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PPWR registration: no volume threshold

1 Sep 2026 · Regulation

"I only ship a few packages a month — do I really need to register?" Since the PPWR came into force on 12 August 2026, the answer is unambiguous, and Fost Plus has now put it in writing.

TL;DR — PPWR registration has no volume threshold: every producer must register in each country of sale, and non-EU sellers need an authorised representative first.

The registration duty covers every producer

The PPWR requires every producer — every company subject to extended producer responsibility (EPR) — to register in the national producer register. As Fost Plus states it plainly:

"This applies to all household packaging placed on the Belgian market."

"All" means all. There is no carve-out for small sellers.

There is no volume threshold

Registration is not gated by how many kilograms you ship. It applies from the first package. The "300 kg" figure that circulates online is a different, narrower rule — we come back to it below.

Foreign producers must appoint an authorised representative

Fost Plus is equally explicit on this point:

"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."

And under the PPWR, from 12 August 2026, a foreign producer must be represented by an Authorised Representative who is (1) established in Belgium and (2) registered with EPRiBEL. Neither condition is optional.

Who actually registers you

  • Fost Plus member — Fost Plus registers you collectively, at no additional cost (registration fees only apply from 2027).
  • Not a member — you register directly through EPRiBEL.
  • Selling only through a platform — in many cases the platform registers; but for e-commerce sellers this is still being clarified by the authorities.

Then what is the "300 kg" figure?

The 300 kg threshold comes from old Belgian national law and exempts exactly one thing: the take-back / recycling obligation (Article 6 of the Cooperation Agreement). It does not exempt registration, and it does not exempt the AR obligation. A seller under 300 kg still needs an authorised representative.

The practical takeaway: from the very first package you place on the Belgian market, you need a Belgian authorised representative registered with EPRiBEL. A "small" volume does not get you out of it.

Sources: Fost Plus — PPWR Insights 8: mandatory registration and Fost Plus — PPWR in force: applicable rules.

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