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FAQ - What are the UK Battery Producer Registrations?


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Some of our customers have been querying the position regarding the new regulations and whether their activities fall under the new complaince guidelines.

From 15th October 2009, battery producers are required to register with an approved Battery Compliance Scheme. The following notes clarify which types of business the regulations apply to and the collection, treatment and recycling obligations for battery producers.

The UK Waste Batteries and Accumulators Regulations 2009 were introduced on 5 May 2009 and set out new rules for the collection, treatment and recycling of all types of batteries and accumulators (rechargeable batteries), including batteries which are incorporated into electrical equipment.

Am I a Batteries Producer?

A Batteries Producer is defined as “any person in the UK that places batteries, including batteries incorporated into appliances or vehicles, on the market for the first time on a professional basis”.

So you are a battery producer in the UK if you manufacture batteries in the UK, import batteries into the UK or import electrical equipment which contains batteries. If you buy batteries from a supplier in the UK and fit them into equipment in the UK then you are a not a Battery Producer in the UK (because the batteries had already been put on the market in the UK). However, if you supply equipment containing batteries into other EU Member States then you may be a Batteries Producer in these other countries.

What are the battery collection, treatment and recycling obligations?

The UK Batteries Regulations apply to all types of batteries and specifically include batteries incorporated into equipment (apart from batteries used in military and space equipment). As per the EC Batteries Directive, the UK Batteries Regulations define three categories of battery, and places different requirements on Battery Producers in each category:
  • Portable Battery = battery or battery pack that is sealed, hand carried and not an industrial or automotive battery
  • Industrial Battery = battery designed exclusively for industrial or professional uses
  • Automotive Battery = battery used for automotive starter, lighting or ignition power

Portable Batteries producers

Batteries Producers who place > 1 tonne per year of portable batteries on the UK market are required to:
  • Collect data on the amount of batteries placed on the UK market from 5 May 2009.
  • Pay for the collection, recycling and disposal of waste batteries in proportion to your market share from 1 January 2010; and
  • Join one of the seven approved Battery Compliance Scheme (BCS) by 15 October 2009. The BCS will register its members with the UK Environment Agency, arrange the collection, recycling and disposal of batteries on your behalf (in accordance with your market share obligations) and report batteries compliance data to the authorities.

Batteries Producers who place < 1 tonne per year of portable batteries on the UK market are exempt from the requirement to pay for the collection, treatment and recycling of portable batteries, and do not need to join a BCS. Instead, they must register directly with one of the Environment Agencies (for example, the Environment Agency for companies in England and Wales) by 12 November 2009.

Industrial and automotive batteries producers

Producers of industrial and automotive batteries are required to:
  • Register directly with the Department for Business, Innovation and Skills (BIS) by 12 November 2009.
  • Make arrangements for the separate collection and recycling of waste industrial and automotive batteries. This includes producers and users of industrial and automotive batteries concluding other financing arrangements.

How do I register as a Batteries Producer?

To register as a Batteries Producer in the UK you must have a physical presence in the UK, such as a UK office, trading arm or Post Office box.

All producers of industrial and automotive batteries, and producers who place < 1 tonne per year of portable batteries on the market, can now register directly with the relevant authorities through a single online system. The National Packaging Waste Database (NPWD, http://npwd.environment-agency.gov.uk/Public/BatteriesHome.aspx) allows these producers to apply as a batteries producer by providing the following information:

1. The types of batteries placed on the UK market (portable, industrial or automotive)

2. Basic information about the company, including organisation name and contact details. NPWD will then provide a login username, password and 6-digit PIN for the company to access their account on the NPWD system

3. Once the registrant has received login details for their company account on the NPWD system, the company will be able to make an application to register as a producer of portable (placing less than 1 tonne on the market annually), industrial or automotive batteries. Information to be provided in the application may include:

a. Reporting the amount of lead acid, nickel-cadmium and other types of batteries placed on the market since 5 May 2009 for the first compliance period; and for waste industrial and automotive batteries producers

b. How the management of waste industrial and automotive batteries will comply with the take-back and recycling requirements of the UK Battery Regulations

As mentioned above, any company who places > 1 tonne per year of portable batteries on the UK market must join one of the seven approved Battery Compliance Scheme (BCS) by 15 October 2009. A list of approved Battery Compliance Schemes is available from the UK Environment Agency website http://www.environment-agency.gov.uk/business/regulation/107939.aspx


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