Are you a batteries producer?
In the Directive itself the definition of “Producer” is as follows:
“‘Producer’ means any person in a Member State that, irrespective of the selling technique used, including by means of distance communication as defined in Directive 97/7/ EC of the European Parliament and of the Council of 20 May 1997 on the protection of consumers in respect of distance contracts (1), places batteries or accumulators, including those incorporated into appliances or vehicles, on the market for the first time within the territory of that Member State on a professional basis”.
The UK Batteries Regulations will introduce Producer Responsibility obligations which is now an increasingly common approach (e.g. WEEE Regulations and Waste Packaging Regulations) for EU environmental legislation. It basically places a reporting and financial burden on companies who are deemed to be classified as a “Producer” so that they are responsible for their own market share percentage of the overall cost of the collection and recycling of batteries placed on the UK market. This will then ultimately ensure that the EU targets are met by the UK.
Batteries and accumulators have many different routes to market. It is expected that producer obligations will fall on the following persons:
Businesses will be deemed producers in this context if they are:
- UK manufacturers of batteries placed on the UK market
- Domestic Original Equipment Manufacturers, if products include batteries when placed on the market
- Businesses that assemble battery packs
- Private label owners
- Importers of batteries placed on the UK market
- Importers that are themselves retailers
- Importers supplying to retailers or wholesale customers
- Importers supplying batteries (inclusive of battery packs) to electrical and electronic equipment (EEE) producers
- Importers of appliances and vehicles containing overseas-sourced batteries placed on the market for the first time
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