Do I have to affiliate to Bebat?
Every company that brings batteries or battery-operated devices onto the Belgian market must comply with the take-back obligation for used batteries. This means companies have a legal obligation to organise the collection and processing of used batteries; other obligations include prevention and sensibilisation and reporting to the regional authorities. Companies have two options: either they fulfil the take-back obligation themselves, or they can simply join Bebat.
Bebat has established a collective system enabling its affiliates to meet the take-back obligation.
In other words, we fulfil the take-back obligation for you – that is why affiliation is such a good idea!
What is meant by environmental policy agreements?
15.06.2018 - EPA - Flanders
Environmental policy agreement on the take-back obligation for discarded portable and industrial batteries and accumulators. Download
According to the current legislation, on what basis should the declaration be submitted?
Declarations must be based on the actual number of products and the weight per chemical family. In most cases, the weight is automatically calculated by Bebat. The type of use must also be specified (I/P/A =... Industrial / Portable / Automotive). Bebat differentiates between I/P/A for most battery types. For some types, though, the members must indicate the category when submitting their declaration.
Which batteries to declare to Bebat ?
Statements shall be submitted solely for batteries put onto the Belgian market and purchased from a non-resident company, that is not itself a Participant to the Bebat system.
Non-resident participants should always submit a simplified statement based on their sales of batteries to Belgian customers (companies whose take-back obligation is taken over, or Belgian private consumers in case of distance selling).
Is the environmental or administrative contribution subject to VAT?
The environmental or administrative contribution is a contribution the manufacturer/importer of batteries or battery-operated devices pays to Bebat in return for a service.
Bebat uses this contribution to meet the manufacturer/importer’s take-back obligation. This obligation includes the collection, sorting and recycling of used batteries or accumulators. As the payment concerns a service, the environmental contribution is subject to 21% of VAT.
What is the difference between an environmental contribution and an administrative contribution?The environmental contribution covers all costs of managing waste batteries , a.o.:- Collection, pick-up, sorting, processing and recycling- Prevention, raising awareness and communications- Reporting to the 3 regional authoritiesThe administrative contribution does not include the costs of collection, pick-up, sorting, processing and recycling, although it does cover all of the other expenses listed above. An administrative contribution will be instated for large batteries with a weight of > 20 kg (except for lead acid batteries, where the administrative contribution is applicable from 3 kg onwards). This relates mainly to rechargeable batteries used in hybrid and electric vehicles, and used for the storage of energy from solar panels.Please note that Bebat does offer a full range of services related to the collection, pick-up, sorting, processing and recycling of waste batteries with an administrative contribution. It is impossible however, to apply one and the same uniform price across the board for these services as the costs involved depend on the weight, the chemical family of the waste batteries, the packaging and the services requested, to name just a few differentiating factors.Bebat will offer to individual prices to participants who want to make use of such services. Prices will be tailored to the specific and unique requirements of each participant. Participants handling the collection, pick-up, sorting, processing and recycling of the waste batteries by themselves must pay an administrative contribution and are required to provide Bebat with all relevant details to enable Bebat to report, on their behalf, to the three regional authorities. This is not necessary lead acid batteries subject to an administrative contribution, for as long as the market regulates the collection and recycling of this type of waste batteries. For lead acid batteries already collects all necessary information about their collection and recycling and reports them to the three regional authorities.
Why differentiated environmental contributions for rechargeable lithium batteries?
Effective from 1/01/2018, Bebat is set to implement differentiated environmental contributions for rechargeable lithium batteries with a weight of ≤ 20 kg. The reason is the substantial collection and recycling costs as well as the safety risks related to waste rechargeable lithium batteries.
Billing contributions to consumers
On invoices/cash register receipts for industrial and li-ion automotive batteries sold to consumers, you are free to choose whether you visibly specify the environmental contribution or administrative contribution in the invoice or not. For portable batteries however, you are not permitted to specify the environmental contribution on invoices/till receipts to consumers – as specified in EU Directive 2006/66-. Our list of nomenclature numbers states whether batteries are portable, industrial or automotive. If this is not specified, you are required to submit this information yourself using the decision tree.
Billing contributions between professionals in case one product contains several batteries and/or accumulators with a different environmental contribution
It is a legal obligation to specify the amount of the environmental contribution as well as the number of batteries sold on all invoices between professionals. There is no such obligation for administrative contributions.
This sample invoice illustrates how invoices between professionals are to be drawn up in the event you are selling products that contain multiple batteries with different environmental contributions.
Declarations have to be made based on the nomenclature number system in myBatbase. Each nomenclature number will carry a specific contribution, based on the average weight of the batteries included in the relevant nomenclature number category. For nomenclature numbers where participants are required to input the exact weight of the battery, the contribution will be determined based on this exact weight.
Declarations will continue to be made based on the nomenclature number system in myBatbase. Each nomenclature number will carry a specific contribution, based on the average weight of the batteries included in the relevant nomenclature number category. For nomenclature numbers where participants are required to input the exact weight of the battery, the contribution will be determined based on this exact weight.
Please find hereafter a file with the nomenclature numbers for monthly declarations, as well as a file with the simplified nomenclature for simplified declarations.
You find here an Excel file for monthly declarations
You find here an Excel file for simplified declarations (yearly)
Contributions per piece and per kg
All contributions are exclusive of VAT and apply per piece (battery or pack) with the exception of the environmental contributions for rechargeable lithium batteries with a weight of > 10 kg & ≤ 20 kg. For this type of batteries, the contribution is charged per kg. Here you can find an overview of the current environmental and administrative contributions.
Timing of introduction of the contributions: important for your stocks
The new environmental and administrative contributions are introduced in two steps. During a period of three months the new contributions will be applicable to sales between all professionals (manufacturers, importers, wholesalers and retailers).
For sales to consumers, the new contributions will take effect on 01/04 at the latest. This gives professionals who sell to consumers 3 months to deplete their stocks.