Register as an operator of an online marketplace

Specifically, you must first register as an online marketplace with Recupel. This is only possible if you:

• have a Belgian establishment and a Belgian VAT number;

• or, for foreign online marketplaces, if you have appointed an authorized representative with a Belgian registered office, as required by both European and Belgian regulations. 

Next, an Entry Agreement  must be signed, which outlines the commitments between the online marketplace and Recupel.

The affiliation procedure explained, step by step

Below, we will go through the affiliation procedure and the necessary documents you must provide if you wish to become member of Recupel as an online marketplace:

• You submit a request for affiliation as an online marketplace and confirm the business details, contacts, and product categories you wish to register for by sending the signed confirmation letter to Recupel.
• After receiving the request for affiliation, Recupel will contact you to:
  • verify your request for affiliation as an online marketplace.
  • request the details of the person authorized to sign the Entry Agreement
  • request the details of the authorized representative if you are located abroad
  • request a list of the sellers (name and VAT number) for whom you assume the EPR
• You receive an email with the Entry Agreement and sign the agreement through the online signing platform used by Recupel.
• You receive an email with the agreement signed by both parties.
• Then, you will receive an email with your username and a link to create a password to access Recupel's online declaration portal.

• In the quarterly declaration, you confirm per product category the quantities of EEE put on the Belgian market and returned abroad, and if requested the weight (for professional appliances), for all sellers active on the sales platform for whom you assume the EPR. With each quarterly declaration, you attach the list (Excel or PDF) of all sellers stating company name and VAT number.
• The declaration contains two columns:
  • Appliance brought to market: here you declare, per product category, the number of household and professional appliances that all sellers for whom you assume the EPR have imported or produced and which are subsequently destined for the Belgian market.
  • Returnable: here you request a refund of the Recupel contributions you paid to Recupel for appliances put on the market that were subsequently returned abroad by consumers or end users (e.g. under the legal right of withdrawal or the seller's ‘return policy’).
• The reported quantities per product category will be invoiced based on the Recupel contributions listed on the appliance list  applicable at the time of sale.
• At least once a year, upon request from Recupel, you must provide a list with the details of the quantities sold in Belgium per category and per seller for whom you assume the EPR.
• Annually in January, you must report the collected discarded EEE taken back from the market in the WEEE report.

The operator of an online marketplace must inform the sellers active on its sales platform that they are required to indicate on their invoices to end users/consumers that the Recupel contribution has been paid for the appliances in question and is included in the price, by stating "Recupel contribution included". 

This notification "Recupel contribution included" must be transparantly stated on any means of communication where the price of an appliance actually purchased by the consumer/end user is mentioned.

You can only assume the EPR for sellers offering electronics via your sales platform for direct sales to private individuals or end consumers in Belgium. As the operator of an online marketplace, you should not report sales to resellers or distributors, nor sales outside of Belgium.

If you, as the operator of an online marketplace, are also a producer and sell electronics in Belgium under your own name, you must register separately as a producer/importer with Recupel.

The affiliation as ‘online marketplace’ is only meant if you want to assume the EPR for the sellers operating in Belgium via your sales platform.

Recupel regularly performs checks on the quarterly declarations of all its members, including online marketplaces. After submitting a declaration, you may be contacted to verify whether the quantities are correct and whether the correct product categories were applied. Recupel also checks the list of sellers added to the quarterly reports to prevent double declarations.

A more detailed audit can be scheduled in consultation with the online marketplace. During this type of audit, Recupel will perform a more in-depth control on elements such as:

• the method used to verify the sellers active on the sales platform for their affiliation with Recupel
• the method used to link the articles to the correct product categories of the Recupel appliance list
• the method used to calculate the quantities to be declared for all sellers for whom the EPR is assumed
• the list with the details of the quantities sold in Belgium per category and per seller for whom the EPR is assumed

More information can be found in the Entry Agreement under article 6. The audit itself and the examination of the documents received are always performed confidentially. Recupel only reports consolidated declarations of all its members to the authorities.

The new legislation takes effect from 29.03.2025 and from that date onwards, as an online marketplace, you can assume the EPR if you wish. There is no obligation for online marketplaces to do so for periods prior to 29.03.2025. Recupel can contact sellers to retroactively declare if they were selling EEE on the Belgian market before 29.03.2025 without being affiliated to Recupel or having an individual waste management plan.

Any deviations from the above must always be approved by Recupel.