Battery producer responsibility

If your business manufactures or imports batteries for sale in the UK, you have legal obligations under the Batteries and Accumulators (Placing on the Market) Regulations 2008 and the Waste Batteries and Accumulators Regulations 2009. These regulations require producers to register, finance the collection and recycling of waste batteries, and meet labelling and reporting requirements.

The obligations vary depending on whether you deal in portable, industrial, or automotive batteries. This guide explains what you need to do for each type.

Are you a battery producer?

You are a battery producer if you:

• Manufacture batteries or accumulators in the UK (including batteries incorporated into appliances or vehicles)
• Import batteries into the UK, regardless of the selling technique used (including distance selling and online sales)

The definition covers all battery types: portable (such as AA, AAA, button cells, and batteries in consumer electronics), industrial (such as batteries for electric vehicles, uninterruptible power supplies, and energy storage systems), and automotive (starter, lighting, and ignition batteries).

If you only sell batteries that have already been placed on the UK market by another producer, you are a distributor with separate take-back obligations but no registration requirement as a producer.

How to register and comply

Your registration route depends on the type and volume of batteries you place on the market.

Portable batteries

Small producers (1 tonne or less of portable batteries per year) must register directly with the environmental regulator via the National Packaging Waste Database (NPWD). You must report data annually and still contribute to collection and recycling costs proportional to your market share.

Large producers (more than 1 tonne of portable batteries per year) must join an approved Battery Compliance Scheme (BCS). The BCS finances collection, treatment, and recycling of waste portable batteries on your behalf. It will charge fees based on the tonnage and chemistry of batteries you place on the market.

The UK portable battery collection target is 45% of the average annual amount placed on the market over the preceding three years. Each BCS receives a share of this target based on its members' combined market share.

Industrial and automotive batteries

Industrial and automotive battery producers register directly with the Office for Product Safety and Standards (OPSS) on NPWD. There is no requirement to join a compliance scheme for these battery types. However, you must:

• Industrial batteries: Take back waste industrial batteries free of charge from end users when supplying new batteries, and in certain other circumstances
• Automotive batteries: Collect waste automotive batteries free of charge from final holders such as garages and scrapyards

Labelling requirements

All batteries placed on the UK market must carry specific markings. Getting labelling wrong can result in enforcement action.

Required markings

• Crossed-out wheelie bin symbol: Indicates the battery must not be disposed of as general waste. Must be visible and legible on the battery or its packaging.
• Capacity marking: All portable and automotive batteries must display their capacity in milliampere hours (mAh) or ampere hours (Ah) in a visible, legible, and indelible form.
• Chemical symbols: Batteries containing mercury (Hg) above 0.0005%, cadmium (Cd) above 0.002%, or lead (Pb) above 0.004% by weight must display the relevant chemical symbol beneath the crossed-out wheelie bin symbol.

Placement rules

Markings must appear on the battery itself. Where the battery is too small (surface area less than 0.5 cm squared for the wheelie bin symbol), the marking must appear on the packaging. Chemical symbols must cover at least one quarter of the area of the wheelie bin symbol.

Reporting obligations

All battery producers must report data to their regulator:

• Portable battery producers (via BCS): Quarterly data on batteries placed on the market, reported through the BCS. The BCS then reports to the regulator.
• Automotive battery producers: Report total tonnage, chemistry, and brand name by 31 March the following year via NPWD.
• Industrial battery producers: Report tonnage and chemistry annually via NPWD.

Battery Compliance Schemes must obtain sufficient evidence to meet members' obligations for the previous compliance period by 31 May the following year.

Recycling efficiency targets

Waste batteries collected must be recycled to minimum efficiency levels, depending on chemistry:

• Lead-acid batteries: 65% recycling efficiency by average weight, including recycling of lead content to the highest degree technically feasible
• Nickel-cadmium batteries: 75% recycling efficiency by average weight, including recycling of cadmium content to the highest degree technically feasible
• Other batteries (including lithium-ion): 50% recycling efficiency by average weight

These targets are met by the compliance schemes and recycling operators, but producers ultimately finance the process. Higher recycling efficiency requirements may increase compliance costs for batteries that are difficult to recycle.

What to do now

1. Determine your producer status: Assess whether your business manufactures or imports batteries into the UK
2. Classify your batteries: Identify whether each product is portable (sealed, under 4 kg), industrial, or automotive
3. Register: For portable batteries over 1 tonne, join an approved Battery Compliance Scheme. For all other categories, register directly with OPSS via NPWD
4. Check labelling: Ensure all batteries carry the crossed-out wheelie bin symbol, capacity marking, and any required chemical symbols
5. Set up reporting: Establish processes to track tonnage and chemistry of batteries placed on the market by type