- Why become a member of Recupel?
- You bring appliances onto the market that have been purchased from a Belgian supplier.
- You import electrical and/or electronic appliances and put them on to the Belgian market for the first time.
- As an online shop located outside of Belgium, why should you join Recupel?
- How do you declare appliances?
- It is important to know that you are legally obliged to take back appliances.
- What should you state on your receipt or invoice?
- Basic principles for a correct declaration.
- An instructional video for the declarations.
If you sell electrical and/or electronic appliances in Belgium that you have purchased abroad or manufactured in Belgium, you are legally obliged to collect and process these appliances when they are discarded. To comply with this legal take-back obligation, all you need to do is join Recupel. Once you have signed a membership agreement, we will deal with this take-back obligation on your behalf. How exactly does this work? You declare the number of appliances per quarter on our digital member platform. Then you receive an invoice from Recupel containing the Recupel contribution for all these appliances. Recupel is then responsible for the collection, transportation and processing of the discarded appliances. The processing of e-waste is monitored and controlled by Recupel. It is only carried out by recognised Recupel partners and in accordance with the law. Additionally, Recupel reports to the regional authorities on your behalf. You can consult the Entry Agreement here.
What if you only sell electrical and/or electronic equipment from a Belgian supplier or suppliers? In that case, you do not need to register with Recupel as an importer or manufacturer. However, you are legally obliged to state the Recupel contribution for the appliance on your customer's invoice or receipt. In order to comply with the legal take-back obligation, you can join Recupel as a collection point for broken electrical and electronic appliances.
You import electrical and/or electronic appliances and put them onto the Belgian market for the first time.
Become a member of Recupel to declare your imported or manufactured electrical and/or electronic appliances. Membership is free and you can register easily here. Once a quarter, you will be asked to declare the number of appliances you have sold in each product category on the Recupel member platform, using your personal login.
Do you sell electrical and electronic appliances online to Belgian end consumers, but your registered office is located outside of Belgium? If so, you are legally obliged to register as a member of Recupel. According to Belgian and European legislation, you must appoint an authorised representative in Belgium. If you do not have one, Recupel can act as your authorised representative free of charge. You can join Recupel here.
When you sign the Entry Agreement, you can also fill in an addendum in which you designate your authorised representative.
What if you sell in another European country besides Belgium? Contact our counterpart in the country in question.
Once you become a member of Recupel, you submit quarterly declarations of how many appliances you have brought onto the market. This is easy through the digital member platform. You also have to submit an annual declaration of the appliances brought onto the market each year. Every three months, you will receive a digital invoice from Recupel with a detailed overview of your declaration. You can easily view your invoices on the digital member platform.
- What is the take-back obligation?
Consumers have the right to hand in their old appliances at the store where they purchase a similar new product . The retailer is obliged to take back this discarded appliance free of charge, even if it was purchased from another store and the consumer is buying a similar new product made by another brand. When a new appliance is delivered to the buyer’s home, the retailer must also take back the old appliance free of charge. Every importer (i.e. a company that purchases products outside of Belgium) or manufacturer who brings an electrical or electronic appliance onto the Belgian market is therefore legally obliged to collect and process discarded appliances. This also applies to second-hand appliances that are imported into Belgium and then discarded here.
You can find more information about the take-back obligation and the regional authorities' environmental policy agreements here.
- How does Recupel help companies to take back discarded appliances?
Customers buy appliances from you and want to return their old appliances. To make this easier for you, Recupel has set up a collection system. As a retailer, you can meet your obligation by becoming a Recupel collection point. We provide you with free containers to collect household appliances and we remove them on your request. You can read all about this here.
To arrange for the disposal of professional appliances, you can contact an accredited Recupel transporter or processor. You will find their details here.
Your customers must be transparently informed about the Recupel contribution that applies to appliances brought on the market.
In the case of a sale by a professional to a consumer, it is sufficient to indicate that the contribution is included in the price.
However, if the transaction is between professionals, the amount of that contribution must appear on the sales receipt or invoice.
This applies to all forms of publicity where prices are provided, such as price lists, catalogues, brochures, websites, etc.
- The following applies to household appliances:
- Sales to distributors: state the Recupel contribution separately for each appliance.
- Sales to private individuals or end consumers: it is sufficient to state 'Recupel contribution included'.
- The following applies to professional goods:
- Sales to distributors: it is sufficient to state 'Recupel contribution included'.
- Sales to private individuals or end consumers: it is sufficient to state 'Recupel contribution included'.
- What is the definition of an imported or manufactured appliance?
We consider an appliance (whether new or defective) to be imported or manufactured when it is sold, rented, made available or leased to a third party, or put into use directly, for the first time in Belgium. These appliances must be declared when they are put onto the market or at the time of purchase.
- Do you have to declare the export of appliances?
Export is defined as the physical shipment of equipment out of Belgium, whether this is an intra-Community supply (within the EU) or an export as defined in the VAT Code.
If you purchase appliances (household and/or professional) in Belgium that are intended for export, you can request a reimbursement of the Recupel contributions that have been paid in your declaration on the member platform.
- Transportation of appliances
You do not have to pay a Recupel contribution for:
- appliances that you import, store in a customs or VAT warehouse and put on the market abroad.
- appliances that you import and store in a (normal) warehouse and subsequently export.
- appliances that you manufacture and put on the market abroad.
- When do you have to file a declaration?
The Recupel declaration must be submitted every three months, and appliances are declared in the quarter in which they have been sold or imported. You will receive an e-mail invitation to submit your declaration. The deadline is the 20th of the month following the end of the quarter for which the declaration is being filed. You must also submit an annual declaration. In this, you confirm how many appliances you have brought onto the market in the past year.
- What is the Recupel contribution?
Companies who produce, import or sell e-appliances on the Belgian market are also responsible for the collection and recycling of these appliances. They can organize this themselves, but most choose the simpler solution and join Recupel as a member.
Per appliance brought onto the Belgian market, our members pay a Recupel contribution. In exchange, Recupel ensures that their appliances get a new life: we inform consumers and companies about the importance of this and how they can do this. We then make sure that they know how they can bring their old or broken appliances to a Recupel Collection point free of charge for reuse or recycling. In doing this, the recovered raw materials can be reused in the production of new appliances or in other industrial applications. Finally, we also ensure the required reporting to the government is done correctly.
- Household and professional appliances. What is the difference?
The distinction between household and professional appliances is made on the basis of the product's intended use and thus no longer on the basis of objective criteria such as weight/ size/ power, which was the case until 31/12/2021.
Appliances that can be used in both a household and professional environment are considered household appliances. Appliances that are exclusively intended for professional use are considered professional appliances.
Note: An appliance shall be considered as a household appliance unless it can be proved that it has a professional character.
The distinction between "all-inclusive" and "administrative" contributions remains.
For example: a laptop can be used for household or professional purposes and is thus considered household equipment (it does not have an exclusive professional application). A barcode scanner is exclusively for professional use and is thus considered professional equipment.
For example: a coffee machine designed for professional use (office, bar, etc.) that could potentially be used by an individual at home is still considered as professional equipment. In this case, the use by an individual is considered to be exceptional and not reasonably foreseeable.
In order to determine if a product is household or professional, the appliance list provides explicit definitions, examples and exceptions. These must be followed. If the appliance list does not provide an answer, you can determine whether the appliance has a household or professional character using the step-by step-plan created by Recupel. It is important to follow the order of the steps. If you get the answer after the first step, you do not need to proceed to the next steps. You can find the step-by-step plan here.
More information on the difference between the household and professional character of an electr(on)ical appliance can be found here.
- The appliance list
Is your product a household or a professional appliance? To which Recupel product category does an electrical or electronic appliance belong ? As from 01/01/2022 the electr(on)ic appliances are classified in 6 European main categories, more information is available here. The list of all electrical and electronic appliances with their respective Recupel contributions is available here.
- Filing a declaration for a quarter before 1 January 2022
Until 31/12/2021 electr(on)ic appliances were divided in 10 European main categories. Within these categories, there was also a distinction between ‘household’ and ‘professional’. Not the intended use (applicable as of 01/01/2022) but objective criteria such as weight and capacity determined the household or professional character of an appliance. To help you with the conversion of the categories (valid until 31/12/2021 versus valid from 01/01/2022) a conversion table is available. You can consult it here.
- How is the Recupel contribution invoiced?
When invoicing, we calculate the total of the Recupel contributions to be paid, minus the Recupel contributions to be reimbursed (for exported appliances). Have you declared appliances with a total contribution of less than €50 (excluding VAT)? In that case, you will not receive an invoice straight away. It will only be sent once your total declared contributions are €50 or more. If you stay below this amount, you will only receive an invoice once a year. If you have declared a total contribution of €50 (excl. VAT) or more, you will receive a digital invoice by e-mail. You will receive separate invoices for the declaration of your household appliances and professional appliances.
This video provides a good basis to make optimal use of the declaration system in general.