Which batteries do I need to declare?

All portable, industrial and automotive batteries put on the Belgian market must be declared to Bebat. This applies to both batteries sold separately (replacement market) and built-in and supplied batteries (initial installation), as well as both non-rechargeable (primary) and rechargeable batteries. The three categories are: 

  • Portable batteries: standard batteries, such as in watches, remote controls, etc.
  • Automotive batteries (lead or lithium-ion): cold-start batteries for starting combustion engines.
  • Industrial batteries: specifically designed for professional or industrial use. A battery weighing over 3 kg that is not an automotive battery is always considered an industrial battery. The same applies to batteries used in any type of electric vehicle, such as the battery for an electric bicycle, industrial cleaning machine, emergency lighting, energy storage, electric vehicle, forklift, etc. – even if it weighs less than 3 kg.

Not sure? A handy decision tree has been made to make it easy to determine which category applies to a battery!


Important: certain battery types can not be put on the market:

  • From 18/02/2024: Portable batteries containing more than 0.02 weight percentage of cadmium (expressed in metallic cadmium), regardless of whether sold separately or in devices or whether built into light means of transport or other vehicles.
  • From 18/08/2024: Portable batteries containing more than 0.01 weight percentage of lead (expressed in metallic lead), regardless of whether they are built into devices.
  • From 18/08/2028: Portable zinc button cell batteries containing more than 0.01 weight percentage of lead (expressed in metallic lead), regardless of whether they are built into devices.

An overview of all legislation relating to this can be found at https://www.bebat.be/en/b2b/legislation.

Do I have to submit a declaration to Bebat?

Your company is located in Belgium

Which batteries do you need to declare if your company is located in Belgium? See the diagram below: 

Overview - In Belgium

In other words, batteries that meet the following criteria:

  • Produced by your company in Belgium or purchased from a foreign supplier that does not take over your declaration obligation;
  • Sold in Belgium;
  • Separate or built into a device.

How can you be certain whether your foreign supplier is taking over your take-back obligation?

This applies if the supplier:

  • States the Bebat environmental or administrative contribution on its invoice 
    or
  • Is affiliated with Bebat and confirms that they are taking over your take-back obligation.


Your declaration can be based on sales data or purchase data.

  • Declaration based on sales data:
    If you only work with invoices when selling batteries (separately or built-in/provided), you may base your declaration on your sales data.
  • Declaration based on purchase data:
    If you only work with receipts or a combination of receipts and invoices, your declaration must be based on your purchase data.

Consider the following when determining which batteries to declare.

Declaration based on sales data

This type of declaration applies if you only work with invoices when selling batteries (separately or built-in/provided).

To be included in the declaration​​

  • ​​​Batteries you have purchased in Belgium or that are produced by your company and/or purchased from a foreign supplier that does not take over your declaration obligation.

To be deducted from the declaration

  • ​Batteries you have sold abroad and purchased in Belgium.
  • Batteries you have sold abroad and purchased abroad from suppliers that take over your declaration obligation at Bebat.

Do not need to be declared

  • ​Batteries you have sold or purchased in Belgium.
  • Batteries you have sold abroad and have produced in Belgium or that are purchased abroad from suppliers that do not take over your declaration

Declaration based on purchase data

This type of declaration applies if you only work with receipts (whether or not combined with invoices) when selling batteries (separately or built-in/provided). 

To be included in the declaration

  • ​Batteries you have purchased abroad from suppliers that do not take over your declaration obligation at Bebat or that you have produced in Belgium.

To be deducted from the declaration

  • ​Batteries you have purchased in Belgium and sold abroad.
  • Batteries you have purchased abroad from suppliers that have taken over your declaration obligation at Bebat and that you sell abroad.
  • Batteries you have purchased abroad from suppliers that do not take over your declaration obligation at Bebat or that you have produced in Belgium and sold abroad on the condition that you included these batteries in your declaration on purchase or production.

Do not need to be declared

  • ​Batteries purchased in Belgium and sold in Belgium.
  • Batteries you have purchased abroad from suppliers that do not take over your take-back obligation at Bebat or that you have produced in Belgium and sold abroad on the condition that you did not include these batteries in your declaration on purchase or production.

Your company is located outside of Belgium

Which batteries do you need to declare if your company is located outside of Belgium? See the diagram below:

Overview - Outside of Belgium

In other words, batteries that meet the following criteria:

  • Sold by your company to private individuals in Belgium (such as through an online shop).
  • Separate or built into a device.

Your declaration is based on your sales data as described above. You declare batteries that you sell to private individuals in Belgium via remote sale, as well as to Belgium companies for which you take over the declaration obligation to Bebat.

Nothing to declare? Submit a zero declaration.

Do you not have anything to declare for a specific period? Submit a zero declaration.