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Are you a Producer?

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Are you a Producer?

Electronic recycling cycle

Are you a Producer?

How can you tell if you are a producer by answering the following questions?
 
1. Do you market your product in Spain through imports or intra-EU acquisitions?

2. Do you manufacture batteries in Spain?

3. Does another company manufacture your brand?

4. Do you sell products online in Spain?

If the answer to any of these questions is YES, you are a producer of batteries and should be aware of how you are affected by Royal Decree 106/2008, of February 1, on batteries and accumulators and the environmental management of their waste, and its subsequent amendment by Royal Decree 710/2015, of July 24.
 

Who is a Battery Producer?

Article 3 of Royal Decree 106/2008 establishes the definition of producer as:

“Any natural or legal person who, regardless of the sales technique used, places batteries or accumulators on the market for the first time, including batteries or accumulators incorporated into appliances or vehicles, within the framework of a professional activity. The sales techniques used include distance communication, as defined in Law 47/2002, of December 19, amending Law 7/1996, of January 15, on the Regulation of Retail Trade, for the transposition into Spanish law of Directive 97/7/EC on distance contracts and for the adaptation of the law to various Community directives.”

Producers have a series of obligations as established in Law 7/2022 and the regulations regarding batteries, accumulators, and rechargeable batteries, including:
  • Regulation of registration in the Integrated Industrial Registry, in the Batteries, Accumulators, and Rechargeable Batteries section.
  • Reporting data on products introduced and marketed in Spain through a declaration.
  • Complying with the obligation to provide information on invoices regarding the assigned producer number.
  • Complying with product marking obligations.
  • Complying with waste collection targets.

*SUN RE - BATTERY will handle the registration process at the time of membership and on behalf of the producer.

Declaration of batteries, accumulators and batteries

The producer must report quarterly, before the 20th of the following month, the data report containing information on the quantity of batteries, accumulators, and rechargeable batteries introduced and marketed in Spain during that period, through the corresponding quarterly declaration report.

The declaration data can be submitted through the intranet, which is intuitive, easy to use, and has a personalized space for each producer.

After the deadline for reporting the battery declaration, SUN RE-BATTERY will transfer the information received to the Ministry to comply with the obligation to report the data of producers introduced and marketed in Spain by companies participating in the SCRAP.

Upon completion of the process, the producer will receive an invoice based on the information and data on what has been placed on the market and the rates (recycling rate) established by SUN RE-BATTERY.

Other obligations

Manufacturers shall mark batteries, accumulators, and rechargeable batteries placed on the market with the illustrated symbol in order to maximize the collection of properly separated batteries and accumulators. This symbol shall be included in a visible, indelible, and legible manner on each device. In exceptional cases, if necessary due to the dimensions or function of the product, the symbol shall be printed on the packaging, in the instructions for use, and on the warranty for batteries and accumulators.

Battery and accumulator manufacturers shall specify through a mark on the device that it was placed on the market after August 13, 2005, or September 26, 2009, to clearly establish that the waste generated will not be considered historical waste. This marking shall be carried out in accordance with standard UNE-EN 50419 or any standard that replaces it and shall be included in a visible, indelible, and legible manner on each device.
 

 
The producer must include their Identification Number provided by the Integrated Industrial Registry of Battery, Accumulator, and Battery Producers (RII-PYA) in their commercial transactions (invoices or documents relating to the transaction or website for online commerce), as a guarantee to the buyer that they comply with the obligations set forth in this Royal Decree.
 
Standard phrase to include on invoices: “RII-PYA No.: _______”
 
NOTE: THE COST OF MANAGEMENT CANNOT BE REFLECTED ON THE TICKET OR INVOICE.
(According to Article 19 of RD WEEE 106/2008)

*Indicate in the instructions for EEE and batteries and accumulators that before depositing WEEE at the collection facilities, the batteries must be removed and deposited separately for proper management.
 

How to Comply?: Adhesion Procedure

To join SUN RE-BATTERY, follow the procedure below:
  1. Registration Form: The company must complete the Registration Form through their personal account. Once completed, SUN RE-BATTERY will review the information for accuracy.
  2. Contract: The contract will be prepared using the information on the form and signed by both parties.
  3. Registration Formalization: SUN RE-BATTERY will be responsible for registering the company in the Integrated Industrial Registry of Battery and Accumulator Producers (RII-PYA).

WHEN THERE IS A CHANGE OF SCRAP:

If the company is already registered with another SCRAP and joins the SUN RE-BATTERY association, the steps to follow are as follows:
  1. The company must submit the deregistration request to its former SCRAP.
  2. Formalize its membership in the SUN RE-BATTERY SCRAP using the aforementioned procedure.
  3. Notify the Ministry of the change of SCRAP (during the last quarter of the year).

 
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