Obligations under waste batteries regulations exist for three main ‘actors’; producers; distributors; and end-users and affect three ‘categories’ of batteries: portable (weighing less than 4Kgs and not industrial or automotive); industrial (specifically designed for business or commercial use – like fork-lift batteries); and automotive (batteries designed to start or power vehicles – not just cars).

  • You are a producer if you make, or have made under your own brand, or import (to sell) batteries.
  • You are a distributor if you sell batteries to the person who uses them.
  • You are an end-user if you use batteries in your business. Domestic users are known as consumers.

You can have obligations under one or more categories.

Producer obligations

These obligations vary depending on the battery category:

Portable producers must:

  1. Work out the weight of batteries they produce each year. If your company imports batteries on their own or in equipment, then obligations arise on all batteries you own as they cross UK borders. This weight is the producer liability;
  2. If the annual producer liability is less than one tonne, make a simple registration on the National Packaging Waste Database and pay a flat £30 fee. Registration and fees are due for every year that the liability arises and is based on the prior calendar year;
  3. If the annual producer liability is more than one tonne, join a battery compliance scheme and provide quarterly reports to the scheme on the weight and type of batteries placed on the UK market in the prior calendar quarter. In addition, fees must be paid to the scheme to support the safe recycling and disposal of those batteries once they enter the waste stream;
  4. Display their Battery Producer Numbers on invoices/delivery notes for all business to business sales;
  5. Keep (for four years) records of the batteries they produce.

Industrial producers must:

  1. Register as a producer directly on the National Packaging Waste Database. There is no charge for this;
  2. Provide your Battery Producer Number on business to business sales paperwork, such as delivery notes or invoices;
  3. Keep (for four years) records of batteries placed on the market and collected for treatment/recycling;
  4. Take back industrial batteries (at no cost to the end user) when supplying new batteries. The end user can also request take back without purchase if they can’t return their industrial batteries to the original producer or if you placed their battery type on the market within the last three years;
  5. Send all waste batteries collected to either a UK approved treatment and recycling centre or a UK centre approved for the export of waste batteries for treatment/recycling overseas.

Note that if you are likely to have to store waste industrial batteries you may need to either register a waste storage exemption or obtain a waste storage permit.

Automotive producers must:

  1. Register on the National Packaging Waste Database not later than 28 days after first placing batteries on the market. There is no charge for registering;
  2. Display your Battery Producer Number on all invoices/delivery notes for business to business sales;
  3. Keep (for four years) records of batteries placed on the market and collected for treatment/recycling;
  4. Tell end users how they can return waste batteries to you;
  5. Collect waste automotive batteries from the final holder at no cost to that holder;
  6. Ensure that all sealed lead-acid waste batteries are stored in a sealed battery box that is acid resistant;
  7. Send waste batteries to either an approved UK treatment/recycling centre or an approved exporter for treatment/recycling overseas.

It is important to note that you may require a storage exemption or environmental permit to keep waste batteries on your premises.

Distributors and retailers of portable batteries must:

  1. Calculate how many batteries (on their own) they sell each year on each of their sites. If less than 32kgs on any site, no further action is necessary for that site;
  2. Offer free waste battery deposit at each site selling 32kgs or more per year;
  3. Make such deposits available to all store visitors. There is no requirement to purchase batteries or any other products;
  4. Ensure there is adequate instore (or online in the case of internet retailers) marketing material to make customers aware of the takeback service;
  5. Comply with all applicable hazardous waste regulations, both storage and consignment, as some batteries are classed as hazardous waste and it may not be possible to determine this accurately on each site.

Final collection of batteries may be made free of charge by a battery compliance scheme, but this is not obligatory.

End users of portable batteries must:

  1. Ensure that batteries are not disposed of in their normal mixed waste collections;
  2. Not place used batteries in civic or municipal waste battery collection sites.

End users should:

  1. Attempt to return batteries to the original producer if possible (not necessarily the supplier they purchased from);
  2. If this is not possible, contact a battery compliance scheme to see if they will collect;
  3. If very large, contact a battery compliance scheme to discuss becoming a voluntary corporate collection site;
  4. Comply with all applicable waste management laws, including hazardous waste regulations where appropriate.

End users of industrial batteries must:

  1. Ensure that batteries are not disposed of in their normal mixed waste collections;
  2. Ensure that they do not send waste industrial batteries to landfill or incineration sites;
  3. Not place used batteries in civic or municipal waste battery collection sites;
  4. Ask your supplier to take back old batteries when you purchase new ones;
  5. Attempt to contact the original supplier if you are disposing of waste industrial batteries without replacing them. If you cannot contact the original supplier, then contact a company that produces the same type of battery as you are disposing of. If you cannot find any such company, then you should contact the Department for Business and Skills (BiS) for advice.

End users and final holders of automotive batteries must:

  1. Ensure that batteries are not disposed of in their normal mixed waste collections;
  2. Ensure that they do not send waste automotive batteries to landfill or incineration sites;
  3. Not place used batteries in civic or municipal waste battery collection sites;
  4. Ask your supplier to take back old batteries when you purchase new ones;
  5. Attempt to contact the original supplier if you are disposing of waste industrial batteries without replacing them. If you cannot contact the original supplier, then contact a company that produces the same type of battery as you are disposing of. If you cannot find any such company, then you should contact the Department for Business and Skills (BiS) for advice.