Portable batteries: distributor and retailer responsibilities
If you supply 32 kilograms or more of portable batteries per year to end users, you must allow all end users to return waste portable batteries free of charge. If you have more than one retail outlet, you only have to take back batteries at those that supply more than the 32 kilogram threshold. The responsibilities apply even if you are using distance selling methods.
One pack of four AA batteries per day is approximately 32 kilograms per year.
You must:
- ensure there is a free collection point for all kinds of waste portable batteries, not only the types you supply
- provide information to end users about your take-back arrangements
Only batteries supplied separately from equipment count towards the 32 kilograms threshold. Distributors of equipment containing portable batteries - such as laptop computers or mobile phones - do not have to take back waste portable batteries unless they also supply portable batteries separately.
You must not charge end users for returning waste portable batteries. They can drop off waste portable batteries without having to buy new batteries. You must not show customers the separate cost of collecting, treating and recycling batteries.
If you have a collection point for customers waste batteries, you do not need a waste management licence to store them on site. When they are moved, or collected by a registered waste carrier, you must treat them as Hazardous/special waste. (Alkaline batteries are not considered as hazardous/special waste, however a mixed load will probably contain batteries containing lithium, cadmium or mercury. You will need to pre notify SEPA/NIEA and use a consignment note.
Point-of-sale information
You must provide information to customers about your take-back facility, including the location of your take-back facility and how it can be used. To help you with this you can download posters and identifiers.
If you supply portable batteries online or by mail order, you could include the identifier on your website or on other relevant documentation. You will still need to provide the information about your take-back service, however.
Store waste batteries securely
You should collect waste batteries in secure containers.
If you store waste portable batteries at a collection point, this activity is automatically exempt from waste management licensing, so you will not need to register an exemption.
If you intend to transport the waste batteries you collect yourself, you must comply with controls on special waste and dangerous goods.
GOV.UK: Battery waste - producer and supplier responsibilities
You must also ensure that the batteries collected are taken for recycling. Distributors with obligations to have a take-back system are entitled to request a free collection from battery compliance schemes (BCSs).
BCS duties
You should contact a BCS to arrange for the waste batteries that you have collected to be taken away. The BCS must respond within 21 days in order to make arrangements for collection. The collection must be free of charge to the distributor.
Distributors below the 32 kilogram threshold
If you supply less than 32 kilograms of portable batteries in a year, you have no waste portable battery take-back responsibilities. You can still choose to collect waste batteries, but you will not be entitled to free collection by a BCS. You may need to arrange for the transport and disposal of the waste portable batteries that you have collected yourself. You must therefore comply with controls on special waste and dangerous goods.
It is recommended that you contact a BCS or your waste contractor before you start collecting waste portable batteries to find out what recycling options they operate that you may be able to access.