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The European Packaging and Packaging Waste Regulation (PPWR) will come into force on 12 August 2026. This Regulation will replace the Belgian term “verpakkingsverantwoordelijke”/”responsable d’emballages” (responsible company, i.e. party responsible for packaging) with a new, uniform European term: “producer”. A producer is similar to a responsible company, but the two terms are not entirely identical. Each is defined differently. For more information on the new definition of “producer”, please see the explanatory note, which you can access via this link.

To help companies correctly identify the “producer”, a simplified document entitled “The responsible producer for EPR in the Member State” has also been developed. The producer can usually be identified quickly using the decision tree in this document. You can access the simplified document via this link.

In Belgium, the impact of the new definition, in terms of identifying the company subject to extended producer responsibility (EPR) for packaging, varies depending on the type of company.

For companies that are currently Type A responsible companies, the situation will generally change only to a limited extent, with most existing responsible companies also becoming producers in the future. Only responsibility for “rigid” transport packaging, such as pallets used to transport products, will be transferred to the Belgian manufacturer of this packaging, if one exists. However, if the current Type A responsible company orders its pallets from abroad, it – and not the foreign manufacturer of the pallets – will remain the producer in the future.

For companies that are currently Type B responsible companies, the situation will not usually change, with most existing responsible companies also becoming producers in the future.

Similarly, current Type D responsible companies will also almost always become producers.

The biggest change concerns current Type C responsible companies, which operate only in the industrial and commercial packaging sector. In most cases, these companies will no longer be producers. Instead, their foreign supplier will become the producer. Nevertheless, former Type C responsible companies will continue to have a responsibility: to act diligently and avoid using “illegal packaging”. Article 44(4) of the European PPWR stipulates that producers are not permitted to make packaging available on the territory of a Member State if they are not registered to do so in that country. In most cases, registration will be carried out through the future producer responsibility organisations (the current accredited compliance organisations).

We therefore strongly advise Type C responsible companies to contact their supplier as soon as possible, urging them to join an accredited compliance organisation in Belgium or a producer responsibility organisation (PRO) authorised by Belgium, and to do so before 12 August 2026. For industrial and commercial packaging, the accredited compliance organisation Valipac is currently the only option.

Belgian manufacturers of “rigid” transport packaging, such as pallets, should also start preparing now for their future producer responsibilities.

It is important to note that the legislation will change in mid-2026. This means that both the former responsible company and the new producer will have to submit a declaration to the accredited compliance organisation or the authorised PRO for that same year: specifically, the former responsible company will report on all packaging placed on the market up to and including 11 August 2026, and the new producer on all packaging placed on the market on or after 12 August 2026.