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The environmental contribution for home batteries starting in 2022: frequently asked questions

The environmental contribution for home batteries starting in 2022: frequently asked questions

2021 saw an unprecedented rise in the number of home batteries installed. If you contributed to this as well, as a manufacturer, importer or installer putting batteries on the Belgian market, then you know that you have to comply with the legal take-back obligation. That means you have to take back the batteries at the end of their life and you are responsible for all aspects related to processing and recycling.

But the longevity of home batteries has meant that until now, those concerns were something for the distant future, and you had to determine how you wanted to prepare for this: "Do I already charge the future processing costs to the customer now or will I pay them myself later?"  

This situation is now about to change, as Bebat introduces an environmental contribution for Energy Storage Systems (ESS or home batteries) as of 1 January 2022. As a Bebat participant you will need to pay this contribution at the time when the battery enters the market and not when it is taken back in the future.  

This new scheme undoubtedly raises a lot of questions for you: 

  • So what exactly is changing? 

  • Why an environmental contribution?  

  • How much is the environmental contribution?  

  • How does the new declaration to Bebat work? 

  • Does this imply any change to the take-back obligation? 

  • Are consumers aware of this?  

Read on, and you will find all the answers in this article.

What will change with the introduction of the environmental contribution for home batteries?

From a limited administrative contribution to a comprehensive environmental contribution

As you undoubtedly know, until now you had to pay an administrative contribution of 0.057 EUR (excl. VAT) per battery for batteries over 20 kg. This fee covered the costs associated with prevention, awareness-raising, communication and reporting, but did not include collection, dismantling and recycling. To cover those costs, you could conclude an individual tailor-made contract with Bebat and set aside provisions for future costs. This is the so-called "pay-as-you-collect" system.

Under the new scheme, the old system of administrative contributions and individual contracts will disappear to make way for an environmental contribution (similar to that for batteries ≤ 20 kg). This environmental contribution is calculated per kilogram.

The old scheme prior to 1 January 2022 

The new scheme as of 1 January 2022 

Administrative contribution per battery. It covers:  

  • prevention
  • awareness-raising
  • communication
  • reporting 

Environmental contribution per kilogram.. It covers:  

  • prevention
  • awareness-raising
  • communication
  • reporting
  • collection
  • dismantling
  • recycling

An individual contract with Bebat could be drafted based on the needs for:  

  • collection
  • dismantling
  • recycling 

No individual contract.

The processing costs to be paid at the end of the life cycle, upon collection of the battery. Environmental contribution to be paid at the beginning of the life cycle, i.e. when the battery enters the market.

 

Why is the environmental contribution introduced for home batteries?

The solution to unclear schemes and financial surprises in the future

The request to introduce an environmental contribution for home batteries came from the sector itself. Until now, there was no clear scheme for the take-back of waste home batteries, resulting in difficult situations on the market. Companies that were prepared for the future and had already charged the processing and recycling costs to the end customer had a competitive disadvantage compared to companies that were not thinking ahead, which will get into trouble in the future when they are faced with processing costs that they never passed on to the customer as part of the take-back obligation. There was a risk that, due to the take-back obligation in force, companies would not only have to take back the batteries they sold by themselves but also those of other players who are no longer active at that time.

Thuisbatterij living

Therefore, there was a need for a clear scheme. With the new environmental contribution, every company that manufactures or imports home batteries and puts them in Belgium on the market will pay an environmental contribution per kilogram. 

Transparency is key, as the environmental contribution must be visibly stated on invoices to professional customers with the amounts indicated. You can also charge the contribution to end customers, as a separate category on the invoice. This way, all parties involved are certain that no unexpected costs will follow later on.

Which batteries are subject to the environmental contribution?

The environmental contribution is introduced for energy storage batteries weighing up to and including 200 kg that are connected to a decentralized electrical power production facility, regardless of where they are installed (ESS or Energy Storage Systems). In other words, it applies to the well-known lithium-ion or saltwater-based* "home batteries".  

Batteries that are primarily used for backup purposes, so-called UPS batteries, are not subject to this scheme.

* For lead-based home batteries, the administrative contribution continues to apply.

What are the rates of the new environmental contribution and what costs are covered?

Rates per kilogram cover the costs related to the collection, dismantling, processing and recycling of home batteries

Both the existing administrative contribution and your individual contract with Bebat will cease to exist, to make way for the environmental contribution that is paid when the battery is put on the market. The rates are as follows:

  • € 2.39 / kg (excl. VAT) for lithium-ion-based Energy Storage Systems (ESS)
  • € 1.27 / kg (excl. VAT) for saltwater-based Energy Storage Systems (ESS)  

This contribution covers the costs of registration, prevention, awareness-raising, collection, dismantling, processing, recycling, reporting to the authorities and research & development to find out whether the batteries can be given a second life (pay-as-you sell). 

In other words, all costs are covered. This means that at the time of take-back at the end of the batteries' life cycle (8 to 10 years later), you should not expect any more costs. Lead-acid batteries remain subject to the administrative contribution.

Did you have an individual contract with Bebat for home batteries? This is no longer necessary due to the new environmental contribution and will be cancelled by Bebat. 

Transition period

The changes will enter into force on 01/01/2022 for sales between professionals  (manufacturers, importers, wholesalers and retailers). As with any previous rate change, a transition period is again foreseen until 01/04/2022 for sales to consumers. This allows existing stocks of home batteries put on market before 01/01/2022 to be sold to consumers for 3 more months at the contributions of 2021. However, Bebat will charge the environmental contribution for all home batteries put on market from 01/01/2022 onwards.

How to submit a declaration to Bebat from 1 January 2022?

As of 1 January 2022, as a participant, you are required to submit a monthly declaration for all home batteries you put on the market.

  • Are you already submitting a monthly declaration to Bebat? Then you continue to do so.
  • Are you submitting an annual declaration to Bebat? Then you still have to declare the batteries sold in 2021 under the old system, and pay the administrative contribution of € 0.057 (excl. VAT) per battery. You can do so until 28 February 2022. Any batteries you sell in 2022 must be declared under the new monthly system. That means the batteries you put on the market in January 2022 must also be declared by the end of February. In other words, there is a short transition period during which you may need to file multiple declarations.

Annual declaration 2021 

Monthly declarations as of 2022 

  • Batteries you put on the market in 2021
  • Declaration by 28 February 2022 
  • Batteries you put on the market after 1 January 2022
  • Monthly declaration, before the end of the next month 

There are new nomenclature numbers for declaring home batteries, which you should use in your declaration.

Discover the new nomenclature numbers

Provide the number, weight and reference number per battery via the participant platform MyBatbase.

Does this imply any changes to the take-back obligation?

The take-back obligation is applicable for all manufacturers, importers or installers of batteries who put batteries on the Belgian market. In order to comply with this take-back obligation, you have the choice to submit an individual plan yourself and have it approved by the regional authorities, or join Bebat as a participant. So, doing nothing is not an option. Participants who put home batteries on the market and have an own collection system and want to keep this system will have to submit an individual scheme to the authorities for all the categories of batteries (portable, industrial, automotive) they put on the market.

You will find more information in this blog article.

Will consumers be informed about the environmental contribution?

Consumers also have an important role to play. They may observe a price increase in companies that previously did not charge the costs for processing and recycling on their invoice. But the new scheme also has benefits for end users. Once the environmental contribution has been paid to Bebat, the take-back of the home battery is assured, so they have nothing to worry about later. After all, Bebat records every home battery that you declare as a participant and for which an environmental contribution has been paid. Bebat will inform consumers about the environmental contribution to make sure the benefits become clear to them as well: they can rest assured for the future and they are making an important contribution to a better environment and a sustainable society!  

Bebat makes every effort to inform all stakeholders about their obligations under the take-back obligation and to encourage them to comply. 

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