Key Environmental Reporting for Businesses

What you need to know

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Companies are required to submit various environmental reports and declarations on a regular basis. These obligations depend on the sector, the size of the company and the environmental impact of the activities. Below is a non-exhaustive overview of the most important obligations.

Table of contents

Integral Environmental Annual Report

The Integrated Environmental Annual Report (IMJV) is an annual report that companies are obliged to submit to the Flemish government. This report must be submitted by 14 March and contains aggregated data on the company’s environmental impact.

The data from the IMJV are used by the Public Waste Agency of Flanders (OVAM), the Flemish Environment Agency (VMM), and the Flemish Energy and Climate Agency (VEKA) for European and international reporting obligations.

The online IMJV window is used to submit the report, which includes data on air emissions, energy consumption, water emissions, groundwater use, waste management and production volumes, in addition to general data. Which parts need to be filled in depends on the specific business activities.

Groundwater consumption and waste water discharge levy

Both individuals and businesses have to pay a fee for wastewater treatment and groundwater use. Companies are often large consumers and must submit a declaration of their (ground) water consumption by 15 March each year via the digital levy counter. In January, bulk users receive the declaration letters with access codes for the counter.

Companies can opt for a calculation based on measurement data of the discharged wastewater (measurement campaign by an approved laboratory) or for a flat-rate calculation method (sector-specific conversion coefficients).

Companies with their own wastewater treatment usually opt for the calculation based on measurement data, because this option is often more advantageous than flat-rate charges.

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Waste

Waste processors

OVAM has developed the Materials Information System (MATIS), which monitors the production of waste and follows the recycling process and its application in new products.

All companies classified under category 2: the collector of industrial waste (IHM), the collector of household waste, the waste processor and the storage and transhipment of waste report waste data every quarter (31 May, 31 August, 30 November, 28 February) via the digital portal.

Waste producers

All companies that produce waste – but are not waste processors – are obliged to keep a register of the waste generated. This is updated monthly with the most recent data.

The waste register contains the following information:

  • Date of production or disposal
  • Mode of transportation
  • Quantity (tonnes)
  • Nature and composition of waste (EURAL code)
  • Description of the waste or an indication of its quality
  • Method of processing or application
  • Nature of the waste operation
  • Details of the collector, waste dealer or broker
  • Details of the processor's establishment unit

Packaging

Every company that places packaged products on the Belgian market is obliged to inform IVCIE (Interregional Packaging Commission) annually about the quantity, type and recycling rate of the packaging.

Take-back obligation

For companies that put more than 300 kg of packaging waste on the Belgian market, fixed recycling and recovery percentages must be achieved to fulfil the take-back obligation.

As a company, you can take matters into your own hands and submit your packaging declaration online. This is only feasible if you are packaging manager C (unpacking products) or if you organise the take-back of packaging waste from your customers yourself.

Especially the latter is not easy, which is why you can also join an accredited organisation that will take over the formalities from you. For commercial packaging, you can call on Valipac and for household packaging on FostPlus.

Duty to inform

Companies that place packaged products on the Belgian market must inform IVCIE annually about the quantity, type and recycling rate of the packaging.

As with the take-back obligation, you can also choose to comply with this legal obligation as a company itself or to engage a recognised body for this.

Prevention

Companies that place more than 300 tonnes of single-use packaging on the Belgian market or have goods packaged with at least 100 tonnes of single-use packaging must draw up a prevention plan.

This plan, which must be submitted every three years, sets out the measures to reduce or prevent primary, secondary and tertiary packaging waste. The prevention plan may include qualitative or quantitative measures, as well as measures that promote reuse.

The prevention plan must be submitted through the professional federation or the IVCIE, with deadlines of 28 February or 31 March respectively.

Batteries

A company that places batteries and/or products containing batteries on the Belgian market remains responsible for those batteries when they are discarded, because of the legal framework for taking back the batteries. This take-back obligation includes a series of obligations that must be met: registration, collection and recycling.

For batteries ≤ 20 kg, only an environmental contribution is paid. For larger batteries (> 20 kg) an administrative fee is charged which does not include the collection and recycling costs.

Through Bebat‘s Mybatbase portal, an online declaration can be done. For sales of less than 10,000 batteries per year, annual declarations must be made by 28 February, while for larger numbers, monthly reports must be made.

And it doesn't stop there

These are certainly not all environmental administrative obligations. There are still numerous situations where competent authorities must be notified or reports must be kept available for the licensing authority.

Situations that are best not lost sight of:

  • Special conditions in an environmental permit regarding emissions to air, water and soil
  • Exceeding emission limit values
  • Inspections of boilers, warehouses, tanks ...
  • Environmental coordinator's annual report
  • Soil surveys
  • Renewal or regularisation of environmental licence
  • VOC emissions
  • ...

Stay on top of your environmental obligations, otherwise the only waste you may be looking at is that of your administration. Need help? Contact us!

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