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Battery declarations: tips to avoid mistakes

Battery declarations: tips to avoid mistakes

Are you a Bebat participant and do you bring batteries (or battery-powered devices) to market in Belgium? Then you must file a declaration. These declarations sometimes include mistakes. Following the audits in 2022 and the beginning of 2023 (for the 2021 declaration year), together with Martine Vanheers, Finance, Customer Service, Legal & Public Affairs Director, we look at the most frequently made mistakes and how you can ensure your next declaration is faultless.

Tailored advice

Every participant is audited on average once every three years (this is a statutory obligation). These audits aim to verify whether the declarations match reality. They are often carried out using an online questionnaire on the participants’ platform MyBatbase. For participants that put more than 12,000 batteries a year on the market, a thorough audit is conducted on-site by a specialised audit firm. In 2022 and the beginning of 2023 (for the 2021 declaration year), 1,318 audits were carried out – 1,098 of which were completed online and 220 were conducted on-site at the company’s premises by a specialised audit firm.

During such an audit, the accuracy of the declaration is verified. For Bebat, this is also an opportunity to provide participants with advice tailored to their individual situation. 

Following the audit, Bebat will send you a report of the main findings. This sets out how well you did, as well as any points requiring improvement. This blog post offers a broader picture than your individual report. Which errors do numerous Bebat participants make and how can they be avoided?

In 2021 (audits in 2022 and beginning of 2023), the most common mistakes made on declarations were:


Number of times identified 

Percentage of total audits 

No check on whether foreign suppliers took over the declaration obligation



No contribution on invoices and/or credit notes



Incorrect use of A & B nomenclature



Incorrect nomenclature



System not ready for introduction of differentiated contribution



No comments



Too much declared



Too few declared



How does this compare to previous years?

Failing to check whether a foreign supplier is a Bebat participant continues to be a big stumbling block, although this can easily be checked on MyBatbase.
A hard time using the right nomenclature numbers. This is why Bebat developed a handy overview. More and more participants appear to be ready for differentiated contributions – a development that can still improve. Overall, 17% of the audits were completely error-free. We are on the right track, but there is still room for improvement!

Let’s take a closer look at each of these errors.

The most common errors

1. No check on whether foreign suppliers took over the declaration obligation

More and more foreign companies are affiliated to Bebat. They often no longer have a separate importer for each country. Imports are arranged on a regional basis (e.g. Belgium – the Netherlands – Luxembourg). They commit to paying the environmental contributions for their sales points in Belgium.

However, some foreign participants do not declare the batteries at Bebat for all their Belgian customers. So, it is advisable to check whether your foreign supplier is affiliated with Bebat. If this is the case, you need to verify whether they declare the batteries you buy from him to Bebat. If your foreign supplier does declare them, you don’t have to. If not, you still have to declare these batteries. 

One declaration is sufficient. Make clear agreements in this regard.



How can you check if your foreign supplier is affiliated to Bebat? You can verify this by checking whether the environmental contribution is listed on the invoices of your supplier. Is this not the case? Go to MyBatbase > tab Lists > Participant list and check to see if you can find your supplier on this list.

2. No environmental contributions on invoices to professionals

Quite a few Bebat participants forget to include the environmental contributions and amounts on their sales invoices to professional customers. Note: this is required by law. This enables both the regional authorities and your customers to check whether you are a Bebat participant.


It is not sufficient to simply state on invoices that the Bebat contribution is included, without mentioning the amount. The contribution amounts are best specified on a separate line or under a separate heading on your invoices.

You can find an example invoice here

3. Incorrect Incorrect use of nomenclature numbers

The use of correct nomenclature numbers is essential to report correctly to the authorities. They require an overview of the numbers of batteries and their weights categorised by chemical family and whether sold individually or built-in. The introduction of differentiated contributions has made the nomenclature numbers even more important. For annual declarations (fewer than 10,000 batteries a year) filed via the MyBatbase platform, the numbers have been pre-filled in the declaration. This makes it easier identify the battery category to declare.

However, careful attention is required when filling in other (monthly) declarations. Using the search function, you can enter specific battery characteristics to find the correct nomenclature number. Many batteries have an international IEC code, which simplifies the search. However, not all built-in batteries have these codes.

On the declaration, nomenclature numbers distinguish between A and B nomenclatures. A represents batteries sold separately, while B represents batteries built into a device. Quite a few participants use A and B in the wrong way in their theirbuilt-in. These are also often incorrectly used.


What is the chemical family? Use? Weight? These are important questions to consider as the answers will lead to the correct nomenclature number. Incorrect numbers have a knock-on effect throughout the chain and so are best avoided. So, prevention is better than cure.

You will find a handy overview of the nomenclature numbers for the monthly declarations here, and for the annual declarations here.

Contract ondertekenen

4. System not ready for differentiated contributions

In 2018, Bebat introduced differentiated contributions. This is because the contribution for a battery can vary according to its weight and chemical family. We notice that this is not always done correctly.

Modification to IT systems

Martine Vanheers, Bebat: ‘Mistakes still happen here. Let's consider lithium batteries as an example.characteristics of the battery, link these to a different nomenclature number and specify a corresponding price on the invoice. Some participants still have to make necessary changes to their systems. That’s usually a job for the IT department.’

You need to know the chemical family, the weight and a number of other properties of the battery, link these to a different nomenclature number and specify a corresponding price on the invoice.

- Martine Vanheers, Director Finance, Customer Service, Legal & Public Affairs at Bebat -

Martine Vanheers, Director Finance, Customer Service, Legal & Public Affairs at Bebat

- Martine Vanheers, Director Finance, Customer Service, Legal & Public Affairs at Bebat -

5. Too few or too many batteries declared

Many participants are found to have declared too few or too many batteries. Declared a higher number of sold batteries than you effectively brought to market? The excess contribution you paid will be refunded. Declared too few batteries? Then the owed contributions will subsequently be collected. In some cases, a financial contribution is still required.

Why is it so important that the declaration is correct?

Martine Vanheers: ‘Bebat must report the number and weight of the batteries brought to market to the authorities, so these must be accurate. Furthermore, the collection rate imposed on Bebat by the authorities is calculated based on the number of collected batteries divided by the average number of batteries put on the market in that year and the two previous years. If the latter number of batteries is ‘inflated’ by excessive declarations, then we will be obliged to collect more used batteries. So accuracy is essential!’

Declaration completely correct!

Why is it important for you as a Bebat participant to correctly declare the number of batteries that you put on the market last year (or month)? There are at least two good reasons. Based on these declarations:

  • the environmental contributions are calculated that you as a participant pay for the cost of prevention, awareness-raising, collection and recycling of used batteries.
  • the number of batteries and the weight of all declarations are reported to the authorities. Based on these numbers, the collection rates that are imposed on Bebat are calculated.

It doesn't take an Einstein to understand that nobody benefits from inaccurate declarations.

Everything you need to know about the declaration can be found here

Any questions? Please contact us:

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