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Are you a Producer?

Are you a Producer?

Electronic recycling cycle

Are you a Producer?

Do you put product on the Spanish Market through an import? Do you manufacture Electrical or Electronic Equipment (EEE) in Spain? Even though your company manufactures in another country, do you have a headquarters in Spain that is in charge of sales and distribution? Does another company manufacture your products by putting your brand on it? Do you sell products in Spain online?

If the answer to any of these questions is YES, you are a "PRODUCER OF ELECTRICAL OR ELECTRONIC EQUIPMENT (EEE) " and you should know how RD 110/2015 affects you:

Who is a Battery Producer?

Article 3 of Royal Decree 710/2015 on Batteries and Accumulators establishes that the status of PRODUCER of Batteries and Accumulators is any natural or legal person who, regardless of the sales technique used, puts batteries on the market for the first time. Batteries or Accumulators, including Batteries or Accumulators incorporated into devices or vehicles, within the framework of a professional activity.

Quarterly Communications

Before the 20th day of the month following the expired quarter, the producing company will carry out the COMMUNICATION of the quantities of Batteries and Accumulators placed on the market during that expired quarter (units and Kilos).

The data of said COMMUNICATION will be entered through the new INTRANET in sunrebattery.eu, which is intuitive, easy to use and with a personalized space for each Producer.

Once the communication is made on the website of the SUN RE – BATTERY Association, our Association will ensure that this information is sent to the Ministry, as established by the Regulations.

At the end of the process, the Producer company will receive an invoice according to the number of devices placed on the market and the rates (Recycling Rate) established between the SUN RE-BATTERY Association and the company.

In this way, and on a quarterly basis, the company must pay the amount of the invoice, which will be obtained by multiplying the Recycling Fee by the number of Kilos or units placed on the market by the company.

Other obligations

  • Registration of the manufacturing company in the RII-PYA (Industrial Integrated Registry of Batteries and Accumulators Producers) and updating of the information so that it can be modified. (SUN RE - BATTERY WILL BE IN CHARGE OF CARRYING OUT THIS OBLIGATION/PROCESS AT THE TIME OF ACCESSION AND ON BEHALF OF THE PRODUCING COMPANY).
  • Quarterly COMMUNICATION: The producing company must send Quarterly the data of the Products placed on the Market in Units and Kilos
  • Proceed to marking with the symbol of the crossed out bin.

The producers will mark, with the illustrated symbol, the Batteries and Accumulators that are placed on the market in order to maximize the collection of properly separated Batteries and Accumulators. This symbol shall be included in a visible, indelible and legible form on each device. In exceptional cases, if necessary due to the dimensions or function of the product, the symbol will be stamped on the packaging, in the instructions for use and in the Batteries and Accumulators guarantee.

The producers of Batteries and Accumulators will specify through a mark on the device that it was placed on the market after August 13, 2005/September 26, 2009, to unequivocally determine that the waste generated will not have the historical consideration. This marking will be carried out in accordance with the UNE-EN 50419 standard or the one that replaces it and will be included in a visible, indelible and legible way on each device. Accumulators guarantee.

  • The producer must include your Identification Number provided by the Integrated Industrial Registry of Batteries and Accumulators Producers (RII-PYA) in its commercial transactions (invoices or document related to the transaction or web page for online commerce), so that it is a guarantee for the buyer that he complies with the obligations set forth in this royal decree.
Phrase type to include in Invoices: "RII-PYA No.: _______"

(According to art.19 of RD WEEE 106/2008)
  • Indicate in the Instructions of EEE and Batteries and Accumulators, that before depositing WEEE in the collection facilities, the batteries must be removed and deposited separately for proper management.

How to Comply?: Adhesion Procedure

To adhere to the Collective System of Extended Producer Responsibility (SCRAP) SUN RE - BATTERY, the following procedure must be followed:
  1. ADHESION FORM     The company must complete the "Adhesion Form" that you will find on the web sunrebattery.eu. Once completed, SUN RE - BATTERY will check that the data is correct.
  2. CONTRACT     With the details of the Adhesion Form, SUNREUSE ASSOCIATION will prepare and send the Contract that must be signed by both parties.
  3. FORMALIZATION OF REGISTRATION     The SUN RE - BATTERY association will be in charge of registering The Integrated Industrial Registry of Battery and Accumulator Producers (RII-PYA) of the Ministry of Industry, Commerce and Tourism (MINCOTUR) ↓
Obtaining by assignment of the Ministry of the number RII-PYA


In the event that the company was already registered in another SCRAP and proceeds to join the SUN RE - BATTERY association, the PREVIOUS steps to follow would be the following:

The SUN RE - BATTERY association will be in charge of preparing the Deregistration Request in the old SCRAP.
  1. Registration in the SCRAP SUN RE - BATTERY with the aforementioned procedure.
  2. Communication to the Ministry of the change in SCRAP (during the last quarter of the year).