1. Operation of the IRPC

1.1. Tasks of the IRPC

The tasks of the IRPC include the following:

1

Monitoring whether companies (parties responsible for packaging, aka “responsible companies”) and accredited compliance organisations are fulfilling their reporting and take-back (i.e. recycling and recovery) obligations.

2

Checking the way in which the responsible companies and accredited compliance organisations meet their statutory recycling and recovery targets.

3

Approving or rejecting prevention plans of companies (responsible companies).

4

Granting or refusing accreditation to the organisations responsible for promoting, coordinating and financing the selective collection, recycling and recovery of packaging waste.

5

Assisting and advising the regional governments, for example by creating consultative forums, providing logistical support or proposing legislative amendments.

6

Conducting or commissioning studies and research into the management and prevention of packaging waste.

7

Processing transit notifications in order to issue approval for planned shipments of waste that does not originate from Belgium and will not be treated there either. Additionally, processing individual shipment notifications relating to an approved notification.

1.2. Composition of the IRPC

The composition of the decision-making body in 2025:



Flemish Region

Full members:
- Ann De Boeck
- Nick Vliegen (until 30/01/2025) / Roeland Van Roosbroeck (since 31/01/2025)
- Anneleen De Wachter (Chair since 05/03/2025)
Alternate members:
- Luc Goeteyn
- Roeland Bracke (until 30/01/2025) / Anne D’Haese (since 31/01/2025)
- Christof Delatter (until 30/01/2025) / John Wante (since 31/01/2025)



Brussels-Capital Region

Full members:
- Marion Courtois
- Céline Schaar
- Stéphanie Uny
Alternate members:
- Valérie Verbrugge
- Stéphanie Thomaes
- Milan Jousten



Walloon Region

Full members:
- Lara Hotyat (until 29/01/2025) / Thomas Leroy (since 30/01/2025)
- Vincent Brahy (until 29/01/2025) / Sylvie Meekers (since 30/01/2025)
- Martine Gillet (until 29/01/2025 and Chair until 29/01/2025) / Jean-Yves Mercier (since 30/01/2025)
Alternate members:
- Guillaume Lepère (until 29/01/2025) / Manuel Mengoni (since 30/01/2025)
- Marie-Hélène Lahaye (until 29/01/2025) / Eloïse Pignon (since 30/01/2025)
- Jean-Yves Mercier (until 29/01/2025) / Diego Wauthelet (since 30/01/2025)

The organisational structure of the Permanent Secretariat in 2025:

Marc Adams

Departments under the Director

LINDA VANDEN BROECKE

HEAD OF DEPARTMENT

General Affairs

and Upstream External Audit Department

QUENTIN MATHOT

HEAD OF DEPARTMENT

Accreditations, Declarations and

Internal Audit Department

CAROLINE AURIEL

HEAD OF DEPARTMENT

Prevention, Research, Downstream External

Audit and Transit Department

1.3. EPR and Litter Cooperation Agreement

The IRPC acts as secretariat for the Extended Producer Responsibility Interregional Platform (EPRIP), which was created in 2009 with the aim of developing a common understanding on extended producer responsibility (EPR).

In 2025, the EPRIP worked hard on the new Interregional Cooperation Agreement on Extended Producer Responsibility (EPR) and Litter. This was finally adopted on 9 February 2026. On the one hand, this agreement establishes an interregional framework for dealing with streams other than packaging waste that are subject to the principle of EPR. On the other hand, it passes on the costs of litter to those responsible for generating these waste streams.

This new Cooperation Agreement incorporates the EPRIP into the IRPC, creating the new “Interregional Commission for EPR”, which will comprise two sections: the “Packaging decision-making body” and the “EPR decision-making body”. This new incarnation of the IRPC will be known as “EPRiBEL”.

As well as finalising the Cooperation Agreement, work continued on preparing the implementing cooperation agreements required to apply the EPR part of the aforementioned Cooperation Agreement.

1.4. Packaging and Packaging Waste Regulation (PPWR) and International cooperation (EUNR.org)

Packaging and Packaging Waste Regulation (PPWR)

Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC, was published on 22 January 2025.

This Regulation (hereinafter referred to as the PPWR) entered into force on 11 February 2025 and sets out new provisions for preventing and reusing packaging. It largely replaces existing Belgian legislation, specifically the Cooperation Agreement of 4 November 2008 on the prevention and management of packaging waste.

The PPWR will cover the entire life cycle of packaging and packaging waste. New Belgian legislation must ensure that this Regulation is implemented by 12 August 2026 at the latest.

A brief overview of the five key elements of the PPWR:

1. Sustainability requirements and recycled content in packaging

The PPWR tightens up existing rules for substances present in packaging by imposing restrictions on placing on the market food contact packaging that contains excessive levels of PFASs.

The Regulation also imposes an obligation to introduce a reporting system on hazardous substances. In addition, it introduces minimum recycled content targets for several categories of plastic packaging. For example, single-use plastic beverage bottles must contain a minimum percentage of recycled content of 30% by 2030, and 65% by 2040. Contact-sensitive packaging made from PET as the major component must also contain 30% recycled content by 2030, and 50% by 2040.

2. Prevention targets

The PPWR sets incremental targets per capita for each Member State to reduce the amount of packaging waste, with a 5% reduction by 2030, 10% by 2035 and 15% by 2040, compared with 2018.

The Regulation also sets a maximum empty space ratio of 50% in packaging and requires manufacturers to minimise the weight and volume of packaging.

3. Reuse targets and refill obligations

The PPWR sets binding reuse targets for 2030 and indicative targets for 2040, depending on the type of packaging and taking into account certain exceptions. Cardboard packaging is generally exempted from these new rules.

Take-away businesses will also have to offer their customers the option of using their own containers at no additional charge, and by 2030 must endeavour to offer 10% of products in packaging formats suitable for reuse.

4. Deposit return systems

The Member States must set up a deposit return system for single-use plastic bottles and metal beverage containers by 2029 at the latest, unless they can demonstrate that at least 90% are collected separately and recycled.

5. Restrictions on certain packaging formats

The new rules introduce restrictions on certain packaging formats, including:

• single-use plastic packaging for fruit and vegetables;

• single-use plastic packaging for food and beverages (filled and consumed on the premises), condiments and sauces within the HORECA sector;

• single-use plastic packaging for small cosmetic and toiletry products used in the accommodation sector (e.g. shampoo or body lotion bottles);

• very lightweight plastic carrier bags, except for very lightweight plastic carrier bags required for hygiene reasons or provided as sales packaging for loose food to prevent food wastage.

For Belgium, this will mean some significant changes. For example, there will no longer be a national definition of “responsible company” or “producer”; instead, there will be a uniform European definition of “producer”. The current Belgian term “responsible company” and its corresponding definition will therefore be scrapped.

This is not just a change in terminology; there are also substantive changes. For instance, a company currently classified as a “responsible company” may no longer be considered a “producer” under the new Regulation. Conversely, companies that were not previously classified as “responsible companies” may now suddenly come under the definition of “producers”.

International cooperation (EUNR.org)

The new Packaging Regulation fundamentally changes the legal framework governing packaging and packaging waste, and this new legislation raises a great many questions. For this reason, several public authorities within the EU Member States, which are or will be responsible for the register of producers and the annual reports of producers and PROs (producer responsibility organisations) have come together to form a new organisation: EUNR (European National Registers for Packaging). The IRPC is one of the founding members of the EUNR and is actively involved in its activities.

This new organisation already represents 16 Member States and is open to any other national organisation involved in registration.

The PPWR is harmonised European legislation. Because of this, only official guidance or implementing acts from the European Commission – supplemented by common positions among the Member States – can provide the clarity businesses need to navigate the legislation. The EUNR aims to be a key point of contact for the European Commission and has already interacted with it on several occasions. The EUNR seeks to provide answers to the questions businesses face in applying the PPWR.

In the context of the PPWR, international cooperation goes beyond the EUNR. The IRPC is active in various other international forums. Furthermore, it is responsible for coordinating Belgium’s position when the European Commission is drafting implementing acts.

International cooperation represents a significant new workload for the IRPC’s Permanent Secretariat, but also provides a unique opportunity to influence the European decision-making process, the first results of which we are already seeing.

Clarification of the definition of “producer”

💡

This decision tree is a simplification and doesn’t give a full picture of the “producer”. It should be used with care.

Does the packaging become waste in the EU member state?

✘ No producer in that member state according to PPWR

✔

Is the manufacturer⁽²⁾ of the complete (empty) packaging or the packaged product based in this member state (domestic)?

✔ Yes

The manufacturer(2)is the producer, because there is no one else before in the supply chain.
for transport, service and primary production packaging: Manufacturer(2)of the complete(empty)packagingin its final form
for sales and grouped packaging: Manufacturer⁽²⁾of the packaged product

✘ No

Is there another company in the Member State that opens the supply chain?

✔ Yes

The first company in the domestic supply chain (“national importer”⁽¹⁾, distributor) is deemed to be the producer.

✘ No

Is a delivery made directly from abroad to the end user of the product?

✔ Yes

The foreign company is the producer.

⁽¹⁾“national importer” means “the one who makes packaging/packed products available for the first time from within the territory of that Member State”

(2) or the “importer” (as defined in the PPWR), in case the manufacturer is outside of the EU.