BeWeee is the Belgian online reporting tool developed in collaboration with OVAM (Flanders), DSD - DGO3 (Wallonia), and Brussels Environment (Brussels-Capital Region) to allow you to comply with your reporting obligations. Europe wants to hear from all Member States how many appliances have been put on the market and how many waste appliances have been collected and recycled. For this purpose, producers of EEE, distributors of EEE, and the collectors, traders or brokers of waste, re-use centres, processing facilities, and notifiers of WEEE must all submit annual reports via the BeWeee tool.

  • Terminology
  • Registration of users and companies
  • Reporting obligations and relevant legislation
  • Abroad and other regions
  • Sources of legislation

Terminology

What is EEE?

EEE stands for electrical and electronic equipment and is defined as follows: Equipment which, in order to work properly, is dependent on electric currents or electromagnetic fields, and equipment for the generation, transfer, and measurement of such currents and fields, that are intended for use with a voltage rating not exceeding 1000 volts for alternating current and 1500 volts for direct current.

This definition does not apply to the following equipment:

  1. Equipment which is necessary for the protection of the essential interests of the security of Member States, including arms, munitions, and items intended for specific military purposes;
  2. Equipment which is specifically designed and installed as part of another type of equipment that is excluded from or does not fall within the scope of the take-back obligation, and which can fulfil its function only if it is part of that equipment;
  3. Filament bulbs;
  4. Equipment designed to be sent into space;
  5. Large-scale stationary industrial tools;
  6. Large-scale fixed installations, except any equipment which is not specifically designed and installed as part of these installations;
  7. Means of transport for persons or goods, excluding electric two-wheel vehicles which are not type-approved;
  8. Off-road mobile machinery made available exclusively for professional use;
  9. Equipment designed solely for the purposes of research and development that is only made available on a business-to-business basis;
  10. Medical devices and in vitro diagnostic medical devices, where such devices are expected to be infective prior to their end of life and cannot be disinfected, and active implantable medical devices.

For an explanation of what the definition of EEE includes or excludes, please refer to the EWRN “Guidance Papers” www.ewrn.org

What is WEEE?

WEEE stands for waste electrical and electronic equipment and is defined as follows: Waste EEE includes all components, sub-assemblies, and consumables that are part of the product at the time it is discarded.

What is a producer of EEE?

The producer of EEE is in fact the first party with a VAT number that puts an appliance on the Belgian market. Therefore, the producer may be an importer of EEE.

The legislation defines a producer of EEE as follows: a producer is any natural or legal person who, irrespective of the selling technique used, including distance selling, and in accordance with the Act of 6 April 2010 on Market Practices and Consumer Protection:

  1. is established within the territory and manufactures a product under its own name or trademark, or has a product designed or manufactured which it markets within the territory under its name or brand;
  2. is established within the territory and resells a product produced by other suppliers under its own name or brand. In doing so, the reseller will not be regarded as the producer of the product if the producer’s mark, as referred to in point (a), appears on the product;
  3. is established in the territory and professionally markets a product;
  4. is located outside the territory and sells a product through distance selling directly to private households or users other than private households in the territory.

A person who exclusively provides financing through or pursuant to a financing agreement and who does not bear the advantages and disadvantages of ownership will not be deemed to be a producer of the product unless they also act as a producer as referred to in points 1 to 4;

What is a distributor of EEE?

A distributor of EEE is any natural or legal person in the supply chain who places EEE on the market. A distributor of EEE may at the same time be a producer of EEE as defined above.

What is household waste EEE?

Appliances intended for use by private households (even if they are used by a company) are always classified as household WEEE. Computers or refrigerators are always household WEEE even if they are used in a company.

The legislation defines household WEEE as follows: Household WEEE is waste EEE from private households and waste EEE from commercial, industrial, institutional and other sources which, because of its nature and quantity, is comparable to that from private households. Waste from EEE that is likely to be used by both private households and users other than private households will, in any case, be considered as household waste EEE;

This means that if the appliance is intended for use by private households it should be classified as household EEE.

What is professional waste EEE?

Professional waste EEE is all waste EEE that cannot be considered as household waste EEE, such as a refrigerated counter or a server.

What are the categories of EEE?

Electrical and electronic equipment is classified into the following 6 categories:

  • category 1: temperature exchange equipment;
  • category 2: screens, monitors and equipment containing screens having a surface greater than 100 cm2;
  • category 3: lamps, including LED lamps;
  • category 4: large equipment (any external dimension more than 50 cm);
  • category 5: small equipment (no external dimension more than 50 cm);
  • category 6: small IT and telecommunication equipment (no external dimension more than 50 cm).

For further information on what category is applicable to a specific appliance please refer to “sources legislation”.

Registration of users and companies

Why do I need to register?

You need to register your company before you can submit reports. You only need to register your company once; in the following years, you will be able to complete or change your data at any time. Through registration, we know what company the report concerns and who the contact person is. The list of registered producers of EEE is published online.

Please keep your details up to date, for example in the event of a change of address or contact person!

What do I need to register as a producer or importer of EEE?

  1. Contact details.
  2. In the case of an authorised representative, also the contact details of the producer being represented;
  3. The company registration number of the producer of EEE;
  4. The category to which the EEE belongs, as referred to in Article 3.4.4.2;
  5. The type of EEE: household or professional equipment;
  6. Information about how the producer complies with its responsibilities, either individually or through a collective scheme, including information about financial security;
  7. The sales techniques used, e.g. distance selling;
  8. A statement that the information provided is accurate.

How do I add a company?

You should first register your own company. Once completed, you can add another company.

Why do I have to submit reports?

European Directive 2012/19/EU on waste electrical and electronic equipment has been transposed into regional legislation by the three regions. This Directive specified new reporting requirements for (waste) electrical and electronic equipment, including (waste) photovoltaic solar panels. In this way, we can form a picture of all the EEE and WEEE in circulation on our market. Your reports help us to build a picture of all the EEE and WEEE in circulation on our market and to comply with our reporting obligations to Europe.

Who should submit reports?

Anyone who collects, trades, brokers, exports, processes, or prepares for re-use any waste EEE is obliged to submit reports on this. This obligation also applies to waste streams collected and processed outside the Recupel system, the PV-Cycle system, or a producer with an individual waste prevention and management plan. Distributors of EEE who do not cooperate with a Recupel or PV-Cycle contractor are also obliged to submit reports on this.

In addition, each producer of EEE, including importers, is obliged to submit reports on the quantities of EEE that have been put on the market and waste EEE received under the take-back obligation.

If you work with Recupel, PV-Cycle, or a producer with an individual waste prevention and management plan, submit reports directly to them. For example, anything that you already report in the Recupel REP tool does not need to be reported again via BeWeee.

What if my company has different roles?

In that case, you must submit reports for each of these roles (producer of EEE, distributor of EEE, registered collector, trader or broker of waste, re-use centre, processor, or exporter).

Reporting obligations and relevant legislation

What if I report all EEE and/or WEEE via Recupel, PV-Cycle, or a producer with an individual waste prevention and management plan?

In that case, you must continue to submit reports to them and not via BeWeee. If you also dispose of a part of the EEE and/or WEEE via other channels, you are obliged to submit reports about this in BeWeee.

Do I also have to submit reports if I dispose of everything to a Recupel contractor, PV-Cycle, or a producer with an individual waste prevention and management plan?

Yes, if you dispose of EEE to a Recupel contractor, PV-Cycle, or a producer with an individual waste prevention and management plan but do not submit reports to them, you must submit reports on these quantities of waste EEE via BeWeee. To put it simply, you must submit reports on everything, but you do not have to report things twice (for example, both via the Recupel REP tool and via BeWeee).

As a distributor of EEE, what should I include in the reports?

Any WEEE that you, as a distributor of EEE, have accepted from your customers. You must submit reports on the quantities and destinations for each category of EEE that you have collected.

As a producer (or importer) of EEE, what should I include in the reports?

All of the EEE that you, as a producer of EEE, have put on the Belgian market for the first time. You are the first with a Belgian VAT number who buys the EEE or you are a foreign company and sell to private users through distance selling. With regard to the collectors and processors that you have a contract with, you must submit reports on the quantities of each category of WEEE that has been taken off the market, the destinations for this WEEE and what the processing results are.

As an authorised representative, what should I include in the reports?

If a company is established abroad and sells directly to users (private households or businesses) through distance selling, the foreign company is the producer or importer of EEE. In this case, the producer is obliged to appoint an authorised representative in Belgium. This authorised representative takes over the obligations of the producer, which means they are obliged to submit reports. You must tick that you are an authorised representative and which producer it concerns. The authorisation must be uploaded as an attachment.

As a collector, trader or broker of waste EEE, what should I include in the reports?

All WEEE that you, as a registered collector, trader, or broker of WEEE, have collected, traded, or brokered on Belgian territory and the destinations of this WEEE.

As an exporter of EEE, what should I include in the reports?

All waste EEE collected in Belgium that you export outside Belgium. As an exporter, you are also responsible for the achievement of the objectives by the foreign processor. You must request the processing results from the foreign processor and also complete the report as a processor.

As a processor of (W)EEE, what should I include in the reports?

All waste EEE that you, as a processor, have received from Belgium, the processing results of what you have processed yourself, and the destinations of what you have not processed yourself.

As a collector, trader, broker or processor of waste, can I submit reports on behalf of my customers?

Yes, that is possible. You have to make clear contractual agreements about who will submit the report. You can then upload an attachment to BeWeee stating for which data you submit reports and for which companies, which means we avoid double counting. Legally, your customers remain responsible for submitting the reports.

As a re-use centre of EEE and/or WEEE, what should I include in the reports?

All quantities of WEEE that you as a re-use centre have collected in Belgium to prepare for re-use, the quantities that were eventually prepared for re-use, and the quantities that were finally sent elsewhere for further processing.

Do I have to submit reports on the export of EEE?

As a producer of EEE, you should deduct these quantities from the quantities that you have put on the market. The exported quantities of EEE are no longer on the Belgian market. Please note that you must submit reports on these quantities of EEE in the tool of the respective Member State where they have been put on the market. As a notifier, you must also submit reports on the quantities that you export, and you are responsible for the achievement of the objectives by the foreign processor. You must request the processing results from this processor and also complete the report as a processor.

Abroad and other regions

As a Flemish company, do I have to submit reports on the WEEE that I have collected in the other Regions?

Yes, you must submit reports on all WEEE that you collected in Belgium, regardless of whether you are located in another Region or country.

Do I have to submit reports on the WEEE I have collected abroad?

No, you should only submit reports via BeWeee on the quantities that you have collected in Belgium. You will have to submit reports on the quantities collected abroad in the national register of the relevant EU Member State.

Do I have to submit reports if my company is not established in the territory?

Yes, you have to submit reports on all WEEE that you have collected in Belgium, regardless of your place of establishment.

Do I also have to submit reports if I import second-hand EEE and put it on the Belgian market?

Yes, you are then a producer of EEE and must submit reports on these quantities.

Do I have to submit reports on the export of EEE?

As a producer of EEE, you should deduct these quantities from the quantities that you have put on the market. The exported quantities of EEE are no longer on the Belgian market. Please note that you must submit reports on these quantities of EEE in the tool of the respective Member State where they have been put on the market. As a notifier, you must also submit reports on the quantities that you export, and you are responsible for the achievement of the objectives by the foreign processor. You must request the processing results from this processor and also complete the report as a processor.

Sources of legislation

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