Producer responsibility for batteries

Who has producer responsibility?

Environmental legislation on batteries and accumulators sets out producer responsibility; this means that if you produce or import batteries in view of reselling them in Denmark, you must contribute to the organisation and financing of take-back and management of those batteries when they reach the end of their service life. As a producer or importer your business must be registered in a register and report once a year the volumes sold in the Member State.

In Denmark the rules on producer responsibility are administered by DPA.

Producer or importers?

If you produce or have a battery product produced in your own name/brand, you are subject to producer responsibility, including duties to register, take back, and report on batteries sold in Denmark.

If your business buys batteries from an EU country or a country outside the EU and you import them to Denmark in view of selling this product to a dealer or an end-user your business is an importer and has the duty of registration and reporting in Denmark. Your business also has a take-back obligation for the product in Denmark.

Producers and importers are generally referred to as “producers”, since the rules are the same for both types of business

Which products are covered?

All types of batteries – and a few exemptions

The producer responsibility system concerns all batteries. However, in relation to registration and reporting the batteries are divided into automotive batteries, portable batteries, and industrial batteries as well as the substance groups lead, cadmium, mercury, and other.

It is important that you are clear on which type of battery you sell; the requirements for registration and reporting are based on this classification, and there are different rules depending on the type of battery you sell.

If you import electrical products or vehicles, you have a separate producer responsibility for the batteries contained in such products

How to proceed?

For any business subject to producer responsibility there are requirements you must see to yourself, while other tasks can be delegated to others. In the following list you can see what you must do yourself and what other players such as compliance schemes can do on your behalf.

Note that even if others can do this or that on your behalf, they do not take over your producer responsibility.

The duties may be assumed by the producer or the importer himself (individual compliers) or the producer/the importer may choose to carry out these tasks together with other producers or importers. This is called compliance schemes.