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What do you need to know as a manufacturer or an importer?

Are you a Belgian manufacturer or importer of electro-appliances and you bring these onto the Belgian market? Then you must take the following into account...

As an importer or manufacturer, you have a legal obligation to take care of the collection and processing of the discarded appliances when you bring a new appliance onto the market.

To satisfy this legislation, you can enter into an affiliation agreement with Recupel. Then, we take care of this obligation. Once affiliated, there is some administration to complete regarding declaring the number of appliances brought onto the market.

What is the Recupel contribution?

The Recupel contribution is the amount added to the price of a new electro-appliance. Recupel uses this revenue to organise and coordinate the collection, sorting, processing and recycling of waste in Belgium.

All of the appliances that are subject to a Recupel contribution are listed in the appliance lists and are divided into 10 categories. Each category is further divided into ‘professional’ (blue) and ‘household’ (light blue).

For all professional electro-appliances, an administrative contribution is charged when the appliance is brought onto the market by the manufacturer or importer. This contribution covers Recupel’s costs for administration and reporting, but not for collection and processing.

For household appliances, an 'all-in' contribution is charged. It is stated separately – as ‘Recupel contribution’ – on the invoice or the payment receipt. In contrast to the 'administrative contribution', this ‘all-in’ contribution covers the costs for collection and processing as well as for Recupel’s operations and communication (reporting, monitoring companies, etc.).

The legal obligation

The legislation stipulates that each manufacturer that ‘brings an electro-appliance onto the Belgian market’ is also in charge of the collection and processing of the discarded appliances.

As a manufacturer of electro-appliances, you are responsible for taking back the discarded appliances at the end of their lifecycle, and you must oversee the recycling processing. What does this mean in practice? If you manufacture or assemble appliances, you are obliged to fulfil your take-back obligation.

We can handle your take-back obligation. It’s simple: affiliating with Recupel in accordance with the category of appliances that you import is all that is required.

If you would like more information about this, please contact us at 0800 40 386 (free of charge) or via the online contact form.

If you manufacture appliances and you do not have an affiliation agreement with Recupel, then you must submit an individual waste management plan to the authorities of the three regions (see Affiliation).

Appliance list

The Product Search Engine is a tool that quickly and easily gives you answers to questions like: the appliances belong to which category – household or professional? Which contribution applies at this time and what is the history of this contribution? And so on.

About affiliation

If you, as a company, manufacture appliances, then you can enter into an affiliation agreement with Recupel in order to satisfy the legislation concerning the collection and processing of discarded appliances.

Affiliation with 1 or more product categories is free of charge and can be done simply by entering into an online affiliation agreement.

If, as a manufacturer, you do not affiliate with Recupel, then you must submit an individual waste management plan to the authorities of the three Belgian regions.

More info at:
OWD: Office Wallon des Déchets
BIM: Brussels Instituut voor Milieubeheer
OVAM: Openbare Afvalstoffenmaatschappij voor het Vlaamse Gewest

About reimbursement of the Recupel contributions

If, as a manufacturer, you export appliances for which you have paid contributions to your Belgian supplier, then under certain conditions (export certificates) you can re-claim the contributions from Recupel. See Membership.

Reimbursement of the contributions also applies in the following cases:

  • upon sale with foreign VAT;
  • upon taking back defective goods;
  • upon assembly or installation in new products (e.g. screens, control tables, ...).

If you would like your Recupel contributions to be reimbursed, then you must first enter into an affiliation agreement for the product category(ies) in which you are active. This agreement contains the general conditions for the reimbursement of your Recupel contributions.

Important: Recupel contributions are divided into two categories: all-in contribution and administrative contribution.

The all-in contribution applies to all household electro-appliances. It defrays the cost of collecting, sorting, transporting and processing the appliances that are brought back to the container park or to the shop at the time of purchase of a new similar appliance. A part of the contribution also goes towards Recupel’s operations and communication (reporting, monitoring companies, ...).

For all professional appliances, an administrative contribution is charged when the appliance is brought onto the market. This contribution covers reporting and administrative costs. You cannot re-claim this administrative contribution.

Mandate to foreign suppliers

As a Belgian importer of electro-appliances, you can give your foreign supplier(s), with their consent, a mandate to fulfil your obligations in connection with the affiliation agreement.

You need not pay a Recupel contribution for, and/or make a declaration of:

  • goods that you import, store in a customs or VAT bonded warehouse, and bring onto the market in a foreign country;
  • goods that you import and store in a (regular) bonded warehouse and that you thereafter export abroad;
  • goods that you manufacture and bring onto the market in a foreign country.

‘Export’ means physically shipping electro-appliances outside the Belgian territory insofar as this shipping qualifies as an intracommunal delivery or as an export, as defined in the VAT statute book.

Thus, export is broader than merely sending goods outside the EU.

Declaration of appliances brought onto the market

Declaration of data

As a manufacturer, once you are affiliated with one or more categories of appliances that you produce, you need to submit your declaration, per quarter (ormonthly if you so desire), of the number of appliances brought onto the market.

This declaration can be made electronically or manually. For professional appliances with an administrative contribution, you declare the weight in addition to the number of appliances.

Electronic declaration

You submit your declaration via the electronic declaration form. After entering your username and password, you fill in the electronic form.

Manual declaration

You can also submit your declarations by faxing the declaration form to Recupel at the number: 0800 403 86.

Quarterly electronic invoicing

We then provide you with your quarterly invoice electronically, which allows you to pay the legal Recupel contributions.

Even if you submit your declaration each month, you always receive a quarterly invoice. This invoice states the total of the contributions per appliance category for the period concerned.

One time per year, you must also submit a global declaration of the appliances brought onto the market.