Selling batteries and using them when manufacturing goods

This guidance is relevant if you manufacture, import, sell or distribute batteries or electronic and electrical equipment (EEE) that contains batteries.

What you must do if you manufacture or import batteries

If you manufacture or import batteries or EEE containing batteries and place them on the UK market for the first time, you must:

ensure they contain only permitted levels of cadmium and mercury
label them correctly
keep records of the number and weight of batteries you place on the market
check if you need to join a producer compliance scheme
register with your environmental regulator.

If you design EEE or machinery that uses batteries you must:

make sure the batteries can be easily removed from the appliance
provide instructions showing how the battery can be removed safely from the appliance and name the battery type where appropriate.

Comply with restrictions on mercury and cadmium

You must not place a battery on the market if it contains more than 0.0005% mercury by weight. There is an exception for button cells, which must have less than 2% mercury by weight.

You must not place a portable battery on the market if it contains more than 0.002% cadmium by weight. There are exceptions to this rule for:

emergency equipment including alarms and lighting
medical equipment
cordless power tools. The exception for power tools ended on 1 January 2017.

Read our guidance on battery materials and labelling.

Label batteries correctly

If you manufacture or market batteries or battery packs you must label the battery with the crossed-out wheeled bin symbol.

The crossed-out wheeled bin symbol must be printed visibly, be easy to read and permanent. It must take up 3% of the area of the battery or 1.5% of the area of cylindrical batteries.

The symbol size should not be greater than 50x50mm. If the symbol will be smaller than 5x5mm because of the size of the product then it should be printed on the battery packaging and measure at least 10x10mm.

If you place a battery on the market containing mercury, cadmium or lead you must ensure that you label it correctly.

Hazardous substances in batteries	What you must do
Mercury	If you place a button battery on the market that contains more than 0.0005% mercury it must be marked clearly with the chemical symbol Hg below the crossed out wheelie bin.
Cadmium	If you place a battery on the market that contains more than 0.002% cadmium it must be marked clearly with the chemical symbol Cd below the crossed out wheelie bin.
Lead	If you place a battery on the market that contains more than 0.004% lead it must be marked clearly with the chemical symbol Pb below the crossed out wheelie bin.

Read our guidance on battery materials and labelling.

Keep records

You must keep records of the types and total weight of batteries you produce and place on the market per year.

Join a battery compliance scheme if you produce or market portable batteries

If you produce or market more than one tonne of portable batteries or products containing batteries or accumulators per year you must join a battery compliance scheme.

Portable batteries are small sealed batteries commonly found in household appliances, such as AAA cells, mobile phone batteries and button cells found in watches.

The battery compliance scheme will collect, treat and recycle your batteries on your behalf. The amount you have to pay will depend on the individual battery compliance scheme and the amount of batteries you produce or market.

Register with your environmental regulator

You must register with your environmental regulator using the National Packaging Waste Database (NPWD) if you produce or place on the market:

one tonne or less of portable batteries per year
industrial or automotive batteries.

You must apply to be registered using the NPWD within 28 days of the first day you place batteries on the market.

National Waste Packaging Database (NWPD)

Contact your environmental regulator

If you export batteries or products containing batteries to other EU counties you will have to register with the regulators in those countries and comply with local regulations.

For more information, read our guidance for battery producers.

Batteries regulations

Take back waste industrial batteries free of charge

If you produce industrial batteries you must take back waste batteries free of charge from customers if:

you supply new batteries
the end user can't return waste batteries to their actual producer and you have previously placed the same type of battery on the market
the end user can't return waste batteries to any other producer.

For more information, read our guidance for producers of industrial and automotive batteries.

Collect vehicle batteries for free

If you produce vehicle batteries you must collect waste vehicle batteries free of charge from the final holders, such as civic amenity sites or garages.

What you must do if you sell or distribute batteries

Take waste batteries free of charge

If you are a retailer or distributor and you sell more than 32kg of portable batteries you must take back waste batteries in-store for free. If you only supply batteries contained in products you do not have to take back waste batteries in store.

Dispose of waste batteries correctly

You must not incinerate or landfill vehicle and industrial batteries.

If you collect batteries, you must:

send them for treatment or recycling at an approved batteries treatment centre, or
send them abroad for treatment or recycling by an approved battery exporter.

You will need to deal with all unsorted waste batteries and some other waste batteries as hazardous/special waste.

Good practice

Recycle waste batteries.

Use rechargeable batteries in the equipment and machinery you produce and service.

Store batteries safely and ensure that drainage from your store goes to the foul treatment system.

Further information on manufacturing and importing batteries

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