Cookies

This website uses cookies for analysis, personalized content and ads. You always have the right to refuse any cookie or system that is not essential to the basic operation of the web site.

Recupel contribution

3.1   Why is the Recupel contribution not a tax but a contribution? (300010)

Taxes are imposed by the government on the basis of a law.

The Recupel contribution is used in order to allow for services by the Managing Bodies, and was created as a private initiative.
Since the Recupel contribution is collected in the framework of a legal take-back obligation, it is, however, controlled by the supervisory regional authorities.

3.2   How is the Recupel contribution charged in terms of accounting? (300020)

For manufacturers and importers, the contribution in terms of accounting, is not included in the purchase or sales price. It is to be processed in the VAT declaration as a service.

It is recommended to post Recupel contributions as a suspense account (class 4), as is the case for VAT. Contributions are then considered as amounts that do not belong to the company, but as amounts that are "set aside" up to the time of request for payment on the part of the managing body. There are, however, other posting options that are also correct.

3.4   Does Recupel have accounting software that can be downloaded? (300040)

No, Recupel does not recommend a specific accounting program.

Recupel does, however, make online declarations available, which facilitates the process.

3.5   Why do you pay a Recupel contribution? (300100)

Importers and manufacturers, who are members of Recupel, pay a Recupel contribution in order to finance Recupel's activities.

In most cases they have to pass on this Recupel contribution to their customers, resulting in the importers and manufacturers not bearing the cost of the Recupel contribution.

The Recupel contribution is no tax or other special levy, but a contribution to the services performed by the Managing Body in the framework of the take-back obligation for WEEE.

3.6   What does the Recupel contribution cover? (300110)

Since January 2007 we have made the distinction between two types of contributions. All-in contribution: this all-in contribution will be used to pay for the collection, sorting, transport and processing of appliances, brought back to the container park or to the shop when a new similar appliance is purchased. A part of the contribution also goes towards Recupel's operation and communication (reports, company checks, etc.). Administrative contribution: this administrative contribution is used to cover reporting and administration costs. Warning! Since 1 July 2005 a retroactive declaration is in force for appliances with an administrative contribution. This concerns an informative declaration. The invoicing of the administrative contribution starts with the declaration of January 2007. The Recupel contribution for most appliances has been reduced as from January 2007. Since 1 July 2008, most Recupel contributions went down for a second time. This new decrease is partly due to the favourable conditions in which Recupel was able to conclude new contracts with logistic partners. The costs for pick-up and processing went down as a result of this.

3.8   How do you know whether a product is included in the appliance list? (310100)

For most products, it is clear from the managing bodies' appliance list, if a, and if so which, Recupel contribution is to be charged.

If, after consulting the appliance lists, you still have doubts about the contribution to be charged, contact Recupel using the online contact form.

You will receive an informal answer, taking into account the information provided by you.
If you would like a formal reply, binding to the Managing Body, you can also submit a ruling request.

3.9   What is referred to as "domestic" character of appliances? (310110)

An EEE is for "domestic" use when it is destined for private households orfor commercial, industrial, institutional and other use that is comparable in nature and quantity with a product destined for private households. In other words, a computer used in a company's office is domestic use.

3.10   Does a Recupel contribution apply to batteries? (310120)

No, batteries are not subject to Recupel contribution. A “BEBAT” contribution is due for batteries.


BEBAT is the managing body that handles the pickup and recycling of batteries.
Batteries are not subject to Recupel contribution.

An electrical or electronic appliance that runs on batteries is, however, subject to Recupel contribution, at least provided it is mentioned on the Recupel's appliance lists.

3.11   Does a separate Recupel contribution have to be applied to an option? (310130)

No Recupel contribution is charged for an option.

An option is considered to be a component of an electrical or electronic appliance that is unable to work by itself and always has to be connected to the appliance for which it is destined in order to be operational.

3.12   Is there a separate Recupel contribution due for a component? (310140)

A Recupel contribution is only due for a component if the latter is an electrical or electronic appliance that can run on its own.

3.13   Is there a separate Recupel contribution due for spare parts? (310150)

No Recupel contribution is required for spare parts.

A spare part is considered to be a replacement part intended to replace an identical or similar part, which forms an integral part of the original appliance.

3.14   Does the Recupel obligation apply to demonstration appliances? (310160)

Demonstration appliances are subject to the Recupel obligation when they are put into service in your showroom or when they are sold, rented or leased to your customers.

3.15   What happens when several appliances are sold together? (310170)

If appliances are permanently integrated, only one Recupel contribution is charged.

If appliances are not permanently integrated, a Recupel contribution is to be charged for each appliance. For (promo)sets of several EEE therefore, several Recupel contributions are to be charged.

3.16   Are second-hand appliances subject to the contribution? (310180)

Yes, imported second-hand appliances are subject to the Recupel contribution.

3.17   When do you pay the Recupel contribution? (320000)

The time when you pay the Recupel contribution depends on the fact whether it involves imported or manufactured goods.

3.18   When do you pay the Recupel contribution for imported or manufactured goods? (321000)

For imported or manufactured goods, you are to pay the Recupel contribution within the deadline on the invoice you will receive from Recupel.

For declarations that are submitted in a timely manner, invoices are due within 30 days of invoice date.

The invoice is drawn up after submission of the declaration form that includes the appliances marketed during a specific period.

3.19   When do you pay a Recupel contribution for goods purchased from a Belgian supplier? (322000)

For goods purchased from a Belgian supplier, the time of payment of the Recupel contributions depends on the agreement between supplier and manufacturer or importer (see payment terms), although in theory, you will pay these, together with the purchase price of the relevant goods.

3.20   What happens if the Recupel contribution changes between time of purchase and sale of an appliance? (323000)

The contribution charged with the sale of an appliance is always the contribution applicable in accordance with the appliance lists on the date of sale of the appliance, even if this contribution has changed since you bought the appliance.

3.21   What does marketing (in Belgium) mean? (330000)

The Entry agreement defines ""marketing"" as ""the action whereby the appliance imported into or produced in Belgium, whether or not new or defective, is for the first time

  • sold, rented, leased or made available, in Belgium, to a third party or
  • intended for own use This definition also implies that a Recupel contribution is owed in the following cases:
  • For local delivery to parties that benefit from special VAT exemption (e.g., tax-free shops, deliveries to international organisations, diplomats)
  • For goods delivered by a company free of charge or used for demo purposes or as a showroom model
  • For imported second-hand appliances
  • For return import of defective appliances (e.g., appliances that you have exported and that are re-imported in the framework of a warranty, when they become defective).

In the Entry agreement model applicable from 2001 until 2006 for most managing bodies, the ""marketing"" concept, referred to the time when VAT was first owed for an appliance.This implied that importers, in theory, had to submit a declaration before the time of import.

In order to avoid prepayment on the part of importers, Recupel allowed that the goods be reported at the latest at the time of sale, rental, leasing, availability, own use, etc.

The new Entry agreement establishes as a rule that the declaration takes place
taking into account the time of sale.

If, however, it is easier for you to follow up marketed appliances at the time of import, you can of course submit your declaration taking into account the import.

In the event that the importer has mandated an EEA supplier to satisfy a number of their obligations, the declaration will in theory always take place at the time of import by the Belgian buyer, if the foreign supplier takes into account their sales.

3.22   Are second-hand electrical or electronic appliances imported from abroad also subject to the acceptance obligation? (331000)

Yes, you owe a Recupel contribution, also for second-hand appliances imported from abroad. If they are discarded in Belgium, Belgium will be responsible for the recycling of said appliances.

3.23   Is the Recupel contribution required in the event of public tenders? (332000)

For public tenders, the Recupel contribution must be charged.

3.24   Do embassies and international organisations owe the Recupel contribution with the purchase of products in Belgium? (333000)

Yes, embassies and international organisations (e.g., European Commission, SHAPE) as end users must pay the Recupel contribution.

This is justified by the fact that the goods will be discarded on Belgian territory and consequently will be processed by Recupel.
However, they do not have to pay the VAT on the contribution if they are VAT exempt.

3.25   A few special cases for which no Recupel contribution is due (340000)

You do not have to pay a Recupel contribution for the following:

  • Goods you import, store in bonded or VAT warehouse and market abroad.
  • Goods you import and store in a (regular) warehouse and subsequently export abroad.
  • Goods you manufacture and market abroad.
  • For imported or produced goods:on the basis of an invoice drawn up by Recupel asbl , you will pay a Recupel contribution to Recupel asbl for electrical and electronic appliances that you import or manufacture and market in Belgium.
  • For goods purchased from a Belgian supplier: you pay the Recupel contribution to your supplier. In the relationship between supplier and importer or manufacturer, this contribution is part of the contractual price. It must therefore be clearly indicated when the contract is concluded.

3.26   To whom do you pay the Recupel contribution? (350000)

  1. For imported or produced goods:on the basis of an invoice drawn up by Recupel asbl , you will pay a Recupel contribution to Recupel asbl for electrical and electronic appliances that you import or manufacture and market in Belgium.
  2. For goods purchased from a Belgian supplier: you pay the Recupel contribution to your supplier. In the relationship between supplier and importer or manufacturer, this contribution is part of the contractual price. It must therefore be clearly indicated when the contract is concluded.

3.27   Prescription (363000)

In order not to discourage importers and producers from becoming a member of the management organisation, since the cost of the retroactive recycling contribution would become huge, a seven calendar 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.
    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 for 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.

3.28   Amount of the Recupel contribution (370000)

The amount of the Recupel contribution is, in consultation with the supervising authorities, determined by the competent Recupel sector non-profits.

These contributions are determined on the basis of calculations that take into account the number of appliances that will be marketed, the costs of pickup and processing (at least for household EEE), administrative reporting costs, etc.
You will find the amount of the Recupel contribution per appliance in the appliance list used by Recupel, see 'Appliance lists' and product search engine on www.recupel.be.

3.29   Who determines the amount of the contributions? (371000)

The amount of the contributions is determined by the Recupel sectors that have to approve every change.
Regional authorities can provide advice.

The aforementioned expert groups and Recupel have taken into account any costs for pickup, transport and processing per category of appliances as well as the products' lifespan.

3.30   What is the VAT percentage on the amount? (372000)

    • In the invoicing between the member and their customer (private party or dealer), the VAT rate on the Recupel contribution follows the VAT rate on the goods. If the latter is lowered due to a legal provision, this will also be the case for the Recupel contribution between the member and their customer. A contractor, for example, will only charge 6% to their customer if the house is older than 5 years and if the goods are built in (only a small number of electrical appliances are eligible)
    • In the event of VAT exemption for some users (e.g., international organizations) there is, however, no exemption as regards Recupel contribution. The reason for this is that the contribution is intended for the recycling of the appliance in Belgium in an environmentally friendly way, when the appliance is discarded. There is no VAT due on this Recupel contribution in the relationship between the member and these users as far as proving that they are exempt from paying VAT.
    • However, in the relationship between Recupel asbl and the member, the rate of VAT is 21% given that one does not yet know the destination of the product. Any difference between VAT rates is requested for refund by the member from the Belgian VAT administration and this by means of the VAT declaration.

3.31   Can an internet seller become member of Recupel? (372100)

Internet sellers who work from another Member State and who offer products to Belgian consumers are required to register in Belgium for VAT purposes if the selling exceeds a certain limit on a yearly basis. By way of this condition they will be seen as selling from Belgium and will need to pay Belgian VAT on their sales. Companies from other Member States who comply with this stipulation will consequently be considered as Belgian companies and can join Recupel asbl in this capacity.

3.32   VAT exemption? (373000)

VAT exemption does not lead to Recupel contribution exemption, as this contribution is paid for services rendered.

3.33   Can a discount be granted for the amount of the Recupel contributions? (374000)

No discounts can be granted on Recupel contributions.

Therefore the contribution remains unchanged even if the product's sales price is lowered.
Granting discounts to “good debtors” is not possible either.

3.34   Adjustment of the Recupel contribution (380000)

The amount of the Recupel contribution can be revised.

The aim is for appliance lists and contributions to remain as stable as possible in the coming years.

3.35   Will the Recupel contribution amount evolve in the future? (381000)

The Recupel contribution is subject to change depending on the costs for the pickup and processing of specific categories of appliances.

The appliance list is evaluated on a regular basis and consequently the amount of the Recupel contribution can be adjusted every year.

The Recupel contribution can be increased as well as lowered.

3.36   How do I know if the Recupel contribution changes for an appliance? (38200)

Recupel informs the importer or producer in a timely manner of any changes in the amount of the Recupel contribution.

  • If you submit your declaration electronically, the communication will take place electronically.
  • If you submit declarations via post or fax, we will inform you in writing of any changes in Recupel contributions.

3.37   Can you charge the Recupel contribution to your customer as a visible fee? (390000)

When mentioning the contribution to your clients you have to make a
distinction between the all-in contribution and the administrative
contribution.

With regard to the all-in contribution,
importers/manufacturers continue to pass on the all-in contribution
separately to distributors, and always state it on a separate line on the
invoice. Distributors provide clear information to consumers regarding the amount
of the contribution. To do so, dealers may make use of the poster
that they can request via the online order form (section 'Documentation'). If
the distributor instead chooses to stop mentioning the Recupel
contribution separately in its publications (leaflets, price tags, etc.),
he should state 'Recupel included'. Maximum transparency must be
safeguarded in this and the consumer must be able to consult the Recupel
contribution at all times.

With regard to the statement of the Recupel
contribution for professional appliances (administrative contribution),
the 'Recupel included' message shall be generalised. This implies that the
contribution should not be stated separately.

3.38   Can the amount of the contribution be added to the invoice, whilst it was not provided for in the offer? (391100)

It is not down to Recupel to intervene in the contractual relationship between buyer and seller.

3.40   How is the Recupel contribution mentioned in advertising brochures? (392200)

According to the legislation, the Recupel contribution is to be mentioned clearly. This means that every time a customer buys a product, he has to be able to see the amount of the Recupel contribution.

If the distributor chooses not to mention the Recupel contribution separately in his publications (leaflets, price tags), he has to mention 'Recupel included'.

3.41   Must the Recupel contribution be mentioned separately on cash register receipts? (392300)

No. It is not necessary to mention a separate amount on the cash register receipt.

It must always be clear to the customer that the Recupel contribution is included in the price by mentioning it in an obvious place in the advertising brochure and in the racks.

3.42   Is the mention of the contribution obligatory on the price tags? (392400)

No, it is not obligatory to mention the Recupel contribution separately on the price tags.

On the price tags the Recupel contribution is included in the total price.
Consumers, however, have to know exactly how much Recupel contribution is included in the price (Legislation on trade practices, 14.07.1992).
Recupel contributions are to be posted in a strategic location.

That is why Recupel launches an annual information campaign in order for points of sale to be able to inform their customers about the Recupel contribution charged with the purchase of a new electrical or electronic appliance.

3.43   When (on which invoice) and how are we to mention the environmental contribution if the installation is invoiced in various steps? (392500)

The contribution is to be mentioned at the latest on the last invoice.

The invoice reference will mostly be the project and not the product.

3.44   Application of a minimum and/or maximum total amount in accordance with article 5c of the Entry Agreement (392600)

With the implementation of the appliance list valid as of January 1st 2012 a minimum and maximum total amount is introduced for all categories of professional appliances (PRO) with an administrative contribution.

As of January 1st 2012, the annual minimum total amount per member amounts to 100 euro. The annual maximum total amount amounts to 10,000 euro.

Click here for more information on the declaration of professional appliances (PRO) with an administrative contribution with application of a minimum and maximum total amount.

esc