"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.
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.
The practical takeaway: a small seller shipping a handful of packages a week to Belgium still needs an authorised representative. The 300 kg exemption does not get you out of it.
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.
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