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Am I a producer?

The definitions of “producer” are not formulated in exactly the same way in the three region’s but they always mean the same thing, namely a producer is any natural person or legal entity who is the first to bring mattresses onto the Belgian market or intends them for their own use. This can therefore be a mattress manufacturer as well as an importer, distributor or final seller.

This also applies to online sales or other forms of distance selling by non-Belgian companies to Belgian private individuals.

Care centres, holiday centres, nursing homes .. also fall under the heading ‘producer’ if they import mattresses from abroad.

Am I an importer?

A producer is any natural or legal person who is the first to bring mattresses onto the Belgian market. This can therefore be a mattress manufacturer as well as an importer, distributor or final seller.

This also applies to online sales or other forms of distance selling by non-Belgian companies to Belgian individuals.

Care centres, holiday centres, nursing homes ... also fall under the heading ‘producer’ if they import mattresses from abroad.

I am a foreign producer and I sell mattresses in Belgium. What should I do?

Are you a foreign company that exports and sells mattresses in Belgi&umuml;, then as importers, your Belgian customers have a take-back obligation.

However, as a foreign supplier you can take over the administrative modalities of the take-back obligation of your customers in Belgi&umuml;. You then join Valumat yourself and you make an annual declaration of the number of mattresses that you place on the Belgian market.

However, as an importer your Belgian customer remains subject to the take-back obligation. Your Belgian customers must therefore demonstrate to the regional authorities that their foreign supplier declares these mattresses to Valumat. They must therefore “mandate you”. This can be done via a “mandate form.

What are the contributions?

When you join Valumat you pay an annual contribution.

Valumat's general assembly has set the following contributions for 2025:

  excluding VAT including VAT

Children mattresses, excluding crib and cot mattresses*

€ 3.51

€ 4.25

Mattresses and toppers** ≤ 120 cm

€ 7.02

€ 8.50

Mattresses and toppers** > 120 cm

€ 14.05

€ 17.00

* Children mattresses: mattresses of 70 x 140 centimetres maximum, excluding crib and cot mattresses. Crib and cot mattresses are mattresses with a height of less than or equal to 40 mm and with a total surface area of 0.8 m2 maximum.
** Mattresses: products intended for sleeping and resting, suitable for human use for a long period of time, consisting of a strong cover, filled with core materials, and which can be placed on an existing supporting bed structure, including toppers. A topper is a thin mattress with a maximum thickness of ten centimetres that is placed on top of the normal mattress.

Comments on environmental contributions

  • The contributions are calculated in such a way that the income covers the expected expenses.
  • The Valumat contribution only applies to batches that come onto the Belgian market. Mattresses that are exported do NOT fall under the Valumat system.
  • A VAT percentage of 21% applies to the Valumat rates.
  • The contribution may vary over time, depending on the development of costs.
  • The general assembly of Valumat fixes the contributions annually. The aim is to always inform participants as soon as possible about any changes.
Why should I join Valumat?

Are you subject to the take-back obligation for mattresses as a producer or importer? Do you get lost in the red tape that entails the implementation of this obligation?

No problem, join Valumat:

  • Valumat takes a tedious task off your hands.
  • With Valumat, you fulfil your take-back obligation in an efficiënt manner.
  • You do not have to arrange the physical return of the old mattresses from your customers.
  • Companies that choose the individual option must draw up an individual take-back obligation plan and submit it for approval to OVAM. The plan describes how the company organises the selective collection and processing. The company must also take the necessary preventive measures and report annually on the implementation of the plan. This is a cumbersome and labour-intensive task if you have to do it yourself.
  • You do not need to demonstrate any collection and recycling percentages to the authorities.
  • You do not need to raise awareness among users either.
  • The professional Valumat team helps you with free advice when preparing your declaration.

Valumat then takes over the practical modalities of your take-back obligation. In this way, you comply fully with your legal obligations. In all three regions.

How do I join Valumat?

If you are subject to the take-back obligation, you can easily join the Valumat system. 

We call producers and importers of mattresses who join the Valumat system “participants”. To this end, they sign a membership agreement.

Can I join Valumat retroactively at a later date?

If a producer or importer joins the Valumat system at a later date and they have already brought mattresses onto the Belgian market in 2021 and cannot demonstrate that they complied with the legislation through an individual plan, then upon entry into the Valumat system, the contributions will always be charged from 1 January 2021, the date of the entry into force of the take-back obligation.

In this way Valumat wants to avoid discrimination with regard to companies that have been affiliated with Valumat from the start of their activities and have therefore always paid their contributions.

By joining retroactively, you also avoid any fines for not individually complying with your take-back obligation.

Which companies are also affiliated with Valumat?

Wondering which companies are participating in the Valumat system for the implementation of their take-back obligation?
Check the list here.

How do I make my annual declaration?

Annually you report to Valumat about the number of mattresses that you have brought onto the Belgian market via an online application. We call this the annual “declaration”.

Valumat expects the first declaration of the number of mattresses on the market in 2024 by March 31, 2025 at the latest.

For the following years, the deadline is always on March 31 of the year following the reference year. Then the actual quantities of mattresses on the market of the previous year are known. 

Your declaration step by step

  • At the beginning of each calendar year Valumat sends you an invitation by e-mail to fill in your annual declaration with a unique code.
  • You follow the instructions to log into the application.
  • On the validation screen, you fill in the unique code and your e-mail address.
  • An automatic e-mail with a link is generated and sent to your e-mail address.
  • Then click on this link to fill in your declaration and follow the instructions on the screen.

 

What are the environmental contributions for?

A significant portion of the contributions serves to reimburse the costs of the use of the recycling centres, the transport and processing of discarded mattresses. Valumat reimburses final sellers for voluntary collection and the professional market for collection via an approved collector.
In addition to the operating costs, Valumat also provides a budget for research and development into an easily dismantlable and recyclable mattress.

Do I have to join Valumat to comply with the take-back obligation?

As a producer or importer, you can individually fulfil your legal obligations. However, this is a complex, costly and time-consuming matter.

You can also join Valumat that as a collective system implements the terms and conditions of the take-back obligation of its participants. This way you comply with your legal obligations. In exchange, you pay Valumat an annual contribution.

Where can I find the regulations on the take-back obligation?

Importer or producer of mattresses in Belgium? Do you want to know more about the legislation? Consult the legal requirements applicable in the 3 regions (Flanders, Walloon Region and Brussels-Capital Region) and Europe.

The Flemish Region

Decree on the sustainable management of material cycles and waste of 23 December 2011.

The decision of the Flemish Government of 17 February 2012 establishing the Flemish regulations concerning the sustainable management of material cycles and waste.

Take-back obligation covenant.

The Walloon Region

Décret relatif aux déchets of 27 June 1996.

The decision of the Walloon Government of 23 September 2010 to introduce a take-back obligation for certain waste materials.

Environmental Policy Agreement

The Brussels-Capital Region

Ordinance relating to waste of June 14, 2012

The decree of the Government of the Brussels-Capital Region of 1 December 2016 on waste management.

Environmental Policy Agreement: being negotiated.

 

When does Valumat invoice the environmental contributions?

Invoicing contributions and payment terms 2025-2026

In April 2025, Valumat sends a settlement of the past year (2024).

The settlement is the difference between the actual contribution for 2024 (see 2024 declaration) and the advances already invoiced and paid for 2024. 

This invoice is payable within 30 days.

Valumat sends the advance invoice for 2025 to the participants at the same time. The total advance financing is calculated as follows: number of mattresses placed on the Belgian market in 2024 multiplied by the rates of 2025.

25% of the amount is due at the end of May, 25% is due at the end of August and 25% is due at the end of November 2025.

This means that each year participants only have to pay 75% of the advance financing due for 2025 in 2025. The balance of 25% will be settled in April 2026 together with the settlement for the year 2025. The 2025 settlement is the difference between the actual contribution for 2025 and the advances already invoiced and paid for 2025. 

This ensures that the pre-financing for the participants is limited and that the totality of the VAT charged can be immediately recovered.

Click here for the timeline of declaration, invoicing and payment.

Do I have to pass on the environmental contributions to my customers?

Participants in the Valumat system pass on the contribution defined by Valumat to their customersfrom 1 January 2021. On invoices between professionals (with VAT number, B2B) the contribution must be visibly displayed on the invoice. This can be done via a text line (including environmental contributions) or with explicit mention of the amount of the environmental contributions.

For sales to consumers (B2C) it is not necessary to specify this contribution on the invoice or receipt, but it is allowed. Ultimately, the environmental contribution is included in the total price of the mattress and paid by the consumer. The consumer can be informed via other means of communication (e.g. posters, price labels in the shop, mention in advertising brochures, etc.) that his total price includes the environmental contribution.

B2B invoicing options:

  • per invoiced item, stating the amount
  • grouped stating (total) amount
  • per invoiced item or grouped stating "environmental contributions included"

Click here for more information about legislation and pricing to customers (B2C).

How will the contribution be accounted for and how will it be included in the VAT return?

For the sake of clarity, it is the producers, the importers, who must join the Valumat management body. For each mattress put on the Belgian market by the producers, importers, they have to charge an environmental contribution. Be it to an end customer user (consumer/hotel/hospital/prison....) or to a wholesaler, vendor who will in turn pass on the contribution to the end customer.

For producers/importers, the environmental contribution to be charged is not included in the purchase and sale price. The environmental contribution and its VAT must therefore be charged to customers on top of the normal selling price and must be included in the VAT return as a supply of services. The collected contribution is subsequently transferred by the producers/importers to Valumat. Valumat will send an annual invoice for this.

The collection and transfer of the environmental contribution can be accounted for in various ways.

  • A first option is to first book the collection of these contributions as revenue (class 7) and to provide an "invoice to be received" (class 6) at the end of the financial year for the payment of the environmental contribution to Valumat. The Valumat management organisation will then request the contributions collected by the producer/importer via invoice at the beginning of the following year.  This invoice balances the accrued commission "invoices to be received".
  • A second option is to book the collection of this environmental contribution to a waiting account (class 4), as is done for VAT. The contributions are then considered as invoiced and collected amounts that do not belong to the company, but as an amount that is 'set aside'. Producers/importers report the quantity of mattresses they place on the market at the beginning of the following year. On the basis of this declaration, the management organisation Valumat will charge the environmental contribution. The contribution charged by Valumat balances the account on which the contributions collected by the producer/importer were booked. The difference between the total environmental contributions invoiced in the financial year and the turnover to be found in the accounts will have to be explained when the VAT turnover agreement is drawn up.
What guarantees does the Valumat system offer?
  • You comply with your legal obligations so you avoid fines.
  • You benefit from a flexible and clear system that has the recognition of the regions and sectoral federations concerned through the environmental policy agreements.
  • The costs are simple to budget.
I produce or import mattresses and sell them to my customer wholesaler, who in turn exports them. Do I have to pay a contribution to Valumat for this?

At the time of the sale from the producer or importer to the broker, it is not always clear who the ultimate user of the mattress will be.

Does your customer export the mattresses purchased from you? Then this customer can fill in a “declaration on word of honour export”.

You can deduct the quantities stated on this declaration from the quantities that you have placed on the Belgian market when completing your annual declaration.

Exports are taken to mean the physical shipment of mattresses outside Belgian territory that give rise to an exemption from VAT, to be stated on the invoice, in accordance with Article 39 (supplies outside the EU) or Article 39a (intra-Community supply), as defined in the value added tax code.

Foreign consumers who buy mattresses in Belgium do pay the contribution.

I export mattresses produced or imported by myself. Do I have to pay a contribution to Valumat for this?

No, you do not have to pay a contribution to Valumat on this. Your annual declaration only pertains to the mattresses that you have produced or imported to put on the Belgian market.

Exports are taken to mean the physical shipment of mattresses outside Belgian territory that give rise to an exemption from VAT, to be stated on the invoice, in accordance with Article 39 (supplies outside the EU) or Article 39a (intra-Community supply), as defined in the value added tax code.

Are the participants' declarations audited? What about declarations made on their honour?

The regulations in the three regions require Valumat to audit the participants' declarations or have these audited. This will be done by an external party designated by Valumat and at the expense of Valumat. Valumat will also conduct audits on “declarations made on the participants' honour”.

As a producer, do I also have to pay an environmental contribution for mattresses that are delivered free of charge to a showroom or that are sold through outlets or to staff?

It makes no difference whether mattresses are delivered for free or against payment. In both cases, they remain mattresses which are placed on the market. They are therefore subject to a contribution, insofar as they are sold in Belgi&umuml;.

I buy mattresses that I bring out under my name on the Belgian market. (Private label). Can I ask my supplier to take over my administrative obligations towards Valumat?

If you, as a company, have mattresses produced for marketing under your own name (Private Label) on the Belgian market, then you have a take-back obligation. You must then either join the Valumat collective system or submit a waste plan yourself to the regions where you market your mattresses. This must be done in accordance with applicable regional legislation.

However, you can also mandate your supplier, if he agrees, to include the amount of mattresses he has delivered to you under your name (Private Label) in his annual declaration to Valumat. You still remain ultimately responsible, which means that you must be able to demonstrate that your supplier has taken over your obligations.

You can mandate multiple suppliers at the same time. You can do this via a mandate form.

What is the difference between an environmental contribution and a tax?

The contribution which participants pay Valumat is not a tax.

A tax or charge is imposed by the government and laid down in legislation.

The contribution to Valumat serves to cover the costs associated with the implementation of the take-back obligation. The general assembly of Valumat determines the contributions annually.

The regional authorities must approve the contributions.

If a foreign retailer delivers to a Belgian consumer, under which EPR does that sale fall, the Belgian or the foreign one?
  • If a Belgian consumer buys a mattress in a physical shop of a retailer abroad, he is subject to the legislation of that country and therefore pays the applicable EPR contribution there. The foreign producer is not subject to a take-back obligation in Belgi&umuml; and therefore does not pay a contribution to Valumat.
  • If the Belgian consumer buys a mattress online from a foreign retailer, the foreign shop is subject to a take-back obligation because of its sales activities in België. It must then join Valumat and pay a contribution to Valumat for the mattresses which it places on the Belgian market.
What about old slatted frames, box springs, cots. Are there rules about these too?

This take-back obligation only applies to mattresses and therefore not to box springs, sofa’s, the slatted bases and cots. There may still be an EPR for furniture in the future, but that is not yet specifically addressed.

Is it true that we are not obliged to state in our catalogue that the Valumat contribution is included?

In connection with communication to the consumer (as is also the case for other waste flows subject to a take-back obligation), the following is provided: “In accordance with article 3.2.1.1, §7 of VLAREMA, the end seller will affix a notice in a clearly visible place in each of its sales outlets upon which it indicates under the heading “TAKE-BACK OBLIGATION” how it complies with the provisions of chapter 3 of VLAREMA and how the buyer can dispose of his discarded mattress. The consumer must also be informïed of this when selling takes place outside a sales area (e.g. online).” It is therefore recommended that the notice “Valumat contribution included” is provided in your catalogues (e.g. with a *).

When do retailers/importers (B2C) on the one hand and on the other hand producers/importers (B2B) charge the Valumat contribution?

The definition of producer is not exactly the same in the three regio’ns. In the definition, placing products “on the market” is also described as, “selling”, “marketing”, “reselling” and “trading”.

It is generally assumed that the contribution is charged when a mattress is invoiced: when an invoice is issued to a Belgian, it is placed on the Belgian market.

Please note: producers and importers also pay a contribution if for some reason an invoice is not drawn up and the mattress is placed on the Belgian market.

As a producer, can I get compensation if I collect discarded mattresses from my customers?

As a producer, you are also entitled to compensation of € 600 /ton for the discarded mattresses that you collect from your customers. Please note: in that case, your customer will not receive any compensation.

The same terms and conditions apply as for final sellers and professionals:

  • You have the discarded mattresses collected by an homologated Valumat collector.
  • The type of mattress falls under the scope of the take-back obligation.
  • You store the mattresses in a dry and secure environment.
  • You agree on the modalities and costs of collection in mutual consultation with your collector.
What about environmental contributions and discounts?

The environmental contribution is independent of the sale price of mattresses. So there are no discounts on environmental contributions.

What about the contribution on sofa beds?

When the filling is an integral part of the furniture and cannot be removed without damaging the furniture and resulting in it no longer having its original function, this filling is not considered a mattress.

If the mattress can be seen separately from the furniture, is removable and replaceable, it is considered a mattress and a contribution must be paid on this.

I am selling a box-spring bed with 2 mattresses and a topper. How much is the contribution?

You pay an environmental contribution on the 2 mattresses and on a topper, which means three times the environmental contribution at the applicable rate.

I sell covers and cores separately. Do I have to pay a contribution for these?

Covers and cores are not covered by the definition of mattresses. Therefore, no contribution has to be paid on these. It is the party that puts together a mattress using covers and cores that will place the mattress on the market and is therefore subject to a take-back obligation and will have to pay the contribution.

How can I integrate Valumat contributions into my ERP package?

Here you will find a document with several suggestions for integrating Valumat contributions into your ERP package. Of course, every software package is different. This document therefore presents a number of options on how you can approach integration and what aspects should be taken into account.

Eco-modulation of the environmental contributions

The environmental contributions determined by Valumat are uniform contributions that are not differentiated according to the circularity of the mattresses. However, Valumat has set itself the objective of switching to eco-modulation in the relatively short term, i.e. the environmental contribution will in the future be determined in function of the possibility of dismantling of the mattress and the recyclability of the dismantled materials.

Which EBL001 code should be added for Valumat in my EDI system?

Code 044 is used for the Valumat contribution in EDI systems that work in the 'Harmonised order to cash' (EAN) format. See full list here.

Do you use recommended retail prices?

Legally speaking, the environmental contribution must be included in the total price to be paid by the consumer. This applies both to prices indicated by retailers in their shops and to any recommended retail prices (which also include VAT and other taxes and costs) that producers suggest for sales in Belgium. However, this does not apply to purchase prices where the Valumat contribution is invoiced separately.

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