How does bol check your EPR number in 2026?

Oskar Mortensen Oskar Mortensen
10 min read

bol will take your listings offline in the Netherlands and Belgium if your extended producer responsibility duties are not covered, yet there is no field anywhere on the platform for an EPR registration number. Below are the seven categories bol gate today, the three documents they accept as proof, and the packaging check they have not switched on yet.

The bol logo in its own blue on a white panel, above an EPR registration record whose number field is empty, with a green seal on it, a taped parcel and a battery cell

By the end of this guide you will know which extended producer responsibility registrations bol will ask you to prove before they let you sell, and which ones the law asks for even though bol stay quiet about them. It is written for anyone listing on bol in the Netherlands or Belgium.

The surprising part is what bol never ask for. There is no box anywhere on the platform where an EPR number goes, and the reason turns out to be a good one.

What bol will ask you to upload

bol do not take a number typed into a form. They take a document, and which document they want depends on the role you are in.

  1. A purchase invoice for one of the items you want to list, one per product category, if you are not the party that owes the EPR fees. It shows that somebody upstream already placed those goods on the market.
  2. Proof of registration with a management organisation, if you are based outside the European Union and you do owe the fees.
  3. Proof of individual payment, if you meet your producer duties yourself instead of joining a scheme.

Two other things decide how smooth this gets. If you owe EPR fees and you pay them, bol approve you for the relevant categories automatically and there is nothing to upload at all.

The exception they name is a partner from outside the European Union without a VAT number, who can never be approved automatically and always has to apply. Applications are processed within five working days.

Why bol ask for proof instead of a number

Most large European marketplaces have a field for your EPR registration number. bol have none, and the reason is that a number is only worth collecting if the platform can check it against a register.

Two European regulations put almost word-for-word the same duty on bol, the Batteries Regulation and the packaging regulation. Both say the platform must obtain the seller's registration number and a self-certification before letting them sell. Only one of the two has a working register behind it.

The battery register rules have applied since 18 August 2025, and where a register is not public the platform is entitled to look into it free of charge. The packaging duty started later, on 12 August 2026, and the register that would answer it is not open.

What you sell The rule on bol Register status
Batteries Batteries Regulation, Article 62(6) In force since 18 August 2025
Packaging PPWR, Article 45(4) Not open yet

That gap explains the whole shape of bol's policy. Batteries is the one Dutch category they gate, and packaging is the one they say openly they are not checking.

Currently, bol does not actively enforce PPWR obligations. There is no system yet that allows us to check registrations on a large scale.

Read that as a description of the plumbing rather than as bol being relaxed. The packaging register that would issue the number bol are supposed to collect is not open, because the 18 month clock in Article 44 only starts once the Commission adopts the registration format act that was due on 12 February 2026.

Checked on 14 September 2026, the only act adopted under the packaging regulation is a delegated decision on pallet wrappings and straps, and the format act is not among them.

Two identical register entries compared, the battery one carrying an issued number and a solid seal, the packaging one with its number field and seal still empty and dashed

Six of the seven gated categories are Belgian

bol gate seven categories today. Six of them apply to selling in Belgium and one applies to selling in the Netherlands.

  1. Electrical and electronic appliances, disposable cameras and pocket lamps, for selling in Belgium
  2. Car tyres, for selling in Belgium
  3. Batteries and accumulators, for selling in Belgium
  4. HEV batteries and vehicles, for selling in Belgium
  5. Mattresses, for selling in Belgium
  6. Solar panels, for selling in Belgium
  7. Batteries, for selling in the Netherlands

That lopsided split is not a preference of bol's. Flanders wrote its own marketplace rules and did not wait for an EU register to arrive first.

Article 3.2.1.6 of Vlarema, the Flemish waste regulation, already requires whoever runs an online marketplace to do four things.

  1. Tell every producer selling through the marketplace, in writing, what their take-back obligations are.
  2. Demand written proof of scheme membership, or of an individual plan, at the moment the producer registers on the marketplace.
  3. Stop a producer from selling, on the simple request of OVAM, once the Flemish waste agency finds them in default.
  4. Send OVAM a list each year by 1 March of every producer who was able to sell through the marketplace, together with their registration number at each scheme.

There is also a price for waving somebody through. A marketplace that admits a producer with no registration has to carry that producer's EPR obligations itself, and so does one that misses OVAM's deadline to block a producer in default.

That is a solid reason for bol to want the paperwork up front rather than afterwards.

One precision worth holding on to. Belgian waste law is regional, and the wording above is Flanders'. OVAM is the Flemish agency, and it is the only authority bol name.

Not sure if you are registered in every country you sell in?

We will run a demo on a representative product and discuss your specific EPR mix.

How to get every number bol will check step by step

Five steps, in the order that saves the most time. The first two work out what you owe and get you into a scheme, the third applies only if you are not established in Belgium, the fourth is the bol application itself, and the fifth is the one nobody is chasing you for yet.

Step 1. Work out which country treats you as the producer

bol sell into two countries, and the duty lands on whoever puts an item on that country's market first. bol's own wording is that the producer is the party who first places an item on the market in the Netherlands or Belgium, and they are explicit that this can be you rather than the brand you buy from.

That is exactly why the purchase invoice route exists. An invoice from a Dutch or Belgian supplier who already paid the levy shows the duty landed before the goods reached you. Import the same item yourself and it lands on you instead.

Run the test per country and per category, because the answer moves. The same catalogue can leave you a producer in the Netherlands and a reseller in Belgium.

A crate crossing a dashed line between the world outside the market and the Dutch and Belgian market, sealed with a gold stamp at the moment it crosses

Step 2. Join a scheme for every category you sell

Each waste stream has its own organisation, and the two countries share almost none of them.

What you sell Belgium Netherlands
Packaging Fost Plus, or Valipac Verpact
Electronics Recupel Stichting OPEN
Batteries Bebat Stichting OPEN
Tyres Recytyre Stichting RecyBem
Textiles not gated by bol Stichting UPV Textiel, ERP, or Collectief Circulair Textiel
Mattresses, solar panels Valumat, PVcycle not gated by bol

bol say plainly that their own tables are not exhaustive and that the levies applying to your range are your responsibility, so treat any list as a starting point. In Belgium the packaging split matters, because Fost Plus covers household packaging and Valipac covers the commercial kind. Household packaging is the clearest pair to get right, because it is the stream almost every seller has. In Belgium that is Fost Plus and in the Netherlands it is Verpact.

You can also skip the collective route. In Belgium that means filing an individual acceptance obligation plan with OVAM, setting out how you will collect and process your own products, then reporting on how it went every year. It is a genuine option and it is more work than joining.

Step 3. Appoint a Belgian representative if you are not established there

This step catches people out because it does not appear on bol's application form at all. It sits in the Flemish regulation.

Article 3.2.1.5 of Vlarema says anyone established outside the territory who sells at a distance to private households there, directly or through an online marketplace, must appoint a representative established in the territory to meet the producer's obligations.

The mandate has to be written and in place before the products go on the market, and OVAM has to be notified immediately. That representative then carries the same obligations you would have carried.

Selling only to businesses rather than households turns this from mandatory into optional. Some schemes will act as your representative and bol point out that they are not obliged to, so ask before you plan around it. The full authorised representative process covers what the mandate has to say.

Step 4. Apply for selling rights in the categories bol gate

This is the bol part, and it is the shortest of the five.

Pick the categories from the list above that match what you sell, upload the document for your role from the first section, and wait the five working days. If you owe fees and pay them, you should find yourself approved for those categories without applying at all, unless you sit outside the European Union without a VAT number.

Approval means bol will let you list. It does not mean anybody has confirmed your registrations are complete, and bol are clear that they are legally obliged to take a range offline when a partner does not comply.

Step 5. Get your packaging registration ready before bol start checking it

Nothing on bol asks for this today. The duty is live regardless, and there is an enforcement route that never passes through bol at all.

Packaging EPR has applied under the PPWR since 12 August 2026, and Article 44 already says a producer may not make packaging available in a country for the first time unless they, or their authorised representative, are registered there. In the Netherlands that registration runs through Verpact for packaging.

In Flanders, the 1 March list bol send OVAM is built out of your registration number at each scheme, so a gap shows up there whether or not bol ever asked you for a number.

One more split matters if you use Logistics via bol. bol take responsibility for the packaging they add during fulfilment, meaning the shipping box, the tape and the void fill, because they are the party placing that packaging on the market.

Your own item packaging stays yours, registration and documentation included.

Where Repax fits before the packaging register opens

Steps 1, 2 and 5 are the same job wearing three different hats. Somebody has to know, per product and per country, what the packaging is made of, what it weighs, which stream it falls into and which scheme wants the figures.

  • The data is the hard part, not the form. Fost Plus, Verpact, Bebat and Recupel all want the same underlying facts cut a different way.
  • The cut changes per country. One crate is a single row in a Dutch filing and a different row in a Belgian one.
  • It has to hold up later. A 1 March list to OVAM and an annual scheme declaration both look back at a year you have already shipped.

Take a boxed lamp with a battery inside it. That is three waste streams in two countries, so six separate registrations sit behind one product, and this is a different six from the seven gated categories above.

An open parcel holding a table lamp and a battery cell, counted as six separate registrations across packaging, electronics and batteries in two countries

Repax Core is where that record sits. You describe each product once, and Core builds the report each market and scheme expects out of it, locking in the spec as each order ships so a filing can be reproduced years afterwards.

Try Repax Core for free - no card required Describe your products once and Core builds the report each market and scheme expects. Try it free

Core prepares the data behind a filing. It does not submit to a register for you and it does not obtain your registration number, and Repax Comply is the product that carries the filing itself.

Common mistakes about what selling rights approval means

Below are five things sellers get wrong about bol and EPR, roughly in the order they cause trouble.

  1. Reading "no field for a number" as "no duty". bol not asking is not the same as nobody asking. Both regulations put the duty on the seller whatever the platform happens to collect.
  2. Treating bol's seven categories as the list of categories where EPR applies. bol say the opposite, that other categories carry duties they simply do not check yet.
  3. Assuming clearance in one country covers the other. Registration is per country. Being fine in Belgium says nothing about the Netherlands, and the Dutch battery gate is separate from the Belgian one.
  4. Skipping the Belgian representative because bol never mentioned it. It comes from Vlarema rather than from bol's form, and it has to be in place before you sell, not after.
  5. Waiting for the packaging register before gathering the data. The register decides when somebody checks your number. It does not decide when the duty starts, and that was 12 August 2026.

Frequently asked questions about EPR numbers on bol

Below are the five questions sellers ask most often about EPR numbers on bol.

How long does it take to get an EPR number?

bol process a selling rights application within five working days. The registration behind it is the slow half, and under the packaging regulation a competent authority has up to twelve weeks to issue a number once you have given them everything they asked for.

Where do you enter your EPR number on bol?

Nowhere. bol have no field for a registration number and ask for a document instead. Which document depends on whether you owe the fees, pay them individually, or are not the producer at all.

Does bol check packaging registrations?

Not at the moment. bol state that they do not actively enforce PPWR obligations because no system exists yet for checking registrations at scale, and that they will give notice in good time before that changes.

Do you need a Belgian representative to sell on bol?

Yes, if you sell to private households in Flanders and are not established there. The mandate has to be written and in place before your products go on the market, and OVAM has to be notified straight away.

Can Repax do this for you?

Repax Core builds the packaging data and the reports each scheme asks for, so a filing is prepared rather than rebuilt from scratch each year. It does not register you and does not submit on your behalf. Repax Comply does both, across EU markets.

Written by

Content specialist at Repax.io

I translate sustainability regulations by day, chase golf balls by evening. Both involve more rules than anyone admits.