From 1 May 2025, the definition of ESS modules subject to the environmental contribution will be expanded. All ESS modules in an installation ≤ 16 MWh must be declared under the environmental contribution, including residential applications (such as home batteries) and Plug & Play batteries.
This adjustment stems from various developments in the ESS sector.
Heavier batteries
The environmental contribution (pay-as-you-sell principle) was only applicable to ESS ≤ 200 kg. For ESS > 200 kg, as a manufacturer or importer, you paid a small administrative contribution of €0.053 per piece (module) (excluding VAT) when putting it on the market, and later, upon collection, you paid the actual cost for transport, dismantling, and recycling at that moment (Pay-as-you-Collect principle).
Throughout 2024 and early 2025, ESS manufacturers and importers noticed an increasing demand for commercial and industrial ESS. Additionally, we see a remarkable technological evolution: where most modules were previously air-cooled, more and more modules are now liquid-cooled. These ESS modules usually weigh more than 200 kg and, consequently, no longer fell under the environmental contribution but under the administrative contribution.
Due to the long lifespan of such batteries of 15 years and more, determining the future cost for transport, dismantling, and recycling is challenging. The financial debt of a manufacturer/importer thus builds up over many years as they bring more ESS modules to market.
Moreover, the European Battery Regulation (Art.58.7) obliges the manufacturer/importer to provide a guarantee when the end-of-life cost is not paid upfront. This ensures the cost is covered in case of bankruptcy or cessation. The guarantee can take the form of a pledged account, a first-demand bank guarantee, or insurance, in the name and at the expense of you as an individual manufacturer/importer, with the government as the beneficiary.
The sector is unwilling to apply the ‘Pay-as-you-Collect’ principle (administrative contribution) for all these ESS. This brings a lot of complexity and the risk that a manufacturer or importer may be held responsible and have to pay for batteries they did not bring to market.
Plug & Play batteries
Another development in the ESS sector is the Plug & Play batteries with a plug. These may be brought to market from 17 April 2025 and can then be connected to the electricity grid. There is expected to be high demand for this type of battery, and a larger variety of companies will offer them.
This type of battery was not yet included in the definition of ESS modules subject to the environmental contribution.
New ESS definition
Due to the technological evolutions outlined above (for both commercial & industrial batteries and Plug & Play batteries), Bebat, at the request and with the cooperation of the sector, has adjusted the definition for ESS modules subject to the environmental contribution to include these batteries.
The environmental contribution applies to battery modules of energy storage systems that can be connected to the mains voltage and supply energy to the electricity grid, regardless of whether they are stationary or mobile and regardless of the module’s weight. This applies to systems that operate within a grid-connected environment (on-grid) as well as systems that operate completely autonomously (off-grid).
The environmental contribution applies to battery modules used in:
- Plug & Play solutions
- Residential applications such as home batteries
- Commercial & industrial installations, and battery parks ≤ 16 MWh
The environmental contribution is calculated per kg. To determine the battery’s weight, you must take the weight of the battery/module where the serial number is located, including the housing if present. The inverter and BMS (Battery Management System) should only be included if integrated into the housing.
Excluded from the definition are:
- UPS batteries (Uninterruptible Power Supply) intended solely for backup purposes and temporary emergency power supply
- Lead modules