaration has been filed. If a company fails to meet its obligations, the Commission can impose administrative fines or additional compensation payments to offset missed recycling targets.

Fost Plus – Household Packaging

Fost Plus is Belgium’s largest PRO, responsible for managing household packaging waste — the kind that ultimately ends up in private homes. This includes PET bottles, aluminium cans, glass bottles, milk cartons, and other food and beverage packaging.

Any company that places more than 300 kilograms of packaging per year on the Belgian market must become a Fost Plus member. Annual declarations must be submitted by 28 February each year, covering the previous calendar period. These reports include both a company’s own packaging and the packaging that comes with imported goods.

Fees in the Fost Plus system are calculated according to an eco-modulation principle — meaning that packaging made from easily recyclable materials is charged at a lower rate, while harder-to-recycle materials, such as multi-layer plastics, are subject to higher fees. This approach encourages companies to design and choose more sustainable packaging solutions that align with circular economy goals.

Valipac – Industrial and Commercial Packaging

Valipac manages industrial and commercial packaging — the types that rarely end up in households but are widely used in B2B operations. These include wooden pallets, stretch film for securing shipments, large bulk bags, transport cartons, and industrial drums.

While joining Valipac is technically voluntary, in practice it’s the most straightforward and cost-effective way to fulfill EPR obligations for this category of packaging. The alternative — documenting and reporting the entire collection and recycling process directly to the IRPC — can be both complex and time-consuming for most businesses.

As with Fost Plus, annual declarations for Valipac must be submitted by 28 February for the previous reporting year. The organization oversees the recycling process and prepares reports confirming that legal recycling requirements have been met on behalf of its members.

Registration with the IRPC

Registration under the Interregional Packaging Commission (IRPC / IVCIE) can be done directly by the company or through an authorised representative — a common practice for non-Belgian businesses selling packaged goods into the Belgian market.

During registration, companies must provide details such as the types and quantities of packaging placed on the market, the materials used, a plan or proof of how recycling obligations will be met, and contact details for the person responsible for reporting.

Failing to register on time, submitting incorrect data, or neglecting EPR responsibilities can result in significant penalties. These may include financial fines, additional compensatory fees, or even administrative proceedings. The IRPC has the right to audit documentation for several years after a declaration is filed, so keeping an organized digital archive is highly recommended.

Key Deadlines and Compliance Calendar

Belgium’s waste and packaging systems operate on strict deadlines — and meeting them is essential to staying compliant. Although each region has its own procedures, the reporting dates are consistent and repeat every year, which makes it easy to add them permanently to your company’s compliance calendar. They should be treated with the same importance as tax or accounting deadlines.

In Wallonia, businesses that generate hazardous or special waste — such as medical waste or used oils — must submit an annual declaration to SPW ARNE by 31 March for the previous year. This obligation is set out in the Arrêté du Gouvernement wallon and applies to waste types marked with an asterisk (*) in the European Waste Catalogue, indicating materials that pose potential risks to health or the environment.

Not every waste stream automatically qualifies as hazardous; classification depends on its actual composition and labeling. The declaration must list each waste category, its EURAL code, the total volume generated, and how it was managed — whether through recycling, incineration, or neutralization. The best approach is to keep records throughout the year and log every batch of waste as it’s generated, rather than trying to reconstruct the data later in March.

In the Brussels-Capital Region, annual reporting through BRUDAWEB is mandatory for all registered waste transporters, collectors, and brokers. Reports must be submitted by 15 March each year and must include details about all waste collected, transported, or passed on during the previous year. Data such as the waste type, weight, and destination facility must be accurately entered.

Keeping data separated by region is particularly important. Many businesses that operate across multiple regions make the mistake of combining their data sets, which often leads to errors in Brussels reporting. Maintaining a separate record specifically for Brussels ensures compliance and prevents confusion during audits.

EPR Declarations – Fost Plus and Valipac

For packaging, the reporting deadline is the same for both main Producer Responsibility Organisations (PROs) — Fost Plus (for household packaging) and Valipac (for industrial packaging). The annual declaration must be submitted by 28 February for the previous calendar year.

Each report includes details such as the type of packaging material used, the total mass placed on the Belgian market, and how recycling obligations are fulfilled — whether through your own arrangements or via the PRO.

Both organizations provide electronic reporting forms that help classify materials correctly and automatically calculate weights. It’s worth using these tools, as mistakes in classification can lead to corrections or additional charges later. A good practice is to prepare your data in January, since the end of February is typically a busy period for administrative and financial reporting across most businesses.

Maintaining Waste Registers – OVAM, MATIS, and BRUDAWEB

Not every reporting obligation in Belgium follows a fixed annual deadline. For waste registers maintained in OVAM (in Flanders) or MATIS (used by collection and processing facilities), the rules require that data be updated within a “reasonable timeframe” after waste is generated, received, or transferred. In practice, this means entries should be added continuously — not postponed until the end of the year.

In the BRUDAWEB system, data is usually reported as part of an annual statement, but for certain types of operations, such as waste treatment plants, updates may need to be submitted more frequently.

Belgian authorities can request access to your records at any time. Failing to maintain up-to-date registers is one of the most common reasons companies face fines. The best approach is to enter waste data into the system within just a few days of its generation or transfer. This ensures compliance and saves a lot of stress in the event of an inspection.

Sanctions and Consequences of Non-Compliance

Belgian regulations on waste management and the EPR system for packaging are actively enforced. Inspections take place regularly, and penalties are applied efficiently when breaches are found.

For entrepreneurs — especially small businesses or B2B operators — ignoring these obligations or missing key deadlines can cause serious financial and operational problems. Authorities tend to be pragmatic, though: if a minor mistake is corrected quickly, it’s often possible to avoid harsh consequences.

However, repeated or significant violations can lead to substantial penalties — sometimes reaching tens of thousands of euros — along with additional compensation fees to make up for unfulfilled recycling targets. Staying proactive, organized, and transparent in your reporting is the best way to protect your business and maintain a good relationship with Belgian environmental authorities.

Administrative Inspections

In Belgium, inspections can be either planned or completely unannounced. Inspectors may visit companies after receiving reports of irregularities, or as part of coordinated industry-wide checks conducted across a region — for example, in the waste management or construction sectors.

The scope of an inspection usually includes reviewing documentation, checking entries in electronic registers, and sometimes a site visit. In systems like OVAM or BRUDAWEB, any inconsistency between the information recorded online and the paper documentation is considered a breach of accurate reporting obligations. This typically results in data correction requests, and often an administrative fine. In more serious cases — such as missing records or falsified documents — criminal proceedings may follow.

Risk of Losing the Right to Operate

The most serious consequence of non-compliance is the suspension or withdrawal of an environmental permit. This applies especially to companies involved in waste transport, collection, or processing, but can also affect other industries that generate significant waste or place large volumes of packaging on the market.

In the context of EPR, if the Interregional Packaging Commission (IRPC / IVCIE) determines that a company has failed to meet its obligations for an extended period, it may suspend the right to place packaging on the Belgian market until all overdue responsibilities are settled. Furthermore, if a company loses its authorization in one region, this can lead to its refusal in another. The regional administrations exchange compliance data, and the IRPC maintains records of non-compliant businesses, meaning that reputational risks extend far beyond one location.

Business Requirements and Reputation

Compliance in Belgium is not just about avoiding penalties — it’s increasingly a matter of business credibility. In many sectors, especially those linked to quality and sustainability certifications such as ISO 14001 or BREEAM, failing to meet environmental standards can automatically disqualify a company from public or private tenders.

More and more business partners require proof of legal compliance before signing contracts. Without it, your proposal might not even be considered, regardless of price or service quality. Transparent and accurate reporting is therefore not only a regulatory duty but also an important part of building trust and competitive advantage. In Belgium’s business environment, a company’s reputation often determines whether it retains clients and secures new contracts.

Summary and Recommendations

Belgium’s system for waste management and packaging obligations stands out for its regionalized structure. Each of the three regions — Flanders, Wallonia, and the Brussels-Capital Region — has its own registration platforms, procedures, and reporting schedules. On top of that, there is a nationwide Extended Producer Responsibility (EPR) system for packaging, supervised by the Interregional Packaging Commission (IRPC / IVCIE), and implemented in practice through approved Producer Responsibility Organisations such as Fost Plus (for household packaging) and Valipac (for commercial and industrial packaging).

For entrepreneurs, the key is to know exactly where their business operates and which regional rules apply. Companies active in more than one region need to master several systems at once and coordinate reports and declarations carefully to avoid overlapping data or missed deadlines.

The single most important recommendation is to maintain your registers continuously. Belgian authorities can inspect records at any time, so updating your entries every few days — or daily in larger operations — is the best way to avoid stress and mistakes.

The second pillar of good compliance is planning. Every company should include key dates in its yearly schedule:

  • 28 February for EPR declarations to Fost Plus and Valipac,
  • 15 March for BRUDAWEB reports in Brussels, and
  • 31 March for hazardous waste declarations in Wallonia.

At the same time, businesses should ensure that data in OVAM or MATIS is updated continuously. Some sectors, particularly waste management companies or those with environmental permits, may also face additional quarterly reporting duties.

Another crucial aspect is coordination with your partners. If you work with a waste transport company or a PRO organization, make sure you receive all official documents confirming that waste has been properly processed for recycling. In Belgium, local certificates such as bewijs van verwerking or certificat de traitement are commonly required as proof of compliance. The absence of these documents can be treated as a violation, even if the waste was actually recycled.

Finally, always rely on official sources. The most important websites and platforms include OVAM in Flanders (Waste Register and MATIS), SPW ARNE in Wallonia (registration for waste transporters and hazardous waste declarations), BRUDAWEB and BrudaLex in Brussels, as well as the websites of Fost Plus, Valipac, and the IRPC for EPR obligations. All three regions provide up-to-date information in Dutch and French, and often in English as well, along with current forms and guidance.

In short, Belgium’s system might seem complex at first, but once you build a consistent routine for record-keeping, stick to the reporting calendar, and rely on trustworthy sources, your company will stay fully compliant. It’s not only a way to avoid fines — it’s an investment in your credibility and long-term reputation on the Belgian market.

If you prefer not to manage all the formalities yourself, professional support is available — and partnering with experts who specialize in Belgian compliance can save you time, reduce risks, and keep your operations running smoothly.

 

Iza

The author of the article is the amavat® team

amavat® is one of the leading firms providing comprehensive accounting services for Polish e-commerce companies and VAT Compliance across the European Union, the United Kingdom, and Switzerland. The company also offers a proprietary innovative application that integrates accounting with IT solutions, allowing for the optimization of accounting processes and integration with major marketplaces such as Allegro and Kaufland, as well as integrators like BaseLinker.

Ask a Question »
This publication is non-binding information and serves for general information purposes. The information provided does not constitute legal, tax or management advice and does not replace individual advice. Despite careful processing, all information in this publication is provided without any guarantee for the accuracy, up-to-date nature or completeness of the information. The information in this publication is not suitable as the sole basis for action and cannot replace actual advice in individual cases. The liability of the authors or amavat® are excluded. We kindly ask you to contact us directly for a binding consultation if required. The content of this publication iis the intellectual property of amavat® or its partner companies and is protected by copyright. Users of this information may download, print and copy the contents of the publication exclusively for their own purposes.