Collecting and recycling batteries

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

What is extended producer responsibility (EPR) for batteries?

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

• portable batteries
• batteries for light vehicles such as electric bicycles (LMT batteries)
• batteries for electric vehicles such as electric cars
• starting, lighting and ignition batteries
• industrial batteries

When do you have extended producer responsibility?

You have extended producer responsibility (uitgebreide producentenverantwoordelijkheid, UPV) for batteries if your business is established in the Netherlands, and you:

• are the first to bring batteries, or products containing these, on the Dutch market under your own brand or name
• resell batteries, or products containing these, in the Netherlands under your own brand or name
• import and supply batteries, or products containing these, in the Netherlands on a professional basis for the first time

You also have extended producer responsibility if your business is established abroad and you sell batteries, or products containing these, online directly to end users (consumers or businesses) in the Netherlands. You must have an authorised representative in the Netherlands who manages your EPR obligations.

You also have EPR if your company processes, repairs, or reuses discarded batteries in new products (refurbished or repurposed).

You can check 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 do the following:

• You must apply for approval and registration as a producer with Rijkswaterstaat before you put batteries on the Dutch market (in Dutch).
• As a distributor or online platform, you must check whether producers are registered in the register of producers before making the batteries available on the market (in Dutch).
• You must collect the batteries you put on the market. How you should do this, depends on their category (in Dutch).
• You must meet the minimum targets for collection, recycling, and recovery of materials (in Dutch).
• You must ensure that batteries are recycled using the cleanest and best way possible.
• You must cover the costs for the collection, transport, and recycling of batteries. And the costs for informing end users on the importance of separate battery collection, and for your battery records (in Dutch).
• You must submit a report each year before 1 August. In this report you state, among other things, the weight of batteries you brought to Dutch market and the weight of batteries you collected and processed in the previous year. You must use the digital form of Rijkswaterstaat (in Dutch) or contact Rijkswaterstaat via email to producentenverantwoordelijkheid@rws.nl to do so. 

Collective organisation EPR

You can meet your obligations on your own, or with other producers. You can join a collective organisation. They take care of a number of your EPR obligations, such as submitting the forms for approval and registration, collecting batteries, and submitting the annual the report.

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 5 kilograms
• industrial batteries up to 1 kilogram
• 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 for retailers and online platforms

Retailers selling (products containing) batteries must take back discarded batteries free of charge. Online platforms must ensure there are enough collection points and inform their customers where they can hand in the batteries.

If you want to provide a batteries collection point, you can register with Stichting OPEN.