compliance teamThe 300 kg threshold, and what it does not exempt
Step 1
Measure combined packaging weight
Step 2
Compare against the legal wording
Step 3
Record the method
Step 4
Re-check when volumes change
| Control | Evidence to retain |
|---|---|
| Scope | Entity, product, channel, stream and source |
| External action | Version, date, authorised filer and issued receipt |
| Maintenance | Source data, approval, invoice and next deadline |
What the threshold actually measures
The threshold is expressed in the cooperation agreement as at least 300 kg of packaging placed on the Belgian market in a year, and it triggers the take-back obligation. It is assessed on combined single-use packaging, not separately per scheme.
Published scheme material and the legal text are not always phrased identically at the boundary, so a company sitting close to 300 kg should document its own measurement rather than rely on a rounded figure.
What remains below the threshold
Being under the threshold removes the obligation to join a scheme. It does not remove the information obligation, and it does not mean a company is outside the packaging framework.
It is therefore wrong to describe a small seller as having no Belgian EPR obligation. The accurate statement is that scheme membership is not required at that volume.
Keep the measurement as evidence
A company relying on the threshold should be able to show how it measured packaging weight, over which period, and for which products and channels.
That evidence is what makes the position defensible later, including if volumes grow during the year and cross the threshold.
Conclusion
Scope comes before a form. Connect the legal entity, product, sales channel and EPR stream to the rule that actually applies.
Evidence must remain traceable. Keep source data, versions, approvals, filings, receipts and every record issued by an external body.
Third-party decisions are never guaranteed. Approved schemes, public registers, the regulator and marketplaces control their own procedures, timing and decisions.