+49 6196 5835357

info@ecopv-eu.com

🇧🇪 EPR Compliance for Batteries in Belgium |
Guide and Checklist 2026

Extended Producer Responsibility (EPR) for Batteries – 7 Steps to Compliance + Step-by-Step Checklist

Anyone selling batteries or battery-powered devices in Belgium has a legal obligation: Extended Producer Responsibility (EPR) makes companies jointly responsible for the end-of-life of their batteries. Belgium operates a consolidated, nationwide system under a single recognized take-back scheme – with three regional supervisory authorities and increasingly stringent requirements under the new EU Battery Regulation (EU 2023/1542).

What does this mean specifically for your company?

Here are the 7 most important steps – including a checklist to get you started.

🇧🇪 EPR Compliance for Batteries in Belgium |
Guide and Checklist 2026

Extended Producer Responsibility (EPR) for Batteries – 7 Steps to Compliance + Step-by-Step Checklist

Anyone selling batteries or battery-powered devices in Belgium has a legal obligation: Extended Producer Responsibility (EPR) makes companies jointly responsible for the end-of-life of their batteries. Belgium operates a consolidated, nationwide system under a single recognized take-back scheme – with three regional supervisory authorities and increasingly stringent requirements under the new EU Battery Regulation (EU 2023/1542).

What does this mean specifically for your company?

Here are the 7 most important steps – including a checklist to get you started.

Who is considered a “battery manufacturer”?

Under Belgian battery regulations, a manufacturer is any company that places batteries on the Belgian market for the first time – regardless of where the company is headquartered.

Specifically, this applies to:

  • Domestic producers – those who manufacture batteries domestically and sell them in Belgium under their own name or brand
  • Importers – those who commercially import batteries or battery-powered electrical and electronic equipment (EEE) into Belgium from the EU or third countries
  • EU-based companies operating abroad in distance selling – those who deliver batteries or battery-powered goods directly to Belgian end consumers via an online store (B2C or B2B)
  • Non-EU companies – those who ship directly to Belgian end customers via e-commerce; in traditional B2B supply chains, the obligations automatically transfer to the first importer established in the country
  • White-label / private labels – those who market devices with built-in or included batteries under their own brand name in Belgium are considered the first distributor of the batteries contained therein

Practical example: An Austrian company sells Bluetooth speakers with built-in batteries directly to Belgian end customers through its online store → is considered a battery manufacturer under the EPR regulation → must appoint an authorized representative based in Belgium → requires Bebat membership → must report quantities and weights monthly and pay Bebat fees → must display the Bebat certificate on marketplaces (e.g., Amazon.be, Bol.com) to avoid account suspensions.

The 7 Key Steps to EPR Compliance in Belgium

Step 1: Appoint an Authorized Representative (for foreign companies)

Companies not headquartered in Belgium that sell directly to Belgian end consumers via distance selling (B2C or B2B) are legally required to appoint an authorized representative based in Belgium.

The authorized representative assumes full, joint and several financial and administrative liability for all notification, reporting, and payment obligations of the foreign manufacturer toward the Belgian authorities and Bebat.

Requirements for the power of attorney documentation:

  • Written power of attorney agreement (power of attorney / procuration) in one of Belgium’s official languages (Dutch or French) or in English
  • Proof of identity of the foreign company (e.g., extract from the commercial register) – to be digitally validated
  • The authorized representative must first set up a Belgian VAT identification number (BTW/TVA) or an admin account for the foreign company
  • A Hague Apostille is not required as a standard

Step 2: Membership in Bebat (the only authorized take-back organization)

Membership in a government-authorized take-back organization is mandatory in Belgium. In the battery sector – as with WEEE – there is no competition between parallel systems: Bebat is the only government-recognized, nationwide collective take-back organization for batteries throughout Belgium.

OrganizationResponsibility
    Bebat vzwOnly authorized take-back organization – all battery categories, all regions

Bebat handles collection, sorting, recycling, and legal registration in the national interregional register on a consolidated basis.

Theoretical alternative: Self-management is legally permissible but requires approval from all three regional authorities. The manufacturer must independently demonstrate a comprehensive, free take-back network in all Belgian municipalities and provide extensive bank guarantees. For mass-market and B2C products, this option is irrelevant in practice.

Step 3: Registration with the regional authorities via Bebat

Due to Belgium’s federal structure, three regional authorities are legally responsible for market surveillance:

  1. Flanders: OVAM – Openbare Vlaamse Afvalstoffenmaatschappij
  2. Wallonia: SPW – Service Public de Wallonie, Département du Sol et des Déchets
  3. Brussels-Capital Region: Bruxelles Environnement / Leefmilieu Brussel
    Practical procedure:

Practical procedure:

  • Online registration on the Bebat portal (signing of the membership agreement)
  • Bebat automatically handles the legal registration in the national interregional register for all three regions
  • Bebat assigns a unique Bebat participant number, which serves as official EPR proof for customs authorities and online marketplaces

The participant number must then be displayed prominently: in the Terms and Conditions, legal notice, marketplace profiles (Amazon.be, Bol.com, etc.), and on the website.

Step 4: Collect battery data and report it monthly

Volume reporting is mandatory – broken down by chemistry, intended use, and the five categories specified in the EU Battery Regulation. Reports are submitted digitally via the Bebat participant portal.

The 5 battery categories according to the EU Battery Regulation (EU 2023/1542):

CategoryExamples
Portable batteriesAA, AAA, button cells, rechargeable batteries in household appliances
Industrial batteriesStationary storage systems, professional power tool batteries
Vehicle batteriesStarter batteries for motor vehicles (non-EV)
Traction batteries (LMT)E-bikes, e-scooters, light electric vehicles
Electric vehicle batteries (EV) Traction batteries for passenger cars, trucks, buses

What must be reported?

  • Quantities and weights of all batteries placed on the market in Belgium
  • Breakdown by chemistry (e.g., Li-ion, NiMH, lead-acid), intended use, and category

Deadlines:

  • Monthly report (standard): No later than the 19th of the following month
  • Quarterly or annual report: Possible for very small distributors – requires review and approval by Bebat

Step 5: Calculate and pay Bebat fees

The fees payable to Bebat consist of an environmental fee and an administrative fee. Billing is based on the number of units or weight in kilograms, depending on the battery category.

Eco-modulation: Bebat applies eco-modulation criteria. Batteries that:

  • are easily replaceable,
  • have a proven long service life, or
  • contain a high proportion of recycled materials,

are classified at reduced fee rates. Those who prioritize eco-design and repairability pay less.

Step 6: Expanded Reporting Requirements: Carbon Footprint & Due Diligence

The new EU Battery Regulation (EU 2023/1542) introduces additional obligations beyond traditional volume reporting:

Carbon Footprint Declaration:

  • Manufacturers of EV batteries and certain industrial batteries must submit a verified CO₂ footprint declaration digitally or link it to the product
  • The declaration must cover the entire life cycle of the battery (raw material extraction, production, transport)

Due Diligence in the Supply Chain:

  • Larger market participants must maintain evidence of the compliance of their raw material supply chains within the system
  • This applies in particular to critical raw materials: lithium, cobalt, nickel
  • The documentation must be stored in the Bebat participant portal and kept up to date

Step 7: Comply with Labeling Requirements

The following labels are mandatory for all batteries placed on the Belgian market:

  • Crossed-out wheelie bin (WEEE-like symbol): Must be affixed to every battery; placement on the packaging is permitted if space is limited
  • Nominal capacity: Mandatory information for all device and vehicle batteries – to be specified in mAh, Ah, or Wh

Who is considered a “battery manufacturer”?

Under Belgian battery regulations, a manufacturer is any company that places batteries on the Belgian market for the first time – regardless of where the company is headquartered.

Specifically, this applies to:

  • Domestic producers – those who manufacture batteries domestically and sell them in Belgium under their own name or brand
  • Importers – those who commercially import batteries or battery-powered electrical and electronic equipment (EEE) into Belgium from the EU or third countries
  • EU-based companies operating abroad in distance selling – those who deliver batteries or battery-powered goods directly to Belgian end consumers via an online store (B2C or B2B)
  • Non-EU companies – those who ship directly to Belgian end customers via e-commerce; in traditional B2B supply chains, the obligations automatically transfer to the first importer established in the country
  • White-label / private labels – those who market devices with built-in or included batteries under their own brand name in Belgium are considered the first distributor of the batteries contained therein

Practical example: An Austrian company sells Bluetooth speakers with built-in batteries directly to Belgian end customers through its online store → is considered a battery manufacturer under the EPR regulation → must appoint an authorized representative based in Belgium → requires Bebat membership → must report quantities and weights monthly and pay Bebat fees → must display the Bebat certificate on marketplaces (e.g., Amazon.be, Bol.com) to avoid account suspensions.

The 7 Key Steps to EPR Compliance in Belgium

Step 1: Appoint an Authorized Representative (for foreign companies)

Companies not headquartered in Belgium that sell directly to Belgian end consumers via distance selling (B2C or B2B) are legally required to appoint an authorized representative based in Belgium.

The authorized representative assumes full, joint and several financial and administrative liability for all notification, reporting, and payment obligations of the foreign manufacturer toward the Belgian authorities and Bebat.

Requirements for the power of attorney documentation:

  • Written power of attorney agreement (power of attorney / procuration) in one of Belgium’s official languages (Dutch or French) or in English
  • Proof of identity of the foreign company (e.g., extract from the commercial register) – to be digitally validated
  • The authorized representative must first set up a Belgian VAT identification number (BTW/TVA) or an admin account for the foreign company
  • A Hague Apostille is not required as a standard

Step 2: Membership in Bebat (the only authorized take-back organization)

Membership in a government-authorized take-back organization is mandatory in Belgium. In the battery sector – as with WEEE – there is no competition between parallel systems: Bebat is the only government-recognized, nationwide collective take-back organization for batteries throughout Belgium.

OrganizationResponsibility
    Bebat vzwOnly authorized take-back organization – all battery categories, all regions

Bebat handles collection, sorting, recycling, and legal registration in the national interregional register on a consolidated basis.

Theoretical alternative: Self-management is legally permissible but requires approval from all three regional authorities. The manufacturer must independently demonstrate a comprehensive, free take-back network in all Belgian municipalities and provide extensive bank guarantees. For mass-market and B2C products, this option is irrelevant in practice.

Step 3: Registration with the regional authorities via Bebat

Due to Belgium’s federal structure, three regional authorities are legally responsible for market surveillance:

  1. Flanders: OVAM – Openbare Vlaamse Afvalstoffenmaatschappij
  2. Wallonia: SPW – Service Public de Wallonie, Département du Sol et des Déchets
  3. Brussels-Capital Region: Bruxelles Environnement / Leefmilieu Brussel
    Practical procedure:

Practical procedure:

  • Online registration on the Bebat portal (signing of the membership agreement)
  • Bebat automatically handles the legal registration in the national interregional register for all three regions
  • Bebat assigns a unique Bebat participant number, which serves as official EPR proof for customs authorities and online marketplaces

The participant number must then be displayed prominently: in the Terms and Conditions, legal notice, marketplace profiles (Amazon.be, Bol.com, etc.), and on the website.

Step 4: Collect battery data and report it monthly

Volume reporting is mandatory – broken down by chemistry, intended use, and the five categories specified in the EU Battery Regulation. Reports are submitted digitally via the Bebat participant portal.

The 5 battery categories according to the EU Battery Regulation (EU 2023/1542):

CategoryExamples
Portable batteriesAA, AAA, button cells, rechargeable batteries in household appliances
Industrial batteriesStationary storage systems, professional power tool batteries
Vehicle batteriesStarter batteries for motor vehicles (non-EV)
Traction batteries (LMT)E-bikes, e-scooters, light electric vehicles
Electric vehicle batteries (EV) Traction batteries for passenger cars, trucks, buses

What must be reported?

  • Quantities and weights of all batteries placed on the market in Belgium
  • Breakdown by chemistry (e.g., Li-ion, NiMH, lead-acid), intended use, and category

Deadlines:

  • Monthly report (standard): No later than the 19th of the following month
  • Quarterly or annual report: Possible for very small distributors – requires review and approval by Bebat

Step 5: Calculate and pay Bebat fees

The fees payable to Bebat consist of an environmental fee and an administrative fee. Billing is based on the number of units or weight in kilograms, depending on the battery category.

Eco-modulation: Bebat applies eco-modulation criteria. Batteries that:

  • are easily replaceable,
  • have a proven long service life, or
  • contain a high proportion of recycled materials,

are classified at reduced fee rates. Those who prioritize eco-design and repairability pay less.

Step 6: Expanded Reporting Requirements: Carbon Footprint & Due Diligence

The new EU Battery Regulation (EU 2023/1542) introduces additional obligations beyond traditional volume reporting:

Carbon Footprint Declaration:

  • Manufacturers of EV batteries and certain industrial batteries must submit a verified CO₂ footprint declaration digitally or link it to the product
  • The declaration must cover the entire life cycle of the battery (raw material extraction, production, transport)

Due Diligence in the Supply Chain:

  • Larger market participants must maintain evidence of the compliance of their raw material supply chains within the system
  • This applies in particular to critical raw materials: lithium, cobalt, nickel
  • The documentation must be stored in the Bebat participant portal and kept up to date

Step 7: Comply with Labeling Requirements

The following labels are mandatory for all batteries placed on the Belgian market:

  • Crossed-out wheelie bin (WEEE-like symbol): Must be affixed to every battery; placement on the packaging is permitted if space is limited
  • Nominal capacity: Mandatory information for all device and vehicle batteries – to be specified in mAh, Ah, or Wh

Step-by-Step Checklist

(a) Companies based in Belgium

1. Classify batteries into the 5 EU categories (appliances, industrial, automotive, LMT, EV)

2. Complete online registration on the Bebat portal (membership agreement)

3. Include the Bebat participant number in the Terms and Conditions, Legal Notice, and website

4. Enter CO₂ footprint data (if EV or industrial batteries are placed on the market)

5. Set up monthly volume reporting (deadline: the 19th of the following month)

6. Document due diligence records for critical raw materials (lithium, cobalt, nickel)

7. Check labeling: crossed-out trash can + nominal capacity on all batteries

 

(b) Companies from other EU countries

1. Check the sales channel: Are direct sales made to Belgian end consumers via an online store? If yes → proceed to step 2

2. Appoint an authorized representative based in Belgium and sign a power of attorney agreement

3. Have the authorized representative set up a VAT number or admin account for the foreign company

4. Obtain Bebat membership through the authorized representative (framework agreement on behalf of the foreign manufacturer)

5. Provide the Bebat participant number to all Belgian marketplaces and trading partners

6. Upload the Bebat certificate to the merchant backend of Amazon.be, Bol.com, etc.

7. Prepare the monthly volume report (weight + quantity by category and chemical composition)

(c) Companies from third countries (outside the EU)

1. Check the supply chain: Delivery to a Belgian importer → obligations are transferred to the importer; submit all material data (weight, chemical composition) in a timely manner

2. Direct shipment to end consumers (without a Belgian intermediary) → Handle all steps from (b) through an authorized representative in Belgium

3. Provide the Bebat participant number to all Belgian marketplaces

4. Prepare monthly volume reports (weight and quantity by category)

Step-by-Step Checklist

(a) Companies based in Belgium

1. Classify batteries into the 5 EU categories (appliances, industrial, automotive, LMT, EV)

2. Complete online registration on the Bebat portal (membership agreement)

3. Include the Bebat participant number in the Terms and Conditions, Legal Notice, and website

4. Enter CO₂ footprint data (if EV or industrial batteries are placed on the market)

5. Set up monthly volume reporting (deadline: the 19th of the following month)

6. Document due diligence records for critical raw materials (lithium, cobalt, nickel)

7. Check labeling: crossed-out trash can + nominal capacity on all batteries

 

(b) Companies from other EU countries

1. Check the sales channel: Are direct sales made to Belgian end consumers via an online store? If yes → proceed to step 2

2. Appoint an authorized representative based in Belgium and sign a power of attorney agreement

3. Have the authorized representative set up a VAT number or admin account for the foreign company

4. Obtain Bebat membership through the authorized representative (framework agreement on behalf of the foreign manufacturer)

5. Provide the Bebat participant number to all Belgian marketplaces and trading partners

6. Upload the Bebat certificate to the merchant backend of Amazon.be, Bol.com, etc.

7. Prepare the monthly volume report (weight + quantity by category and chemical composition)

(c) Companies from third countries (outside the EU)

1. Check the supply chain: Delivery to a Belgian importer → obligations are transferred to the importer; submit all material data (weight, chemical composition) in a timely manner

2. Direct shipment to end consumers (without a Belgian intermediary) → Handle all steps from (b) through an authorized representative in Belgium

3. Provide the Bebat participant number to all Belgian marketplaces

4. Prepare monthly volume reports (weight and quantity by category)

Are you planning to sell your products in Belgium?

We’ll help you ensure compliance with Belgium’s EPR regulations for batteries so you can get started with legal certainty.

Are you planning to sell your products in Belgium?

We’ll help you ensure compliance with Belgium’s EPR regulations for batteries so you can get started with legal certainty.

Contact

We look forward to your message!

info@ecopv-eu.com

+49 6196 5835357

Frankfurter Str. 70-72
65760 Eschborn

Contact

We look forward to your message!

info@ecopv-eu.com

+49 6196 5835357

Frankfurter Str. 70-72
65760 Eschborn