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.

Are you a battery producer?

You are a battery producer if you:

• manufacture batteries or accumulators in the UK, including batteries built into appliances or vehicles
• import batteries into the UK, however you sell them, including by distance selling and online

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:

• If you produce industrial batteries, take back waste industrial batteries free of charge from end users when you supply new batteries, and in certain other circumstances.
• If you produce 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

• The crossed-out wheelie bin symbol shows the battery must not be thrown away as general waste. It must be visible and legible on the battery or its packaging.
• All portable and automotive batteries must display their capacity in milliampere hours (mAh) or ampere hours (Ah) in a visible, legible, and indelible form.
• 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 in a BCS report quarterly data on batteries placed on the market through the scheme, which reports to the regulator.
• Automotive battery producers report total tonnage, chemistry and brand name on NPWD by 31 March the following year.
• Industrial battery producers report tonnage and chemistry on NPWD each year.

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

1. Check whether your business manufactures or imports batteries into the UK.
2. Classify each battery as portable (sealed, under 4 kg), industrial or automotive.
3. If you place more than 1 tonne of portable batteries on the market a year, join an approved Battery Compliance Scheme. Otherwise register directly on NPWD with the right regulator.
4. Make sure every battery carries the crossed-out wheelie bin symbol, a capacity marking and any required chemical symbols.
5. Set up a way to track the tonnage and chemistry of the batteries you place on the market, by type.