23%
Not checked whether the foreign supplier takes over the EPR
Tips to avoid mistakes in your declaration
Are you a Bebat participant and do you make (products with) batteries available on the Belgian market? Then you must declare these. Although a correct declaration is very important, mistakes can sometimes occur. Therefore, we list the most common mistakes for you, as well as tips to avoid making them.
Control through audits
On average, every Bebat participant undergoes a check every 5 years to verify if their declarations match reality. Often, this is an online audit where the check is conducted via a questionnaire on the participant platform MyBebat. For participants who make more than 12,000 batteries a year available on the market, an on-site inspection is performed by a specialized audit firm.
Most common mistakes
Not checked whether the foreign supplier takes over the EPR
No contribution on invoices and/or credit notes
Incorrect use of Bebat codes
System not ready for implementation of differentiated contributions
Too many or too few batteries reported
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Not checked whether the foreign supplier takes over the EPR
More and more foreign companies are joining Bebat and paying environmental contributions for their sales outlets in Belgium. However, this does not always happen. Therefore, it is best to check if your foreign supplier is affiliated.
Then check if they also declare the batteries you purchase from them to Bebat. If you purchase the batteries for personal use, the foreign supplier is obligated to declare them. In other cases, the foreign supplier can voluntarily take over the declaration. If they declare them, then you do not need to do it. Otherwise, you will still need to declare these batteries.
A foreign supplier can voluntarily take over your EPR obligations. Not sure if your supplier will take over the EPR for you? First check via the link below if they are already a Bebat participant and record in writing (via a mandate) who will make the declaration. You can request a model of a mandate from Bebat. Then check if the environmental contributions are mentioned on his invoices. If you purchase batteries for personal use, the foreign supplier must affiliate with Bebat or submit an individual plan to the three regional governments.
No environmental charges on invoices to professionals
Quite a few Bebat participants forget to mention the environmental contributions along with the amounts on their sales invoices to professional customers. However, this is legally required. As a result, both the regional governments and your customers can verify whether you are a participant with Bebat.
Incorrect use of Bebat codes
The correct use of the Bebat codes is important for us to be able to provide accurate reporting to the authorities. They want to have an overview of the number of batteries and their weight per battery category, chemical family, whether built-in or sold separately.
System not suitable for differentiated contributions
Bebat implements differentiated contributions. This means that your contribution can vary depending on the weight and chemical family of the battery. We have found that this is not always correctly applied because some Bebat participants still need to adjust their IT systems. Usually, this is a task for the IT department.
Too many or too few batteries declared
Often we find that participants report too many or too few batteries. Did you report a higher number of sold batteries than you actually made available on the market? If so, the overpaid contributions are refunded. If you reported too few, the due contributions will still be collected. In some cases, an additional financial contribution is requested. The declaration must be based on the actual number of batteries made available on the market, not on an estimate.
The importance of an accurate declaration
Submitting a correct Bebat declaration, with the appropriate Bebat codes, is important for 3 reasons:
You help Bebat to correctly inform the regional authorities about the batteries that are entering the Belgian market.
Bebat calculates how much environmental contributions you as a participant have to pay based on your declarations.
Based on the declarations, the authorities can determine whether Bebat achieves the legally stipulated collection percentage for its participants.
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When you sell or produce batteries in Belgium, you must declare this to Bebat via MyBebat.
There are specific rules regarding the mention of your environmental and administrative contributions on your invoices.