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Producer responsibility in legislation

Based on Directive 2006/66/EC of the European Parliament and Council, the Waste Act (646/2011) decrees that producers must arrange the waste management of batteries and accumulators they place on the Finnish market at their own expense. The producers are also responsible for a reasonable portion of other equivalent, so-called orphan products. The portion is determined based on each producer’s market share.

Government Decree 520/2014 regarding batteries and accumulators 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 and accumulators is higher than 45%. Collected batteries and accumulators 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 and accumulators, 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 and accumulators 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.

Who is a producer?

Producer refers to a natural or legal person residing in Finland who professionally places batteries and accumulators, including batteries and accumulators contained in electric and electronic devices or vehicles, on the Finnish market for the first time, regardless of the method of sales (Government Decree 520/2014, Section 2).

According to the interpretative note of the authority supervising the producer responsibility, the responsibility pertains to Finnish manufacturers and importers, as well as the Finnish branches of foreign operators, that manufacture or import batteries and accumulators to the Finnish market. In practice, the producer responsibility in Finland only pertains to companies with a Finnish business ID. The interpretative note can be read at: www.ymparisto.fi/en-US

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The classification of batteries and accumulators

In principle, the producer responsibility concerns all batteries and accumulators, including batteries and accumulators contained in electric and electronic devices, vehicles or other products. Only batteries and accumulators 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.

In legislation, batteries and accumulators are divided into three classes:

1. Portable batteries and accumulators, which includes all sealed batteries and accumulators that can be carried by hand and are not industrial batteries or accumulators. We take care of these products. Register as a producer here.
2. Industrial batteries and accumulators, which includes batteries and accumulators designed exclusively for industrial or professional use or used in electric vehicles. No producer organisation has yet been established for non-lead-based industrial batteries and accumulators, so companies must carry out their producer responsibility by submitting an application to the producer register of the Centre for Economic Development, Transport and the Environment (ELY Centre) of Pirkanmaa.
3. Automotive batteries and accumulators, which includes batteries and accumulators used for automotive starter, lighting or ignition power. The automotive lead-acid battery and accumulator producer organisation Akkukierrätys Pb takes care of recycling these products on behalf of producers.

The primary intended purpose of the batteries and accumulators is the deciding factor in their classification. Additionally, the Batteries Directive provides a list of examples of batteries and accumulators that are to be deemed industrial. For example, all batteries and accumulators used for powering electric means of transportation are classified in legislation as industrial batteries or accumulators even if they are small-sized and sold directly to consumers. The authority supervising producer responsibilities has published its own classification instructions.