FAQ

Yes, if you’re a postal service provider responsible for the delivery (A) of parcels (B) in Belgium (C) by parcel delivery workers (D).

The law applies to you if all 4 criteria A, B, C and D are met.
It doesn’t apply if at least one of these criteria isn’t met.

The delivery (A) of a parcel, also known as ‘last-mile delivery’, is the phase from sorting at the distribution centre to delivery of the parcels to the recipient. This includes preparing the route, loading the parcels onto the vehicle, transporting them and delivering them to the specified address. The company sending the parcel doesn’t deliver the parcel itself. (For more information, please refer to the question What does ‘self-delivery’ mean?).

The parcel (B) is a parcel delivery:

• with a delivery address,
• that weighs a maximum of 31.5 kg,
• which contains permitted goods with or without commercial value (no correspondence),
• with closed packaging.

In Belgium (C), the law applies to companies

• that deliver parcels in Belgium, even if the delivery has started in another country;
• that deliver parcels which are distributed from Belgium and are destined for abroad.

Parcel delivery workers (D) are natural persons who deliver parcels for a postal service provider or one of its subcontractors, regardless of their professional status. This law therefore applies to parcel delivery workers who are employees (including students whose curriculum provides for employment), self-employed or self-employed assistants.

Self-delivery isn’t covered by the Parcel Delivery Act. Companies operate ‘self-delivery' when they exclusively deliver their own goods via their own network. In other words, via their own infrastructure and their own employees or temporary workers.

Please note: A company which, in addition to delivering goods via its own network, also delivers goods from third parties is subject to this law.

No, if you’re an entrepreneur who sells products via an online shop and uses external parcel delivery services for delivery, you don’t fall within the scope of this law.

Please note: This legislation applies well to the postal service providers who carry out the delivery for you.

No, if you’re an entrepreneur and you sell your own products via an online shop and deliver them to your customers yourself, you’re not subject to this law.

Please note: This only applies if you as a company only deliver your own products and do not deliver parcels for third parties.

No, if you as a food business or restaurant deliver your own food, ready-to-eat meals or partially prepared meals, this law doesn’t apply to you as it falls under the ‘self-delivery‘ exemption.

If, as a food business, you do not deliver yourself but instead commission a network of subcontractors, this law doesn’t apply to you either.

Note: This law does well apply to subcontractors who deliver for you.

If you, as a pharmaceutical company, commission subcontractors who deliver for you, this legislation doesn’t apply to your pharmaceutical company.

Subcontractors are subject to this legislation as they provide postal services on behalf of third parties.

You have your own parcel distribution network and your own staff to deliver your own goods and your field of activity consists of delivering parcels from other companies? If so, you’re subject to this legislation for all your parcel deliveries

(i.e. both your own parcels and those of other companies).

You have your own parcel distribution network and your own staff to deliver your own goods.

You only deliver your own products and do not deliver products from third parties. If so, you are not subject to this legislation.

The Parcel Delivery Act only covers the delivery of individual parcels.

If you also deliver individual parcels in addition to transporting bulk goods in boxes (mixed transport), you fall under the Parcel Delivery Act for this part of your activity and are required to register your company as a ‘last-mile parcel delivery service’. In this case, all other obligations under the Parcel Delivery Act (e.g. the time registration obligation, the half-yearly report, etc.) only apply to your partial activity as a last-mile parcel delivery service.

These are postal items, not parcels. Therefore, the delivery of newspapers and magazines to newsagents isn’t subject to the Parcel Delivery Act.

Delivery ‘behind the door’, such as unpacking and installation, are separate services from distribution. Delivery to the front door is subject to the legislation. To reflect this correctly in the time registration, the BELparcel online service offers the ‘Add interruption’ function. This interruption is registered for the time spent ‘behind the door’ for additional services or for breaks.

You offer a parcel delivery service as intermediary (commission agent). As such, you’re subject to the Parcel Delivery Act and all associated obligations. Please find an overview of all obligations on the page ‘What obligations does the law impose? From when?’.

The Parcel Delivery Act only applies to the ‘last mile’ parcel delivery phase. Note, however, that both companies are subject to the obligations of the Parcel Delivery Act, as they both offer parcel delivery services. The company that transports the goods to the distribution centre in this example falls under the legislation as principal because it commissions its logistics partner to deliver the parcels over the last mile. In this example, the logistics partner is subject to the legislation as a subcontractor that carries out the order.

You won’t get your fee back unless you’ve paid twice. The fee covers the costs for your registration as a parcel delivery service.

Have you stopped working as a parcel delivery service? Request a cancellation of your registration by sending a message to notifbelparcel@bipt.be.

If you want to be sure whether you’re subject to the legislation or not, please submit your question via our contact form. If you’re not subject to the legislation, you will receive a confirmation. You can present this to your principal as proof. If you’re subject to the legislation, you’re obliged to register.

If you and your logistics partner provide postal services for the delivery of parcels, you’re both subject to the Parcel Delivery Act. You as principal and your logistics partner as subcontractor.

To check whether the Parcel Delivery Act applies, it’s advisable to check your company's delivery model in detail. Do you still have questions? Please use our contact form.

You can appoint the transport manager if he has one year of experience in postal services.
Postal services include collecting, sorting, transporting and distributing postal items.

Persons with similar functions, such as transport managers or prevention advisors, can also qualify as a coordinator. People in positions that require a certain level of safety management and responsibility, such as transport planners, fleet managers or operations managers, can also be appointed as coordinator.

The authority doesn’t produce model due diligence plans. This is because the included information is specific to the company in question. A link to the FPS ELSD website doesn’t fulfil the requirement to draw up a due diligence plan.

If you’re self-employed and deliver parcels on your own account, you don’t have to appoint a coordinator. If you’re self-employed and work alone, but pass on some of your orders to other parcel delivery workers who act for you as subcontractors, you have to appoint a coordinator.

You provide the name and contact details of the coordinator via My BELparcel (undefined).
This is done as part of the half-yearly reporting obligation.

In addition, the name and contact details of the coordinator must be easily accessible to your parcel delivery workers at all times.

You don’t have to pay anything for submitting the half-yearly report. You only pay a one-time fee when you register. You can find out more on the page What data should I register?

Your company has a choice of two tools to create the half-yearly report:

1. the half-yearly report module in the BELparcel online service
2. the web service, which you can integrate into your own systems

You can find information on how to create the half-yearly report on this website under the menu item ‘How does it work?’ in the submenu ‘Half-yearly report’. Please read the How do I create the half-yearly report page.

Here you will find the graphical instructions for configuring the BELparcel web service and the instructions for half-yearly reporting via the BELparcel online service.

Yes, It’s the company that employs the temporary workers - not the interim office - that is responsible for the time registration of the parcel delivery workers.

On the BELparcel online service, you designate temporary workers with the status ‘employee’.

Yes, you must perform daily time registration for your employees/parcel delivery workers in this case. In fact, all parcel delivery service providers are required to perform time registration.

On the BELparcel online service, you do these registrations in the capacity of ‘subcontractor’ and leave the ‘principal’ zone blank.

The time to be recorded starts from the departure of the transport of the parcels concerned by the regulations until the moment when the transport of these parcels ends. This time includes the transport and delivery of other types of freight that the parcel delivery worker carries out at the same time.

If the tachograph obligation applies, the obligation to register parcel distribution times doesn’t apply.

If your own systems meet the legal requirements, you may register parcel distribution times with your own systems in the currently ongoing first phase.

In this case, the parcel delivery worker should register the time separately for each principal.

The registered parcel distribution time doesn’t include work that you do outside the parcel distribution time. Registration should only include the daily parcel distribution time. However, the total working hours have to be shown on the payslip, not just the parcel distribution time. The employee receives remuneration for the entire working time.

The parcel distribution time includes the periods between the start and end of parcel distribution. In Belgium, it is calculated as follows:

• from the time the transport starts at the place where the parcel delivery services begin,
• to the time when the transport ends at the place where the parcel delivery services end.

The parcel distribution time doesn’t include

• loading and unloading of parcels
• maintenance of the means of transport
• breaks
• installation of the delivered goods
• ...

Parcel distribution time starts the moment the vehicle transporting the parcel sets off from its point of departure (in this case, the sender's address).

It doesn’t matter whether a parcel is picked up directly from the sender or from a distribution centre.

Your principal isn’t required to pay you a higher minimum hourly rate.

The driven kilometres are part of the calculation for the minimum remuneration.
This minimum hourly rate reflects a realistic average. Transport economists in consultation with various Belgian interest groups from the transport and logistics sector determined this average. However, this legislation doesn’t prevent you from negotiating your remuneration. Details on the calculation of the minimum remuneration for parcel delivery workers serve as a reference for your negotiations. You can find them on the page Minimum remuneration for parcel delivery workers.

The minimum hourly wage has to be respected at every level of the supply chain.

It’s a payment per worked hour.

You’re, of course, free to negotiate a better remuneration with your principal. After all, you’re not only working as a parcel delivery worker, but also as a subcontractor.

The aim of the legislation of 17 December 2023 is to ensure that every parcel delivery worker, as the last link in the parcel distribution chain, can work under optimal conditions and benefit from the social security to which they’re entitled.

Read all about the calculation of the minimum remuneration for parcel delivery workers on the page Minimum remuneration for parcel delivery workers.

If you transport parcels for which a licence is required, you will have to hold a national or Community road haulage licence in accordance with Article 6/1, §3, No. 1 of the Postal Act. The licence is issued per company, but all vehicles have to be listed on the licence to ensure compliance. You have to pay a deposit for this licence, the amount of which depends on the number of vehicles.

The possession of this licence falls under the broader Postal Act and isn’t a specific part of the Parcel Delivery Act.

According to Belgian legislation (in French), you don’t need this permit, if your vehicle has a maximum payload of 500 kg and the maximum authorised mass doesn’t exceed 2.5 t. Belgium has lowered the threshold from 3.5 t to 2.5 t provided for in Regulation 1071/2009 (undefined).

If this applies to you, please mention this in your additional contact details.

For more information about the road haulage licence, please refer to the FPS Mobility and Transport website (undefined).