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How to become a member of Recupel

2.1   Was Recupel created on the basis of the law? (201000)

A legal framework exists for the creation of managing bodies.

Each Recupel sector has its own managing body. Their statutes, as well as those of Recupel asbl are published in the Appendices to the Belgian Bulletin of Acts, Orders and Decrees. You can consult them at www.staatsblad.be.

2.2   Are there organisations similar to Recupel abroad? (202000)

There are similar organisations in most European countries. The list of collective systems can be found on the website of the WEEE forum: www.weee-forum.org.

2.3   What is Recupel? (210000)

Recupel was founded by manufacturers and importers of EEE with the support of the regional authorities.
Its mission consists in the collection, sorting, processing and recycling of WEEE in Belgium.

This system was implemented on 1 July 2001.

Recupel works with recognized recycling companies that were selected on the basis of their experience in ecological processing of discarded appliances, their efficiency, as well as cost price.
Collection takes place in cooperation with traders, municipalities and intermunicipal companies. Special containers for the WEEE are available to the public in container parks.

Recupel informs and raises awareness among consumers and supports the government in checking the results.

The processing and recycling system is financed by the Recupel contribution paid by consumers when purchasing a new appliance. The system's philosophy is that the polluter pays for pollution and hence has to contribute to a better living environment.

2.4   Recupel's mission (220000)

Recupel is responsible for the practical execution of the take-back obligation. Recupel carries out the following activities, among others:

  • organisation of the pickup of discarded electrical and electronic appliances in compliance with provisions in the (regional) environmental policy agreements;
  • organisation of the processing of the collected discarded electrical and electronic appliances;
  • providing information to all players involved in the execution of the (regional) environmental policy agreements; and 
  • ensuring the monitoring of achieved results in the (regional) environmental policy agreements.

2.10   How is Recupel organised? (230000)

Seven managing bodies, organized as asbl, are responsable for the implementation of the take-back obligation for EEE, i.e. BW-Rec, Recupel AV, Recupel SDA, Recupel ICT, Recupel ET&G, LightRec and MeLaRec.

An importer or manufacturer concludes an Entry Agreement with one or more managing bodies, depending on the product categories he markets. Besides these managing bodies, Recupel asbl functions as executive organ.

2.11   What is a managing body? (231000)

The mission of managing bodies is to carry out the take-back obligation for WEEE on behalf of its members.
The various Recupel sectors are managing bodies that carry out the take-back obligation each for their own product group.

2.12   Did the government invest in Recupel? (232000)

No. The various Recupel managing bodies and Recupel asbl are the results of a private initiative on the part of importers/manufacturers of EEE.

Recupel does report its activities to the authorities, in order to meet the legal obligations in the framework of the WEEE take-back obligation.

2.13   Do I have to be a member of a managing body if I only imort once goods that belong to their area of activities? (233000)

Yes, even if you only import an EEE once in a specific sector, you have to become a member of the relevant managing body.

2.14   Why become a member of Recupel? (240000)

Contracting out the execution of the legally imposed take-back obligation can save you a lot of time and energy, as Recupel manages the organisation of the collection and processing of the delivered appliances throughout Belgium. It is also responsible for informing consumers and distributors about legislation and provides reports to the authorities. By mandating a representative umbrella organisation that has signed the environmental policy agreement, in addition to Recupel membership, you do not have to draw up your own waste management plan that meets the relevant legal requirements. If you wish to draw up your own waste management plan anyway, you can still become a member of Recupel. In this case you do not have to mandate a representative umbrella organisation and the waste management plan will be included in the Recupel membership.

2.15   Who can become a member of Recupel? (250000)

In theory only importers and manufacturers who are subjected to the take-back obligation for waste electrical and electronic appliances can become a member of Recupel. If you are entitled to Recupel contribution refunds you can become a member of Recupel. On certain conditions foreign suppliers can, howerver, also become a member of Recupel.

2.16   Do all sellers, wholesalers and manufacturers and manufacturers of electrical and electronic appliances become members of Recupel? (251000)

No. Only manufacturers, importers and exporters of electrical and electronic appliances, who opt for the collective system, are members of Recupel.

2.17   How do I communicate that I want to conclude an entry agreement? (261000)

Indicate what entry agreement(s) you wish to conclude, preferably electronically.
You can also contact us by telephone (0800/403 86) in which case we will send you the required documents.

In addition to the registration form, which will confirm your membership in a specific managing body, Recupel will also provide you with a username and password (via e-mail) in order to be able to make an electronic declaration.

2.18   How long will it take before Recupel's managing body responds to a membership application? (262000)

In practice registration is relatively fast. A few days after your application you will receive a username and password, enabling you to submit declarations electronically.

2.19   Is membership in a Recupel managing body free? (263000)

Both Recupel membership and future services are free, in theory.

However, if you do not submit an electronic declaration, a contribution to administrative costs for processing the declaration may be charged.
Since January 2007 an administrative fee of € 1.50 VAT excluded can be charged for the processing of declarations that are not submitted through the Recupel website.

This contribution is due for each managing body of which you are a member (for example, if you are a member of BW-Rec and SDA and submit declarations via fax for the month of January 2007, you may be charged an administrative fee twice for this month).

2.20   How to cancel the membership agreement? (264000)

The ways of ending a membership agreement are extensively discussed in the membership agreement.

In the event of no-fault termination cancellation is to take place by registered letter with acknowledgment of receipt or through a bailiff's writ.
A 6-month notice period applies.

It must be noted that even after cancellation of the membership agreement, you are still subjected to the acceptance obligation for EEA if you pursue your activities.

2.21   Retroactive Recupel membership (270000)

Importers and producers can sign a Membership agreement with Recupel at any time.

This does not prevent the fact, however, that legally an acceptance obligation was in effect earlier and that the importers and producers should have complied with legislation from that time on.

Importers and producers that conclude a membership agreement with a Recupel management organisation after the start of activities of the management organisation for a specific product group, are to pay Recupel contributions to Recupel for all goods in said product group that they have marketed from the start of activities by the management organisation for said product group.
Only after submission of an approved individual waste management plan can the relevant importer/producer be granted an exception to the aforementioned principle.
If, for example, you would conclude a membership agreement in the course of 2007 with the LightRec sector, you are to pay Recupel contributions for the lighting fixtures imported since 1 July 2004, as well as for the gas discharge lamps imported since 1 July 2005.

This regulation prevents discrimination against importers and producers who have complied with the acceptance regulations in a timely manner and therefore have been paying Recupel contributions from the start of activities of the management organisation.

However, in order to prevent importers and producers from being discouraged from becoming a member of the management organisation, since the cost of the rteroactive recycling contribution would become enourmous, a 7-year prescription applies to the membership agreement, from the year following the calendar year to which the annual collection status refers.
An example for illustration. If you become a member of BW-Rec in 2008 you will have to pay Recupel contributions for all products marketed after 1 July 2001, as the seven-year period starts from 1 January 2002. If you become a member of BW-Rec in 2009, you will have to pay Recupel contributions from products marketed after 1 January 2002. Obviously for membership in MeLaRec in 2008 you will only owe Recupel contributions for imported medical equipment from 1 July 2005, since this management organisation has only been active from that date.

2.22   Obligations after affiliation (280000)

After affiliation in one or more Recupel Managing Bodies, you have to ensure that your identification sheet remains up-to-date, that you pay Recupel contributions and submit declarations to this end.

2.23   How to keep the identification up-to-date? (281000)

The identification sheet is an important tool in the communication between member importers and producers and the magaging bodies. It determines who will be informed of major changes, for example in appliance lists, who will be reminded to submit an annual summary, and it informs the managing body. It is therefore of the utmost importance that this sheet be kept up-to-date.

You can consult this sheet and modify it using your personal username and password just as you submit declarations.
Any modification to your identification sheet will always be checked by a Recupel employee, who will contact you in the event of an 'abnormal' modification.

If you wish to submit other data to Recupel, for which the identification sheet does not have any provisions, you can contact Recupel via the contact page.
You will be informed of any follow-up to your message.

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