Does your company work with waste electrical and electronic equipment (WEEE)? Then sooner or later, the question arises: do we need to report through BeWeee or not?

The answer depends on your role in the chain. Producer, distributor, collector, reuse centre, recycler or exporter: each role comes with its own obligations.

One report, depending on your role

Whatever your role — or combination of roles — you only submit one report. That report can consist of four parts:

1. What did I place on the market?
2. What did I receive?
3. What did I process myself?
4. What did I not process myself or prepare for reuse?

Not everyone needs to complete every section. That depends on the role(s) you indicate. What matters is that everything entering the chain also receives a destination.

What is your organisation’s role?

Producer

Do you place electrical or electronic equipment on the Belgian market? Then you are considered a producer.

• Do you have an agreement with Recupel or PV Cycle? Then you report to them.
• Do you operate individually? Then you report through BeWeee for the entire chain: from put-on-market to the collection and treatment of WEEE. 

Distributor

Do you buy appliances in Belgium and resell them? Then WEEE falls under an acceptance obligation.

• Do you have an agreement with Recupel or PV Cycle? Then you report to them.
• No agreement? Then you report through BeWeee on the devices you take back and their destination.

Reuse centre

Do you prepare collected devices for reuse? Then your obligations depend on what you accept.

• Do you only accept devices that are potentially reusable after visual inspection? Then, in Flanders, no registration as collector/dealer/broker for WEEE or waste treatment permit is required.
• Do you also accept devices that are not reusable after visual inspection? Then legal obligations do apply.
• Do you dismantle or depollute these devices as well? Then you must also report as a recycler.
• Are you an Approved Recupel Recycler or a reuse centre with a Recupel agreement? Then you report to Recupel.

Collector, dealer or broker

Are you active as a collector, dealer or broker of WEEE? Then you must be registered in Flanders or officially recognised in Brussels or Wallonia.

• Do you work on behalf of Recupel or PV Cycle, or are you an Approved Recupel Recycler? Then you report to them.
• In all other cases, you report through BeWeee.

Recycler

Do you depollute WEEE and send it for further treatment? Then you need a permit.

• Do you work on behalf of Recupel or PV Cycle, or are you an Approved Recupel Recycler? Then you report to them.
• In all other cases, you report through BeWeee.

Exporter

Do you export WEEE abroad?

• Is this done on behalf of Recupel or PV Cycle? Then you report to them.
• Are you the notifier for other WEEE streams? Then reporting through BeWeee is mandatory, including treatment results.
• Do you export second-hand electrical or electronic equipment? Then reporting through BeWeee is strongly recommended. This helps Belgium achieve the European collection targets.

Important: from 2025 onwards, WEEE can only be exported with prior notification.

Received a letter from BeWeee?

Receiving a letter from BeWeee does not automatically mean you need to report. First check whether your situation actually falls under BeWeee.

You must report if:

• your company is registered as a collector, dealer or broker with OVAM
• your company has a permit for WEEE treatment
• you exported WEEE last year via notification
• your company is recognised as a collector in Brussels or Wallonia

You may ignore the letter if:

• your company is a municipality or intermunicipal organisation
• you have a distribution agreement with Recupel and report everything to them
• you are an approved reuse centre with a Recupel agreement
• your company is an Approved Recupel Partner and reports everything to Recupel
• the WEEE you collected, treated or exported was exclusively on behalf of Recupel

When do you submit a zero report?

Are you a collector of mixed waste, construction waste or scrap metal and do you refuse WEEE through a strict acceptance policy? Then, in exceptional cases, a WEEE device may still appear during sorting.

These devices are considered waste generated from your own treatment process. You then dispose of them separately via Recupel, a registered WEEE collector or an authorised recycler. In that case, a zero report is sufficient.

Conclusion

BeWeee reporting may seem complex, but the basic principle is clear: your role determines your reporting obligation.

Do you have an agreement with Recupel or PV Cycle? Then you will usually report to them. In all other cases, BeWeee is often the correct platform.

Still unsure? Check your registrations, permits and agreements first. That is always the best starting point.