Last updated on December 2, 2011
RECUPEL is the Belgian WEEE system in charge of take-back obligations for producers and importers of electric/electronic products on the Belgian market. Recupel was launched in Belgium in 2001, well ahead of August 13, 2005 mandatory EU implementation date, and was one of the first such organizations to become operational in Europe.
The Recupel website, which also has an English version, has very detailed information on all aspects of the WEEE history, legislative context (European, and 3 Regions in Belgium), take-back obligation, electrical and electronic sectors covered with a listing of products in each sector, registration procedure for importers and manufacturers, foreign suppliers, etc.
Belgium WEEE legislation information is only available in Belgium's national languages (French and Dutch) and is available on the www.recupel.be site.
WEEE legislation is fully implemented in Belgium, and companies selling electric and electronic products on the Belgium market must be able to prove they are meeting their take-back obligations. Currently, the only option for companies is to join a local take-back scheme (Recupel).
Currently, there is no national registration for WEEE compliance at the federal government level. In Belgium, administrative procedures related to the environment are dealt by the three regional authorities. Manufacturers and importers that have not registered with Recupel through an Entry Agreement have theoretically the option to submit their own waste management plan to the relevant regional Belgium authorities: Wallonia - DGRNE (OWD), Flanders - OVAM and Brussels - IBGE. However, government registration through the regional authorities is not possible at this stage since the Belgium regional authorities currently are not set up to take registrations. Consequently, there are no deadline dates set up for registration with the Belgium government authorities, and companies currently have no other choice than joining a collective system (Recupel).
Registration with a collective system to fulfill legal take-back obligations:
Producers and importers should register with Recupel as the simplest way to fulfill legal take-back obligations in Belgium, as long as their products fall into one of Recupel's current sectors and listing of products. Please see: Recupel site
Only the listed product lines are handled by Recupel and associated take-back organizations. This list of product categories is updated every year.
Belgium allows foreign companies to register but not to shoulder legal obligations. The local company is liable for legal obligations since the U.S. firm does not have a VAT number. If a company has a local office in Belgium and/or local customer putting the product on the Belgian market, the local office/customer is the one to register with Recupel. However, a foreign supplier may be mandated by a Belgian importer to fulfill its take-back obligations in Belgium. A form is available on the Recupel website.
Recupel contact information:
Belgium implemented the RoHS directive into its legislation in October, 2004, well before the guidance document was published in May 2005.The Belgian law is aligned on the EU law definition, except for the definition of "put on the market". Any banned product on the shelf of a store after July 1st. 2006 even if sold by a U.S. firm beforehand is liable of fines.
What are the fines for breaking the law?
Considerable. Prison from 8 days to 3 years. Penalty fees approximately from 160 Euros to 4 Million Euros.
Enforcement: as of July 1st, 2006
Federal Ministry of Public Health and Environment
Contact: Mr. Denis Pohl
SPF Santé Publique, Sécurité de la Chaîne Alimentaire et Environnement
Place Victor Horta 40, Bte 10
B-1060 Brussels, Belgium
Tel: +32 (0)2 524 95 51
Fax: +32 (0)2 524 96 01
Belgium RoHS legislation
For a copy of the Belgian legislation in English please contact Commercial Specialist Stephane Croigny at Stephane.firstname.lastname@example.org
For further information, please contact:
Stéphane Croigny, Commercial Specialist
tel: +32 2 811 5086