1. Do I include the recycling fee for portable batteries (BaA) as well?
Recycling fee is not displayed on batteries and accumulators. This obligation applies only to household electrical and electronic equipment.
2. When a portable battery is part of the electrical or electronic equipment, are the electrical equipment and the battery reported separately?
Yes, when a battery or accumulator incorporated into electrical or electronic equipment it must be reported separately. You should know, as a producer of the given device, the weight rate of EEE and BaA. Alternatively, turn to your supplier (the real producer of the device in question) who should be able to provide you with this information.
3. What is considered a battery? How are the batteries categorized?
Battery or accumulator is any source of electrical energy generated by direct conversion of chemical energy and consisting of one or more primary non-rechargeable battery cells or consisting of one or more secondary rechargeable battery cells. Batteries and accumulators belong to the following categories:
4. Do I register BaA when importing or when selling?
A producer can choose the method for evidence retaining which suits to him, however, it is important it will allow filling of required data within the defined scope in the NATUR-PACK system, who is submitting the summary report on behalf of all producers represented and retains the reported data. If a producer (PRO NATUR-PACK client) can not manage the evidence he can turn to his sales representative who will recommend to him the appropriate keeping of records respecting the reserved products and company profile. Such recommendation is not binding for the company.
5. Why do customers ask me for registration information when I only distribute batteries?
Obligations of a producer can also apply to a distributor in case when he provides batteries and accumulators to the end user, and these batteries and accumulators originate from a producer who is not enlisted in the Register of producers of batteries and accumulators, regardless of whether it is the batteries themselves or those which are incorporated into appliances or vehicles. For this reason, your clients may request information about registration in the register.
6. Do I have to collect the used batteries from the customer? Are there any conditions or exclusions?
Distributor of portable batteries and accumulators is obliged in relation to the waste portable batteries and accumulators:
- To ensure re-collection in his sales points regardless of their brand and date of placing on the market over the entire lifespan of batteries and accumulators,
- To inform the end users on a possibilities of free re-collection on his web-page, if he has one, and on place which is visible and publicly accessible during sales of portable batteries and accumulators,
- To ensure re-collection on site of delivery of portable batteries and accumulators or site of storage if distributing portable batteries and accumulators to the end user exclusively within mail order, including electronic sales; if he does not have such a place or such a warehouse, then at a place agreed with the producer of portable batteries and accumulators.
Re-collection shall be carried out without the obligation to purchase goods in the given sales point.
7. What other obligations do I have as a BaA producer apart from registration in the register of battery producers?
You can find information on the basic obligations of the producer of batteries and accumulators HERE.
8. Who controls the fulfillment of BaA producer/distributor obligations in the company?
Ministry of Environment SR and Slovak Environmental Inspection are the control authorities. State administration in the sector of the waste management is performed also by:
- Slovak Trade Inspection, a state supervisory authority in the waste management sector controlling the performance of certain obligations of the Waste Act, e.g. obligation to label the batteries and accumulators or a prohibition to place on the SR market certain types of batteries and accumulators.
- Customs Office and Criminal Office of Financial Administration (state authorities for taxes, fees and customs) for the cross-border movement of waste via road transport, e.g. for cross-border movement of the batteries and accumulators, which are not waste.
9. I am not a battery producer, I only have a shop/retail. Do I have to be registered in the producer's register?
- Pursuant to the Waste Act No. 79/2015 Coll., producer of batteries and accumulators is a person who in the framework of his business regardless of the sales techniques used, including contracts concluded at a distance, places on the market for the first time batteries or accumulators produced at the territory of the Slovak Republic or purchased from abroad, including batteries and accumulators incorporated into appliances or motor vehicles.
- It means that even if you do not directly produce batteries and accumulators, but import them from abroad and resell them you are considered a producer of batteries and accumulators, regardless of whether it is the batteries themselves or batteries in appliances or vehicles. The same is true when you operate an internet shop.
- The obligations of a producer apply to you also in case when you provide batteries and accumulators to the end user and such batteries and accumulators originate from a producer who is not enlisted in the Register of producers of batteries and accumulators. Again, regardless of whether it is batteries themselves or incorporated.
10. What is meant by "professional use"?
Term „professional use „applies to the industrial batteries. Pursuant to the Waste Act No. 79/2015 Coll., industrial battery or accumulator is a battery or accumulator, intended exclusively for industrial or professional use or used in a transport vehicle powered by electricity.
PRO NATUR-PACK, a.s. received authorization only for portable batteries and accumulators, not for industrial ones.
11. If BaA is embedded in electrical or electronic equipment, how can I determine its weight?
As a producer of the device in question you should know the weight rate of EEE and BaA. Alternatively you can turn to your supplier (the real producer of the given device) who should be able to provide you with such information.
The Waste Act No. 79/2015 Coll., Art. 45, par. 2 states:
„A producer of devices is obliged to
a) ensure that the device that is placed on the market is designed and manufactured in such a way that used batteries and accumulators can be easily removed,
b) ensure that used batteries and accumulators can be easily removed by a qualified expert independent of the producer if they cannot be easily removed by the end user,
c) attach to the device instructions on how batteries and accumulators can be safely removed from the device in cases according to letters a) and b) and, if necessary, also information for the end consumer about the type of batteries and accumulators that are part of the device.“
It follows from the above that there should always be some possibility of removing - separating the battery from the device.
12. How does BaA re-collection work, where do I report re-collection and what are the fees?
Used portable batteries and accumulators from the re-collection by citizens can be reported to us by the producer having a contract with our company, and we will ensure free taking over and delivery for ecological recovery. A request for collection is submitted by filling and sending of a form on the web-page.
13. Can you provide the company with a collection container to re-collect portable batteries?
Free providing of a container of various size for collection in case of interest is a component of the contract for performance of obligations of a producer of batteries and accumulators.