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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 accumulator
2. Industrial batteries and accumulators
3. Automotive batteries and accumulators

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.

Recser Oy’s internal classification  

Recser Oy has further divided batteries and accumulators into their own sub-classes based on their size. In practice, you can take care of your producer responsibility for all batteries and accumulators whose size allows for easy manual carrying and/or batteries and accumulators sold to consumers fully through Recser Oy, regardless of the intended purpose of the products.  

You can transfer your producer responsibility for large industrial batteries and accumulators to Recser Oy in part, meaning that you can register as a producer and fulfil your reporting obligations to the responsible authority through us. The producer is responsible for organising the reception of large industrial accumulators and other waste management. 

You can take care of your producer responsibility fully or in part through Recser Oy for the following batteries and accumulators: 

1. Portable batteries and accumulators
   A portable battery or accumulator refers to a battery, accumulator or battery unit that is sealed, can be carried manually and is not an industrial or automotive battery or accumulator. (Government Decree 520/2014, section 2, subsection 1, paragraph 4). Examples of portable batteries include AA and AAA batteries and the batteries and accumulators used in mobile phones, laptops, toys, cordless tools and electric toothbrushes.
2. Portable industrial batteries and accumulators
   A portable industrial battery or accumulator refers to an industrial battery or accumulator, within the meaning of the Government Decree on batteries and accumulators (Government Decree 520/2014, section 2, subsection 1, paragraph 7), the size of which allows for easy manual carrying. Portable industrial batteries and accumulators include those designed exclusively for industrial and professional use, as well as batteries and accumulators sold to consumers to be used in electric vehicles (excluding the traction batteries of electric motorcycles).Examples of portable industrial accumulators include accumulators used in electric means of transport, such as electric bicycles, electric scooters and self-balancing unicycles, and in devices such as various manually operated payment terminals in professional use. Portable industrial batteries and accumulators also include the back-up batteries of electrically operated doors and various batteries and accumulators used in measurement and instrument equipment.
3. Portable lithium automotive batteries and accumulators
   A portable lithium automotive battery or accumulator refers to a lithium-based automotive battery or accumulator, within the meaning of the Government Decree on batteries and accumulators (Government Decree 520/2014, section 2, subsection 1, paragraph 6), that is sealed and the size of which allows for easy manual carrying. Automotive batteries and accumulators include those used for automotive starter, lighting or ignition power. Portable lithium automotive accumulators do not include lithium automotive accumulators used in cares (lithium starter batteries). Examples of portable lithium automotive accumulators include the starter batteries of mopeds, motorcycles, ATVs, scooters and ride-on lawn mowers.
   

You can take care of your producer responsibility in part through Recser Oy for the following batteries and accumulators:

1. Large industrial accumulators
   A large industrial battery or accumulator refers to an industrial battery or accumulator designed exclusively for industrial or professional use, within the meaning of the Government Decree on batteries and accumulators (Government Decree 520/2014, section 2, subsection 1, paragraph 7), the size of which does not allow for easy manual carrying. In this context, large industrial batteries and accumulators do not refer to the accumulators of electric vehicles, such as electric and hybrid cars, in which the accumulator is integrated into the device and not intended for the end user to remove at any point. Examples of large industrial accumulators include, but are not limited to batteries and accumulators used for emergency or back-up power in hospitals, airports or offices, batteries and accumulators used in trains and aircraft, forklift batteries and batteries and accumulators used on oil rigs at sea and in lighthouses.

Additionally, the following battery and accumulator types have their own producer organisations:

1. Lead-based automotive batteries and accumulators
   Lead-based automotive batteries and accumulators are 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.
2. Traction batteries of electric cars
   Traction batteries of electric cars refer to the energy reserve needed for operating an electric or hybrid vehicle, including cars, vans, trucks and buses. Traction batteries also include auxiliary batteries, meaning the energy reserve needed for operating the auxiliaries of electric or hybrid vehicles. Finnish Car Recycling Ltd has been approved as a producer organisation for the traction batteries of electric vehicles.  

You can take care of your producer responsibility for other batteries and accumulators by submitting an application to the producer register (tuottajarekisteriin) or by establishing a producer organisation (perustamalla tuottajayhteisön) together with other producers.