Collecting batteries and accumulators

Do you produce, import, or sell (products containing) batteries or accumulators in the Netherlands? Your business may have extended producer responsibility. This means you are responsible for managing the collection and recycling of discarded batteries, accumulators, or the products in which batteries are integrated, such as e-bikes, smartphones, electric cars, or electric toothbrushes .

What is extended producer responsibility (EPR)?

As a producer (manufacturer or importer) you are responsible for the waste management of batteries and accumulators you put on the market in the Netherlands. You must collect and process discarded batteries and accumulators, or arrange this in cooperation with other producers.

When do you have extended producer responsibility?

You have extended producer responsibility (uitgebreide producentenverantwoordelijkheid, UPV) for batteries and accumulators if your business:

• is the first to market batteries or accumulators (or products containing these) in the Netherlands under your own brand or name (producer)
• is the first to trade in (products containing) batteries or accumulators in the Netherlands under your own brand or name (trader)
• is the first to import and market batteries or accumulators (or products containing these) in the Netherlands (importer)
• sells from abroad directly to end users (consumers) in the Netherlands (importer)

Check to see if your business has producer responsibility with Stichting OPEN.

What do you have to do if you have EPR?

If you have EPR, you must:

• notify Rijkswaterstaat (in Dutch, scroll down and choose mededelingsformulier batterijen en accu’s) how you intend to collect and process these batteries
• collect the batteries and accumulators you put on the market
• provide a nationwide collection network
• recycle batteries using the cleanest and best way possible
• inform end users (consumers) on the importance of separate battery collection
• submit a report to Rijkswaterstaat (in Dutch, scroll down and choose verslagleggingsformulier batterijen en accu's) each year before 1 August. In this report you state the weight of batteries you brought to Dutch market and the weight of batteries you collected and processed in the previous year.

Collective organisation EPR

You can meet your obligations on your own, or with other producers. You can join a collective organisation. They can tell you what your obligations are and help you with the collection and recycling.

For specific products it is compulsory to register with a collective organisation. Then there is a general binding statement(algemeen verbindend verklaring, AVV)(in Dutch). There are AVVs for:

• portable batteries up to 3 kilo
• industrial batteries up to 1 kilo
• bicycle batteries

You must register with Stichting OPEN, and pay a waste management fee. Unless you have an exemption.

You must register batteries for cars, such as starter batteries and EV-batteries with Auto Recycling Nederland (ARN).

Take-back obligation

Retailers selling (products containing) batteries and accumulators must take back discarded batteries and accumulators free of charge. They must inform the consumer where they can hand in the batteries.

If you want to provide a batteries collection point, you can register at the Stichting OPEN website.

Reusing discarded batteries

Does your company process or reuse discarded batteries or accumulators in new products for sale (refurbish or repurpose)? Then you may also have extended producer responsibility.