Frequently asked questions
A battery or accumulator is any source of electrical energy generated by direct conversion of chemical energy and consisting of one or more primary battery cells (non-rechargeable) or consisting of one or more battery cells (rechargeable).
The Waste Battery and Accumulator Regulations 2009 set out requirements for waste battery collection, treatment, recycling, and disposal for all battery types and affect producers, battery distributors (retailers), waste battery collectors, recyclers and exporters.
This legislation aims to improve the environmental performance of batteries and accumulators and all those involved in their life cycle.
The manufacturer or importer that first places batteries on the UK market – whether sold separately or built into products – is classed as the 'producer'. If the business has a UK presence, it is responsible for meeting the compliance obligations, including overseas companies registered with Companies House.
How you register for compliance depends on the type of battery you sell and the amount of batteries you put on the market.
- Portable batteries are used to power small, everyday devices that you can easily carry or move around. Portable batteries are sealed, weigh less than 4 kg, and do not meet the definition of an automotive or industrial battery. Examples include AAA cells, mobile phone batteries, and button cells.
- Designed exclusively for industrial and professional applications, industrial batteries are used to power electric vehicles. An industrial battery may be supplied unsealed without being classified as an automotive battery, or sealed without being classified as a portable battery.
- Automotive batteries are used for starting, igniting a vehicle engine, or for powering the lights of a vehicle.
‘Placed on the market’ refers to the first point in time at which an EEE product becomes available for distribution or use in the UK. This is when there is a transfer of ownership from a:
- UK manufacturer to a UK distributor
- UK manufacturer to a UK consumer or user
- Manufacturer outside the UK to an importer in the UK or the person responsible for distributing the item in the UK
- Manufacturer, or formal representative, direct to the final user or consumer
Transfer of ownership can be by sale, loan, hire, lease, or gift.
If you are the first person in a supply chain to professionally make EEE products available to a third person in the UK, you are considered the one that ‘places on the market’. This applies regardless of whether payment is received.
Producers of portable batteries are divided into two registration types under the UK regulations: small portable producers and large portable producers.
- Small portable producers are defined as producers who place under 1 tonne of portable batteries on the market per year (with any volume of automotive/ industrial batteries).
- Large portable producers are defined as producers who place over 1 tonne of portable batteries on the market per year (with any volume of automotive/ industrial batteries).
- A large producer of portable batteries must fund the collection, treatment, recycling and disposal of waste batteries in proportion to their company market share, and are required to report their portable battery placed on market volumes to their scheme on a quarterly basis, and automotive/industrial battery volumes annually.
Producers must record and report the tonnage of batteries they place on the UK market (PoM) throughout each compliance year.
- If you place more than 1 tonne of portable batteries on the UK market in a calendar year, you must register through a Battery Compliance Scheme (BCS) by 15 October before the start of the compliance year (calendar year).
- If you place less than 1 tonne, you can register directly with the Environment Agency instead.
- Producers of automotive and/or industrial batteries only (no portable batteries) must register via the NPWD and provide the total tonnage, chemistry, and brand name of automotive batteries you placed on the market by 31 March in the following year.
An obligated distributor is a company that sells more than 32kg a year of batteries in the UK (approximately 24 AA batteries a week). A distributor supplying portable batteries to end-users must, at the point of supply, accept waste portable batteries back free of charge; and clearly inform end users at the sales point that this take-back service is available.
However, a company selling less than 32kg of portable batteries in a year, or a company who only sells batteries within equipment, are not considered an obligated distributor and are exempt from this requirement.
- Producers of industrial batteries must take back waste industrial batteries free of charge and within a reasonable time from end users if they supply them with new batteries.
- Producers of automotive batteries must collect waste automotive batteries free of charge and within a reasonable time from their final holders, such as garages and scrapyards.
