What is Belgium EPR Batteries

Belgium's battery EPR framework is governed by Regulation (EU) 2023/1542 — the EU Battery Regulation — which applies directly in all EU Member States without requiring national transposition. The Regulation entered into force on 18 August 2023, has applied in stages since 18 February 2024, and its EPR and waste management obligations became fully applicable from 18 August 2025. At national level, the Regulation is supplemented by federal and regional legislation in Belgium. Due to Belgium's constitutional structure, environmental policy is a regional competence divided between Flanders, Wallonia, and Brussels-Capital. Registration obligations are fulfilled with the three regional governments — not a single federal authority. Belgium's established PRO, Bebat (Bebat vzw/asbl), manages battery collection and recycling across all three regions on behalf of its participants and registers them automatically with the regional administrations. The EU Battery Regulation replaced the previous Batteries Directive 2006/66/EC in full from 18 August 2025. It covers all battery types regardless of chemistry or form, whether sold separately or incorporated into products or vehicles.

Does This Apply to E-Commerce & Online Sales

Yes. The EU Battery Regulation explicitly captures distance sellers and e-commerce operators as producers. A foreign brand selling batteries or battery-containing products directly to Belgian consumers via an online store — with no physical establishment in Belgium — is treated as a producer and must comply with Belgian battery EPR obligations. From August 2025, online marketplace operators in Belgium are required to ensure that sellers on their platforms can demonstrate compliance with battery EPR. Marketplace administrators must only admit producers who are Bebat participants or who have an approved individual producer responsibility plan. If a producer cannot demonstrate compliance, the marketplace must deny them access. Annually, by 1 March, marketplace operators must provide the regional governments with an overview of all producers active on their platform during the previous year. Producers using marketplaces for sales in Belgium must comply with all EPR obligations directly — marketplace participation does not transfer the producer obligation to the platform.

Who is the "Producer" under Belgium EPR?

Under Regulation (EU) 2023/1542 and Belgian regional legislation, a producer is any company that makes batteries available on the Belgian market for sale, rental, lease, or use — whether or not for payment. This covers:

1. A producer or importer established in Belgium that manufactures batteries, has them manufactured, or purchases them from abroad and makes them available on the Belgian market for the first time.
2. A producer or importer established outside Belgium that makes batteries directly available to professional or private end users on the Belgian market through distance selling, including online sales.
3. Private label owners whose brand name appears on batteries manufactured by third parties.
4. Economic operators who prepare batteries for re-use or repurposing — treated as producers for the second life of the battery.

An important change took effect from August 2025: Belgian professional end users who previously had to register as producers when importing batteries for their own use no longer bear that obligation. The registration responsibility has shifted to the non-Belgian seller supplying those batteries.

Who Must Register for EPR Batteries in Belgium

All producers placing batteries on the Belgian market must register with the three regional governments — Flanders, Wallonia, and Brussels-Capital. The most practical route is to join Bebat, which handles registration with all three regional authorities on behalf of its participants automatically. Producers may alternatively submit their own application for registration and approval directly to the regional authorities and take on all EPR obligations individually, but this is significantly more complex than joining Bebat. The battery register — a new requirement under the EU Battery Regulation — is being developed by Bebat in collaboration with the three regional authorities. It will be accessible on the websites of all three regional administrations. Bebat participants are automatically included in the battery register as long as they continue fulfilling their obligations.

Belgium EPR Battery Registration Threshold

Regulation (EU) 2023/1542 does not establish a minimum volume or turnover threshold below which producers are exempt from EPR obligations. All producers placing batteries on the Belgian market must register and comply, regardless of size or volume. The only exemption in the Regulation concerns batteries used in military or space equipment, which are outside the scope entirely. For due diligence obligations, companies with annual net turnover below €150 million (as adopted under the Omnibus IV package, July 2025) may be exempt — but this does not affect EPR registration and reporting obligations.

Batteries Covered (and Excluded)

Regulation (EU) 2023/1542 defines five battery categories, all within scope for EPR in Belgium. From 1 January 2026, Bebat introduced new codes aligned to these five categories, replacing the previous three-category structure (portable, industrial, automotive): Portable batteries Batteries under 5 kg not designed for industrial or vehicle use. Includes batteries in consumer electronics, power tools, household devices, and toys. The most commonly encountered category for e-commerce sellers. Light Means of Transport (LMT) batteries Batteries used in e-bikes, e-scooters, e-mopeds, and similar light electric vehicles. Automotive (SLI) batteries Starting, lighting, and ignition batteries used in vehicles. Industrial batteries Batteries used in industrial applications and stationary energy storage systems. Those above 2 kWh have additional requirements including battery passports from 2027. Electric vehicle (EV) batteries Batteries used in electric cars and heavy electric vehicles. Subject to carbon footprint declarations, battery passports from 2027, and detailed collection obligations. Key exclusions:

• Batteries designed for military or space equipment — outside scope entirely
• Batteries in nuclear installations — excluded
• Second-life batteries where the operator performing re-use or repurposing becomes the new producer

Producer Responsibility Organization (PRO)

Belgium's established PRO for batteries is Bebat (vzw/asbl), set up by the battery industry and operating across all three regions. Bebat has been collecting and recycling batteries in Belgium for over 30 years and manages a nationwide collection network with ADR-compliant transport. Bebat offers two compliance routes:

• Environmental contribution (collective system): Producers pay an upfront contribution covering full EPR obligations. Bebat handles collection, recycling, reporting, and registration with regional authorities.
• Administrative contribution (individual customised system): For producers with specific requirements or who wish to manage certain obligations separately.

For large lithium-ion batteries, Bebat participates in Reneos, the European network providing services for end-of-life management of large lithium-ion batteries across the EU. Bebat participants are automatically registered in the producer register with the three regional governments. Producers who join Bebat receive access to the MyBebat portal for declarations and reporting.

EPR Registration in Belgium

The registration process for battery producers in Belgium is as follows:

1. Determine whether your business qualifies as a producer under the EU Battery Regulation — i.e. whether you are placing batteries on the Belgian market for the first time.
2. If established outside Belgium, appoint an authorized representative established in Belgium before registering.
3. Join Bebat by registering through the Bebat website (bebat.be) and signing the participation agreement. Bebat registers participants automatically with all three regional governments.
4. Alternatively, submit a direct registration application to the three regional authorities (Flanders, Wallonia, Brussels-Capital) independently and establish your own approved collection system.
5. Declare the batteries you make available on the Belgian market for the first time through the MyBebat portal, using the Bebat codes aligned to the five EU Battery Regulation categories (applicable from 1 January 2026).
6. Pay the applicable environmental contribution to Bebat, based on battery category and volume.
7. Provide proof of Bebat participation or individual producer responsibility approval to marketplaces operating in Belgium.

Authorized Representative

Under Regulation (EU) 2023/1542 and Belgian legislation, producers or importers established outside Belgium are required to appoint a local authorized representative — a natural or legal person established in Belgium — to fulfill their EPR obligations under Chapter VIII of the Regulation. The authorized representative is responsible for registering with regional authorities, joining Bebat or an alternative approved system, submitting declarations, and serving as the point of contact for Belgian authorities. The representative must be appointed in writing. Bebat provides the necessary documents for appointing an authorized representative and is developing a formal arrangement for this in connection with its updated participation agreement. Foreign producers joining Bebat can arrange authorized representative services through Bebat or through accredited compliance service providers. Important development: In December 2025, the European Commission proposed suspending the authorized representative requirement for EU-established companies until 2035. This proposal has not been formally adopted as of April 2026. For non-EU producers, the requirement is not affected and continues to apply.

What Data Must Be Reported

Producers registered in Belgium must declare and report the following data through the MyBebat portal or directly to the regional authorities:

• Total weight (kilograms) of batteries placed on the Belgian market, broken down by the five battery categories (portable, LMT, SLI/automotive, industrial, EV) — applicable from 1 January 2026 under the new Bebat code structure
• Battery chemistry type where relevant to the contribution calculation
• Brand names under which batteries were placed on the market
• Collection and recycling performance data, as required by regional legislation and reported by Bebat on behalf of participants
• For EV and LMT batteries: number of batteries made available and amounts of waste batteries collected and delivered to treatment facilities

First Reporting Period & EPR Reporting Deadlines

Battery EPR has been in place in Belgium for many years under the former Batteries Directive. The new EU Battery Regulation obligations took full effect from 18 August 2025. Key dates:

• 18 February 2024: EU Battery Regulation begins applying. CE marking and substance restrictions in force.
• 18 August 2025: EPR registration, waste management, and labelling obligations fully in force.
• 1 January 2026: New five-category Bebat code structure introduced, replacing the previous three-category structure (portable, industrial, automotive).
• 1 March (annual): Marketplace administrators must provide regional governments with an overview of all producers active on their platforms during the previous year.
• 18 February 2027: Battery passports mandatory for industrial batteries (>2 kWh) and EV batteries. Portable batteries must be removable and replaceable by end users.
• 18 August 2027: Due diligence obligations in force (delayed from 2025 under Omnibus IV).

Annual declaration deadlines for volumes placed on the market are set through the MyBebat portal. Producers should confirm submission schedules with Bebat at the time of registration.

Labels & Marketing Claims

Crossed-out wheeled bin symbol From 18 August 2025, all batteries must display the separate collection symbol. The symbol must cover at least 3% of the area of the largest side of the battery, up to a maximum of 5 × 5 cm. Chemical symbols Batteries containing more than 0.002% cadmium must be marked Cd. Batteries containing more than 0.004% lead must be marked Pb. Capacity marking Portable and rechargeable batteries must display capacity information. QR code From 18 August 2026, all batteries must carry a QR code linking to product information. For LMT, industrial (>2 kWh), and EV batteries, the QR code links to the Digital Battery Passport from 18 February 2027. CE marking Mandatory for all batteries from 18 August 2024. Environmental claims All environmental and sustainability claims must comply with the Unfair Commercial Practices Directive and Belgian consumer protection law. The Empowering Consumers for the Green Transition Directive (2024/825/EU) must be transposed by March 2026, after which unsubstantiated green claims will be prohibited across the EU including Belgium. Labels must comply in the regional language — Dutch in Flanders, French in Wallonia, and both in Brussels-Capital — where language requirements apply to consumer-facing information.

EPR Eco Fees & Eco-Modulation

Bebat's contribution structure is based on:

• Battery category — the five EU Battery Regulation categories each have distinct contribution rates
• Weight (kilograms) of batteries placed on the market
• Chemistry type — different chemistries carry different recycling costs and contribution levels

Bebat operates both an environmental contribution (collective system covering full EPR obligations) and an administrative contribution (for producers managing certain obligations individually). Under Regulation (EU) 2023/1542, financial contributions must cover the costs of separate collection, transport, and treatment of waste batteries. Eco-modulation — adjusting contributions based on battery environmental performance (durability, recyclability, recycled content) — is required by the Regulation and will be implemented by Bebat as the Belgian framework matures. Specific eco-modulation criteria for Belgium have not been published as of April 2026.

Risks, Penalties & Common Mistakes

1. Selling in Belgium without Bebat participation or individual approval. Marketplaces are required to bar producers who cannot demonstrate EPR compliance. Non-compliant producers face loss of access to Belgian online marketplaces and direct enforcement by regional authorities.
2. Failing to appoint an authorized representative. Non-EU and non-Belgian producers must appoint a Belgian-established representative before registering. Without one, registration cannot be completed.
3. Assuming one EU registration covers Belgium. Battery EPR registration is national. Registration in another EU member state does not fulfil Belgian obligations. Belgium's three-region structure means registration must be managed across Flanders, Wallonia, and Brussels-Capital.
4. Missing the 1 March marketplace reporting deadline. Marketplace operators must report all producers active on their platform to regional authorities by 1 March annually. Sellers must ensure their compliance status is current before this deadline.
5. Using outdated Bebat codes after 1 January 2026. The previous three-category structure (portable, industrial, automotive) was replaced by the five-category EU Battery Regulation structure from 1 January 2026. Reporting under old codes after this date is incorrect.
6. Missing labelling requirements. The crossed-out wheeled bin symbol and CE marking are mandatory from August 2025. Non-compliant products are subject to market surveillance action.
7. Missing the QR code deadline of August 2026. Companies should begin QR code implementation well in advance.

What E-Commerce Sellers Should Do Now

1. Confirm whether your products contain batteries — including batteries incorporated into devices — and whether they are being sold to Belgian consumers.
2. If established outside Belgium, identify and appoint an authorized representative established in Belgium.
3. Join Bebat (bebat.be) and sign the participation agreement. Bebat will register you with all three regional governments and provide access to the MyBebat portal.
4. Declare battery volumes by category through the MyBebat portal using the five-category code structure (applicable from 1 January 2026).
5. Provide proof of Bebat participation to all marketplaces operating in Belgium where you sell battery-containing products.
6. Verify that all batteries carry the crossed-out wheeled bin symbol, CE marking, and capacity information as required from August 2025.
7. Plan for the QR code requirement by August 2026 and the Digital Battery Passport for industrial and EV batteries by February 2027.
8. Track the annual 1 March marketplace reporting deadline and ensure your Bebat participation status is current.

FAQ

Is battery EPR mandatory in Belgium?

• Yes. Battery EPR has been mandatory in Belgium for many years under the former Batteries Directive. From 18 August 2025, the new EU Battery Regulation (2023/1542) fully replaced the Directive. All producers placing batteries on the Belgian market must register with the three regional governments — most practically through Bebat — declare volumes, and comply with collection and recycling obligations.

Do foreign brands selling online into Belgium need to register?

• Yes. Distance sellers and e-commerce operators selling batteries or battery-containing products to Belgian consumers are explicitly captured as producers under the EU Battery Regulation. Non-Belgian companies must appoint an authorized representative established in Belgium before registering. Online marketplaces operating in Belgium are required to verify compliance and can bar non-compliant sellers.

Is there a minimum volume threshold below which registration is not required?

• No. The EU Battery Regulation does not establish a minimum volume or turnover exemption for EPR registration. All producers placing batteries on the Belgian market must register and comply regardless of size.

What changed in Belgium from August 2025 regarding professional end users?

• Until August 2025, Belgian professional end users who imported batteries for their own use had to register as producers themselves. From August 2025, this obligation has shifted to the non-Belgian seller supplying those batteries. Foreign sellers who previously relied on Belgian business customers to handle registration must now register directly in Belgium.

Do I need to register separately with Flanders, Wallonia, and Brussels-Capital?

• In practice, no — if you join Bebat. Bebat registers its participants automatically with all three regional governments. If you choose to comply individually without Bebat, you must submit separate registration applications to each of the three regional authorities.