Batteries and accumulators in the company

Many businesses associate BDO mainly with waste, packaging or electrical and electronic equipment, while the obligations concerning batteries and accumulators very often arise „by the way” and are therefore sometimes overlooked. This is not only a problem for companies selling batteries themselves, but also for those importing or marketing products with batteries or rechargeable batteries, such as toys, electronics, watches or appliances with integrated power supplies. Official BDO material makes it clear that activities involving the production, import or intra-Community acquisition of batteries or accumulators, including those fitted into products, can imply reporting and registration obligations. This is precisely why the subject can sometimes be so tricky: a company thinks it is „selling toys” or „importing gadgets”, while in practice it enters the area of introducing batteries and accumulators in parallel. Registration with BDO covers entities introducing batteries or accumulators, and an annual report is submitted electronically via the BDO system by 15 March for the previous calendar year. 

When does a company become an „introducer of batteries and accumulators”?

It is most important to understand that the obligation is not limited to manufacturers of the cells themselves. If a trader introduces batteries or accumulators into the country for the first time, including those fitted into products, they may be subject to the obligations in this respect. From a practical perspective, this means that when importing toys with batteries, electronic equipment with a built-in battery or other goods containing a power source, it is necessary to check whether the activity triggers an obligation to enter batteries in the BDO register and to include the data in the relevant section of the report. The current BDO system manual explicitly indicates that the report on products, packaging and waste management is submitted by, among others, the introducers of batteries or accumulators, and the form itself contains a separate section „Batteries and accumulators” with a table on the weight of batteries and accumulators placed on the market. This is important, as many companies correctly identify the obligations for packaging or equipment, but omit the additional scope for power sources. 

What obligations do batteries and accumulators have with BDO?

The obligation does not end with mere registration. There is a separate reporting section in the BDO system for batteries and accumulators, which includes information on batteries and accumulators placed on the market, data on public education campaigns carried out, as well as information on the achieved levels of collection of waste portable batteries or waste portable accumulators and the amount of the product fee due. This is where one of the more frequently overlooked risks lies: the entrepreneur not only reports the masses, but must also include public education campaigns. The Batteries and Accumulators Act stipulates the rate of this fee at PLN 0.03 per kilogram of batteries or accumulators placed on the market, and the BDO manual shows that the report must show the minimum amount of funds, funds allocated in-house or transferred to the account of the marshal's office, and how they were used. If the company introduces portable batteries or portable accumulators, there is also the subject of collection levels and a possible battery product fee, which increases the importance of correct accounting. 

Where do used company batteries go and how do you reduce the risk of penalties?

From an operational perspective, businesses often ask not only about the batteries and accumulators report itself, but also about the collection of waste batteries at the workplace. Such waste should not end up in mixed waste, but in a properly organised collection system and handed over in accordance with waste management rules. In practice, it is worth sorting out this area on two levels: firstly, to establish whether the company is an introducer of batteries and accumulators, and secondly, to establish whether it properly handles waste batteries arising from its operations. Well-prepared environmental reporting makes it possible to catch both risks at the same time: a missing entry in the BDO or an erroneous section in the report, and a disorderly circulation of waste batteries in the company.

If you want to check that your company is properly accounting for the introduction of batteries and accumulators, that it is properly recording data in BDO and that it is not overlooking its obligations regarding education campaigns or the product fee, it is worth sorting out this area before a problem arises. The most convenient way to do this is through a professional environmental reporting. Details can be found under Contact page there, you can describe your situation and match the scope of support to your company's real responsibilities.