This is the question that decides everything. It has a clean, three-condition answer — and two common situations where the answer is "no".
The three conditions
You need a Belgian authorised representative when all three are true:
- You are the producer — manufacturer, importer, distributor or brand owner;
- You are not established in Belgium (no Belgian entity);
- You place packaging on the Belgian market by selling directly to Belgian end consumers.
When you need one
Amazon FBA (Pan-EU / EFN) where goods reach Belgian consumers — yes. Own website, Shopify, eBay or bol.com shipping direct to Belgium — yes. The test is where the packaging is first placed on the market, not where your inventory sits.
When you don't
Two situations clear the obligation:
- You sell to a wholesaler or importer. The importer becomes the producer and takes on the obligation — you don't need an AR.
- You already have a Belgian or EU entity. You can register directly — no authorised representative needed.
No minimum volume. The AR obligation applies from the very first package you ship to a Belgian consumer. It is not gated by a sales threshold.
Not sure where you fall? Send us your sales model — we'll confirm it in a day, free of charge.
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