Whilst most customers support the principle of the new regulations covering battery disposal, in practice, they will be keen to keep the cost of compliance to a minimum. Fortunately, there is a very straightforward way of avoiding holding the compliance baby. The regulatory burden is placed squarely on the shoulders of the ‘producer’ which is defined as the first person in the supply chain that physically receives and takes ownership of the product in the UK. Most of the battery product in the UK is imported and first received by either a battery distributor or a direct account of the battery manufacturer and both are now defined as a ‘producer’ under the new regulations. So if you source from a distributor with a UK warehouse, they and not you are responsible for complying with the regulations.
The regulations apply to all types of batteries including automotive, portable (household) batteries (AAA / AA / coin cells etc.) and industrial batteries. As of September this year anyone directly importing these products into the UK will be deemed a battery “producer” under the Waste Batteries and Accumulators Regulations 2009, with responsibility for ensuring that they take back and recycle all batteries that are returned to them – regardless of whether or not they have sold them in the first place.
Producers should have started keeping detailed records of all battery products supplied to the market by weight and chemistry in from 5 May 2009. Their obligations then depend on weight and vary slightly depending on the type of product sold. If you place one tonne or more of portable batteries on the market per year you will have to pay for the collection, recycling and disposal of waste batteries in proportion to your market share from 1 January 2010. You will have to register with a battery compliance scheme that will arrange the collection, recycling and disposal of batteries on your behalf by 15 October 2009. The details are slightly different for automotive and industrial batteries but the principles are exactly the same.
The only exception is for product that is subsequently exported – this is exempt from the regulations. If you’re sourcing your batteries direct from a manufacturer with a warehouse in the Far East, for example, or are using a supplier with a pan-European stocking location outside the UK, then you are responsible for complying with these regulations.