The Waste Batteries and Accumulators Regulations 2009 require companies to take responsibility for the batteries that they place on the UK market.

The aim of the legislation is to minimise the negative impact of these batteries on the environment. The regulations affect all companies who place portable, industrial or automotive batteries onto the UK market.

Does it apply to my organisation?

If your business manufactures, imports or distributes portable, industrial or automotive batteries, you are subject to the Waste Batteries and Accumulators Regulations and must act accordingly.

Required actions for obligated producers

If you manufacture or import batteries you are classed as a ‘producer’ and must:

  • Join a batteries compliance scheme within 28 days of when you first placed batteries on to the market (Producers below the one tonne threshold have the option of registering direct with the Environment Agency).

  • Report the amount of batteries placed on the UK market.

  • You may also be required to finance a proportion of the batteries that your organisation has placed onto the UK marketplace, based on recycling targets set by the government.

The amount you are required to finance will vary depending on whether you are classed as a small producer (placing less than one tonne on the market), a large producer (placing over one tonne on the market) or a distributor (selling more than 32kg of portable batteries a year to end users).

It also depends on whether you only place automotive or industrial batteries on the marketplace. Each classification has specific requirements that we can help with, including registration, reporting and battery collections.

Batteries data reporting requirements

As an obligated battery producer reporting requirements vary depending on whether you are putting on the market portable, industrial or automotive types.

For portable battery producers, who place on the market more than one tonne of batteries a year, you are obliged to proportionally finance the collection and treatment of waste batteries by joining a compliance scheme. This must be done by the 15 October of the preceding year, and the compliance scheme will charge fees to offset your obligation.

The compliance scheme will on your behalf:

  • Register your business and pay an annual fee to the environmental regulator

  • Submit your battery placed on market data to the regulator for the current year, and two preceding years. The data is reported by chemistry type – lead-acid, nickel cadmium, and ‘other’. Records must be kept in writing for a minimum of four years.

  • Buy evidence notes of battery recycling to offset your obligation

If you place less than one tonne of batteries on the market a year, you can register and report directly with the regulator, and will pay an annual fee as opposed to funding collection and recycling activities.

A producer’s obligation is calculated by their average annual placed on market data over the last three years, multiplied by the national recycling target (45%) and the collection/recycling fees charged by the compliance scheme.

If you put products on the market containing batteries, you will have to report the EEE and battery tonnages separately. Please note that for industrial and automotive battery producers, there are different obligations. Producers of industrial and automotive batteries must register with the Department for Business, Innovation and Skills (BIS) and report their annual placed on the market data to them.

What if I’m not compliant?

Failure to meet this legal obligation may result in prosecution and fines. Ignorance of the regulations is not accepted as a defence and previous years’ non-compliance can be counted in enforcement actions.

No matter how large the undertaking, we can assist and guide you every step of the way to ensure your organisation is no longer in breach of the regulations.

Government guidance

You can read the full guidance on batteries producer responsibility here.

Regulation reform

A Government consultation into future Extended Producer Responsibility (EPR) reform for the batteries regulations in the UK is expected to take place in 2022 or 2023.

How can Ecosurety help?

As your batteries compliance scheme we will offset all of your obligations, giving you peace of mind that you are fully compliant with the regulations, as well as saving you time and money.

Our service covers all your commitments to meet the Waste Batteries and Accumulators Regulations including registration, auditing, collection, reporting and evidencing against your obligations, as well as submission to the Environment Agency.

We will:

  • Save you time by managing and guiding you through the complex batteries legislation

  • Save you money through smarter, more efficient management of your batteries obligation

  • Lobby the government on your behalf to influence the direction and shape of future batteries legislation

  • Keep on top of the latest battery recycling technologies, accommodating the recycling requirements of new battery designs

  • Continually grow our extensive battery collection network of over 7,000 locations across the UK

  • Provide updates and support for future batteries EPR reform

How to register

If you are not yet a batteries compliance member with Ecosurety, simply call our team on 0333 4330 370 or email to get started.

Ben Luger Ecosurety

Ben Luger

Marketing Project Specialist

Ben helps drive marketing communications and projects for Ecosurety, including project managing the launch of the Ecosurety Exploration Fund and website content development.

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