"I ship less than 300 kg a year, so I don't need to do anything." We hear this often — and it's a misunderstanding that can get a small seller into real trouble.
TL;DR — The 300 kg threshold only exempts the recycling obligation — the AR and registration duties have no volume threshold and apply from the first package.
What the 300 kg figure actually is
The 300 kg threshold comes from Belgian guidance (via UNIZO): companies placing less than 300 kg of packaging on the Belgian market per year are exempt from the take-back / recycling obligation (the terugnameplicht). It is a narrow exemption tied to one specific duty — joining a collection-and-recycling scheme.
What it does not exempt
It does not exempt the authorised representative obligation. These are two different duties:
- The AR obligation — appoint a Belgian authorised representative. Applies to non-EU sellers from the first package, no threshold.
- The recycling obligation — join a scheme like Fost Plus. This is where the 300 kg exemption lives.
Fost Plus confirms it — in writing
Since the PPWR came into force on 12 August 2026, Fost Plus has stated the position unambiguously:
"Registration is also mandatory for non-Belgian companies without a Belgian establishment that place products on the Belgian market. They must mandate an authorised representative to do so."
"This applies to all household packaging placed on the Belgian market."
Note the wording: all household packaging. There is no volume threshold anywhere in the PPWR registration duty.
The PPWR adds a second obligation — also with no threshold
Under the PPWR, every producer must register in the Belgian producer register, from the first package, with no 300 kg carve-out. And from 12 August 2026, a foreign producer must be represented by an authorised representative who is established in Belgium and registered with EPRiBEL.
So a small seller now faces two duties with no volume floor: the AR obligation, and PPWR registration. The 300 kg exemption touches neither.
The practical takeaway: a small seller shipping a handful of packages a week to Belgium still needs an authorised representative — and now PPWR registration too. The 300 kg exemption does not get you out of either.
For contrast, the Netherlands sets its registration threshold at 50,000 kg — but there, below-threshold sellers also don't need a Dutch AR. Belgium is the tighter market, and the one most e-commerce sellers must get right.
Sources: Fost Plus — PPWR in force: applicable rules and Fost Plus — PPWR Insights 8: mandatory registration.
Need an authorised representative? Get a quote — tell us your target countries and we'll send a tailored plan within one business day.