compliance teamSelling to a Belgian business customer
Step 1
Establish what the buyer does
Step 2
Distinguish resale from use
Step 3
Allocate the packaging
Step 4
Document the allocation
| 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 |
Resale as supplied moves the obligation
Where a Belgian customer imports packaged goods and resells or distributes them as supplied, that customer is normally the packaging responsible for them.
This is the ordinary business-to-business position, and it is the case published scheme guidance describes when it says a foreign company has no Belgian packaging responsibility.
Professional end users are a different case
A business that uses the product rather than reselling it as supplied can be an end user. Under the European regulation that distinction matters for who counts as a producer.
The label "B2B" does not by itself settle the analysis; the question is whether the Belgian recipient resells the product as supplied.
Industrial packaging follows separately
Transport packaging supplied to a business customer sits in the industrial scheme, which has its own membership and declaration.
A company with both consumer and business flows therefore has two files rather than one.
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.