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?
Flanders: Environmental policy agreement on the take-back obligation for used portable and industrial batteries and accumulators (11th June 2010).
Flanders: Environmental policy agreement on the take-back obligation for used automotive batteries and accumulators (11th June 2010).
I read that, in the long term, an environmental or administrative contribution will be charged per product family. What does this mean in practice?
This means we will have to differentiate the environmental or administrative contribution per individual product category.
In concrete terms, it will still be possible to submit a declaration based on the nomenclature code. However, every nomenclature will be linked to a specific environmental contribution, depending on the product category. At present, a universal environmental contribution of € 0.075€ (excl. VAT) is due on almost every nomenclature. Only for li-ion batteries for e-bikes and li-ion automotive batteries, a different contribution is applicable.
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.
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.
Now that the eco-tax has been abolished, are there any other specific regulations that apply to batteries?
Local environmental legislation in Brussels-Capital Region, Flanders and Wallonia is obviously still in place and imposes very similar obligations on companies that bring batteries and accumulators onto the market. In other words, little has changed in practice.