What is producer responsibility? / Producer responsibility in legislation / Classification of batteries / Large industrial batteries / Registering as a producer / Fees / Reporting / Certificate / Labelling / Case Canon / Case GPBM / Case Celltech / FAQ for producers
Government Decree 520/2014 regarding batteries provides more details regarding the arrangement of the waste management. The Decree states that the producers must make sure that the annual separate collection rate for batteries is higher than 45%. Collected batteries must be recycled using the best available techniques. Additionally, producers must provide households and other users with comprehensive information about the environmental effects of batteries, the significance of separate collection and available collection sites.
All producers are also entered either through a producer organisation or directly into an authority register. For producers of portable batteries that are entered directly into an authority register, the obligation to pick up discarded products from distributors is heavy, so the easiest way to take care of the producer responsibility is to arrange it through an existing producer organisation.
Producer refers to a natural or legal person who regardless of the method of sales professionally places batteries on the Finnish market for the first time or distance sells batteries directly to users in Finland, including batteries contained in electric and electronic devices or vehicles. (Waste Act, Section 48).
In principle, the producer responsibility concerns all batteries, including batteries contained in electric and electronic devices, vehicles or other products. Only batteries designed for military purposes, for products related to the monitoring of key national security interests or for products designed to be sent into space are not subject to the producer responsibility.
Read about the classification of batteries here.
a) Finnish manufacturer or importer
If your company imports or manufactures batteries or devices containing them to the Finnish market, you can transfer your producer responsibility obligations to Recser Oy by registering as a producer.
b) Foreign distance seller
Registration requires an authorised representative established in Finland. You can appoint Recser Oy as your authorised representative directly on the registration form as follows:
You can obtain further information on the pricing of the service by requesting it by email at info(a)recser.fi.
If you wish, you may also appoint another authorised representative established in Finland, who will enter into an agreement with Recser Oy for the management of producer responsibility obligations. In this case, enter the details of that operator in the same section of the form.
c) Operator comparable to a producer
Operator comparable to a producer is a foreign company that delivers products to the Finnish market by means other than distance selling. Operator comparable to a producer can be for example an internationally operating large company that supplies its products to a Finnish importer.
You can assume the producer responsibility obligations of a Finland-based producer by making an agreement with Recser Oy. In the ‘Additional information’ field of the form, enter the names of the Finland-based producers whose obligations you want to assume responsibility for (name, business ID and website of the producer).
Alternatively, you may authorise an authorised representative established in Finland to conclude the above-mentioned agreement with Recser Oy on your behalf. In this case, on the registration form, under “Select an authorized representative for the contract”, choose “Other” and enter the details of the relevant operator.
An operator choosing to take care of producer responsibility on behalf of another party must notify the producers and the producer organisation that would otherwise be responsible for the producer responsibility obligations of the fulfilment of the obligations, any changes therein or any cancellations thereof.
d) Online sales platform administrator
As the administrator of an online sales platform, you can assume responsibility for the obligations of distance sellers operating on the platform on their authorisation by registering as a producer for Recser Oy. Please note that you will need a written authorization from the distance sellers operating on the platform.
You can obtain further information on the pricing of the service by requesting it by email at info(a)recser.fi.
If you wish, you may also appoint another authorised representative established in Finland, who will enter into an agreement with Recser Oy for the management of producer responsibility obligations. In this case, enter the details of that operator in the same section of the form.
Did you recognize your company from any of the options above?
Section 54 of the Waste Act requires producers to keep records, by product type, of the batteries and accumulators that they release onto the market and to publish annual information online about the batteries and accumulators that they have collected and recycled. Producers that have transferred their producer responsibility to Recser should, at minimum, disclose that information on collection and recycling can be found on Recser’s website. Producer-specific collection and recycling amounts can be calculated using our ‘Tuottajan puolesta kierrätetty’ (‘Recycled on behalf of the producer’) calculator.
Section 55 of the Waste Act also stipulates that when delivering a product to a distributor, a producer is obligated to inform the distributor of the distributor’s entry into a producer register or producer organisation. Companies that have transferred their producer responsibility to Recser can communicate that they have fulfilled their producer responsibility regarding batteries and accumulators using the producer label on their websites, for example.
