Guidance

Reporting portable batteries that have been exported from the UK

Updated 12 May 2022

This guidance explains:

• when producers and schemes can deduct exports from their batteries data
• how the Environment Agency collects and reviews batteries data

This change took effect in January 2019.

What has changed

The Batteries Regulations 2009 were amended to allow producers and compliance schemes to deduct portable batteries they export outside the UK from their reported batteries data.

This ensures that:

• UK national targets do not include batteries that will never become waste in the UK
• each producers’ targets are only based on the batteries they have placed on the UK market that stay in the UK
• our approach is in line with EU member states

Keep evidence of deducted exported batteries

Compliance schemes must not provide batteries data where producers have estimated the amount of batteries they have exported.

Producers must keep evidence of how many batteries were:

• placed on the market initially
• exported as new batteries in the same compliance year

Examples of evidence include invoices and bills of lading.

You can then deduct these batteries for the data you report.

Here are 4 examples of when you can deduct exported batteries from your reported data.

Example 1

Producer A declares batteries placed on the market. Some of these batteries are sold to company B within the same corporate group. Company B then exports some or all of these batteries.

Company A is able to deduct the exported batteries from their batteries data providing Company A can show evidence that the exports took place for the deducted batteries.

Example 2

Producer C declares batteries placed on the market. Some of these batteries are sold to company D. Company D is a trader who consolidates batteries from a number of different producers before exporting them.

Where company C can prove these batteries have been exported by company D then the exported batteries can be deducted from their batteries data.

Example 3

Producer E declares batteries placed on the market and puts them into stock. Some of these batteries are then sold to an export customer by producer E.

As long as the export takes place during the same compliance period that the batteries were reported as placed on the market, company E can deduct the exported batteries from their batteries data.

Example 4

Company F imports batteries, declares the batteries placed on the market in 2018 and puts them into stock. Some of these batteries are then sold to company G, who exports the batteries in January 2019.

Because the export has not taken place during the same compliance period that the batteries were reported as placed on the market, company F cannot deduct the exported batteries from their batteries data.

Contact the Environment Agency

There may be other situations where exported batteries can be deducted from batteries data. Please contact the Environment Agency if you are unsure about your situation.

How the Environment Agency checks compliance

The Environment Agency will check that reported data can be justified during its routine compliance monitoring.

Reporting exported batteries data

If, after submitting your quarterly return, batteries are subsequently exported, you must re-submit the return for that quarter. You must remove any exported tonnage from the initial amount placed on the market. You do not need to send the Environment Agency a separate report to show the tonnage of batteries that have been exported by each producer.

The last date the Environment Agency will accept resubmissions of battery data is 28 February.