Which ESS modules are subject to the environmental contribution?

Since 1 January 2022, ESS modules ≤ 200 kg have been subject to Bebat's environmental contribution. You pay this contribution as a Bebat participant at the time the battery is put on the market, and not upon its future return. This system, the Pay as you Sell principle, provides financial security and simplified management.

At the request and with the cooperation of the sector, the definition of ESS modules to which the environmental contribution applies, has been modified.

Due to technological developments, the following battery modules are also subject to the environmental contribution from 1 May 2025:

• ESS modules > 200 kg (in an installation ≤ 16 MWh)
  Due to technological developments (such as the shift from 'air cooled' to 'liquid cooled' modules), more and more ESS modules exceed 200 kg. Until now, they were subject to the Pay as you Collect system, where the cost was only charged upon collection. This system will expire for modules of installations ≤ 16 MWh: henceforth, they will also be subject to an environmental contribution.
• Plug & Play batteries
  From 17 April 2025, Plug & Play batteries with a plug may be connected to the electricity grid in Belgium. These batteries were previously not included in the definition of ESS, but are now also subject to the environmental contribution.

Read more about the evolutions leading to these changes

New ESS definition

From 1 May 2025, the environmental contribution will apply to all battery modules of energy storage systems that can be connected to the grid voltage and supply energy to the electricity grid, whether stationary or mobile and regardless of the module weight. This applies to systems operating within a grid-connected environment (ongrid) as well as systems operating completely autonomously (offgrid).

The environmental contribution is calculated per kg. To determine the weight of the battery, you must take the weight of the battery/module where the serial number is located including the casing if present. The inverter and BMS (Battery Management System) should only be counted if integrated into the casing.

Benefits of the new arrangement

• Simplified management: Less complexity for producers/importers in the return and recycling of batteries
• Level playing field: All producers and importers fall under the same transparent arrangement.
• Risk reduction: Producers no longer need to provide a guarantee themselves, reducing legal and financial risks.
• Efficiency & cost savings: More peace of mind due to no longer having unpredictable future costs for return and recycling.

Implementation

The environmental contribution for Plug & Play batteries and ESS modules in an installation ≤ 16 MWh put on the Belgian market, will take effect from 1 May 2025.

• ESS modules put on the market between 1 January and 30 April 2025 can voluntarily be declared under this environmental contribution.
• No transition period Batteries put on the market before 1 May 2025 and not voluntarily declared under the environmental contribution will remain subject to the current system of the administrative contribution with guarantee arrangement.

Why is there no transition period?

All batteries that you as a producer put on the market are subject to the extended producer responsibility (EPR). Before the introduction of this new arrangement, the Pay as you Collect principle applied to ESS modules > 200 kg. This meant that you as a producer/importer paid a small administrative contribution of €0.053 per unit (module) (excl. VAT) when put on the market. Later upon collection, you paid the effective price for transport, dismantling and recycling at that time.

Additionally, the European Battery Regulation (Art.58.7) also obliges you as a producer/importer to provide a guarantee when the end-of-life cost is not prepaid. This ensures that the cost is covered even in the event of bankruptcy or cessation. The guarantee can take the form of a pledged account, a first demand bank guarantee or insurance, in your individual producer/importer's name and with the government as beneficiary.

With the introduction of the environmental contribution, your obligations do not change, but it becomes much simpler for you. The complexity of the above will be limited to 1 May 2025. You pay the cost of end-of-life in advance. The alternative is to submit an application for an individual plan with guarantee arrangement to the regional governments.

How do you declare these ESS modules?

The declaration of these ESS modules is done in the same way as ESS ≤ 200 kg:

• The weight of the battery/module where the serial number is located, including any casing. The inverter and BMS must only be counted if integrated into the casing.
• Serial number, brand and model for each ESS module, so Bebat can identify the discarded module. If you cannot find the brand and model in MyBebat, send a technical sheet to participants@bebat.be and we will ensure the list is updated.

Bebat provides new Bebat codes for all ESS modules.

Read more about the use of the new Bebat codes

How is the limit of 16 MWh per installation assessed?

For this, we look at the total number of MWh of all battery modules of an energy storage installation that are installed (possibly in multiple phases) on a site.

As a site, we consider the environmental-technical unit to which the environmental permit applies or, in the absence of an environmental permit, the company site.

Always contact us in advance if you are installing ESS installations of this size. 

What about modules from ESS installations > 16 MWh?

Bebat is looking into the possibility of developing a separate arrangement for battery modules from ESS installations > 16 MWh.

Do you have any questions about these changes? Do not hesitate to contact our customer service.