PPWR / REGISTRATION & REPRESENTATION

Belgian EPR Representative: Who Needs a Mandate?

First identify the legal duty and the producer. “Authorised representative” can refer to different appointments: PPWR packaging EPR, equipment-related WEEE duties or product-safety work. One contract label does not prove that all of them are covered.

Belgium: assess the foreign producer and route

Fost Plus’s September 2026 guidance says foreign producers without a Belgian establishment must mandate an authorised representative for producer registration. Confirm that the company and activity fall within the described producer situation. Prepare the selling entity, establishment, end-user or distributor route and relevant packaging records.

Define the mandate in writing

The mandate should identify the producer and representative, country, stream, applicable duties, start date and duration. Set out registration, reporting, data provision, approval and change-notification responsibilities. Check the actual requirements with the relevant body; do not assume that every action can be delegated in the same way in every country.

Check the evidence behind a representation claim

Ask for the representative’s legal identity and establishment, a countersigned mandate and a task list. Separate the producer’s register evidence from any registration or recognition concerning the representative. Where dated scheme guidance and current authority material are inconsistent or unavailable, obtain current confirmation before treating a specific administrative condition as mandatory.

Keep other streams and GPSR separate

BelComply’s EPR representation concerns PPWR within the agreed scope. Equipment and batteries need their own assessment; packaging paperwork alone does not establish those arrangements. GPSR product-safety and EU responsible-person services are independent and are not included in EPR. Ask for each service and its responsibilities to be named explicitly.

Related questions

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