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Batteries and Accumulators and Waste Batteries and Accumulators

Battery Directive 2006/66/EC is transposed into Estonian legislation through:

  1. Waste Act (definition of producer and product of concern, general obligations for producer, general requirements for waste handling);
  2. Regulation of Government No. 135, 23.07.2009 (Register of Product of Concern and registration of producers);
  3. Regulation of Minister of Environment No. 5, 10.01.2008 (requirements for treatment of batteries);
  4. Regulation of Minister of Environment No. 64, 21.12.2007 (requirements for labelling batteries);
  5. Regulation of Government No. 124, 07.08.2008 (requirements for collection and returning the batteries, collection rates and targets for recycling and recovery, deadlines for achievement of rates and targets);
  6. Regulation of Minister of Environment No. 12, 16.02.2011 (registration and reporting forms for Register of Products of Concern);
  7. Regulation of Minister of Environment No. 30, 09.05.2011 (restricted hazardous substances and exemptions);
  8. Regulation of Minister of Environment No. 57, 22.07.2013 (information fo users and requirements for public information cmpaigns).

Producer of batteries and accumulators is a person who regardless of the method of sale manufactures batteries or accumulators or imports them into Estonia on the professional basis.
Producer is not a person who finances under or pursuant to any finance agreement unless person also acts as a producer.

Retailer is a person who provides batteries and accumulators on a commercial basis to the party who going to use it.

Economic operator is producer, collector, recycler or other treatment operator.

Product of concern is a product the waste resulting from which causes or may cause health or environmental hazards, environmental nuisances or excessive pollution of environment.
Products of concern are batteries and accumulators, motor vehicles and their parts, tyres and electrical and electronic equipments (EEE) and their parts and agricultural plastics.

Battery or accumulator means a source of electrical energy generated by direct conversion of chemical energy and consisting of one or more non-rechargeable batteries or rechargeable cells.

Portable battery or accumulator means any battery, button cell, battery pack or accumulator that is sealed, can be hand-carried, is neither an industrial battery or accumulator nor an automotive battery or accumulator.

Automotive battery or accumulator means any battery or accumulator used for automotive starter, lighting or ignition power.

Industrial battery or accumulator means any battery or accumulator designed for exclusively industrial or professional uses or used in any type of electric vehicle.

Place on the market: according to Estonian law product is placed on the Estonian market if that product is made available for the first time for the purpose of distribution or putting it into service (made available for the third parties). Putting it into service means an activity which involves the use of product for the first time for its intended purpose. If that product is brought for example from China or USA, then after that when all procedures related with Customs are done (filled declarations etc.) and it is possible to start to sell or use it. If product is just in bonded warehouse, then that product is not placed on the market yet.


Producer has requirement to register in Register of Product of Concern ( and introduce data according to the Regulation of Government No 135, 23.07.2009. Requirement to register entered into force on 13 February 2006. With the Register of Product of Concern must register all producers who place batteries or accumulators on the Estonian market.

There is 2 ways to submit application (and later reports):

1) through Internet or
2) digitally signed file via e-mail (possible only for persons having Estonian ID-card).

There is no fee for registration and any other annual fee.

For registration producer must besides introducing data what kind of brands (s)he represents give affirmation about (financial) guarantee and affirmation that products do not contain certain restricted hazardous substances (according to section 27 of Waste Act), description of public information campaigns (for users of batteries) and waste management plan in which (s)he describes how (s)he collects waste batteries and accumulators and handles waste onward. Producer must also report amounts how much batteries and accumulators (s)he manufactures, imports and/or place on the Estonian market. Data needs to be introduced quarterly. Producer also has to introduce every year waste report and it has to be introduced quarterly as well.

In Register can only register these producers who have registered in Estonian Central Commercial Register. When producer are located permanently outside Estonia then (s)he can not register directly in Register.

Producer has 2 options:
1) found a branch office or subsidiary in Estonia or
2) appoint authorised representative.

Such solution solves the problem where we have to guarantee to foreign producers possibility to register and in the same time it forecloses necessity in case of infringement to turn to Court of that Member State where that producer is located. If producer from outside Estonia (for example in Germany) does not fulfil some of his/her obligations (proportionally his/her market share) then that Estonian producer who has some claims (for example financial) do not have to go to the Court of other Member State where that producer is located. And other reason is that our Environmental Inspectorate can not supervise these producers who have responsibilities in Estonia, but they are located in other location outside Estonia.

All the data in Register are public according to Public Information Act. It means data are attainable with restrictions for everyone in form of request for information. For example, it is not possible to get an information about market shares, guarantees and contracts or information which contains commercial secret. Public are general data about amounts placed to the market and waste handling (summary of all data reported by all producers), description of information campaigns and waste management plans (except parts which contain commercial secret).

In Estonia, there is no Clearing House System. Producers have to divide the costs themselves and communicate with each other. For example if someone has collected more waste batteries than (s)he place on the market then it means that someone collected less than his/her market share is. And that producer who collected more presents a bill for payment to that one that collected less. If they do not get an agreement then the Court solves the problem.





Financial guarantees and requirements for collection

By Waste Act producer is required to ensure the collection, recycling, recovery or disposal of waste resulting from products of concern placed on the market and shall have a sufficient guarantee for these obligations.

Guarantee can be:
1) participation in collective schemes,
2) recycling insurance or
3) closed bank account.
Producer must bear all costs of collection and treatment of waste batteries and accumulators. Producers have also obligation to collect and treat all waste batteries and accumulators resulting from batteries and accumulators irrespective of the date when these batteries or accumulators were placed on the market.

Producer shall take back free of charge waste portable and motor vehicle's batteries and accumulators through retailers (points of sale) irrespective of that will consumer (end-user) buy new battery or accumulator or will not. Producer shall supply retailer with appropriate container(s). Producer of industrial batteries or accumulators cannot refuse to take back waste industrial batteries or accumulators from end-user regardless of chemical composition and origin. Producer is also obliged to take back free of charge waste portable and automotive batteries and accumulators from municipalities and from waste handler who has contract under public law with local government to operate the waste station (owned by local municipality). The producer of EEE and motor vehicle is obliged to take back the battery or accumulator free of charge if it is in appliance or motor vehicle.

Other undertaking can also collect the batteries and accumulators. They should ensure that end-users can take free of charge portable and automotive batteries and accumulators to their collection points. Producer is not obliged to take back free of charge waste batteries and accumulators from such undertaking (waste handler).

Collection rate and recycling targets

Collection rate – means, in a given calendar year, the percentage obtained by dividing the weight of waste batteries and accumulators collected in that calendar year by the average weight of batteries and accumulators that producers either sell directly to consumer or deliver to third parties in order to sell them to consumers during that calendar year and the preceding two calendar years.

Collection rate for waste portable batteries and accumulators which producer needs to achieve are:
1) at least 25% by 26 September 2012 and
2) at least 45% by 26 September 2016.

Collection rates for automotive batteries and accumulators which producer needs to achieve are:
1) at least 75% by 26 September 2012 and
2) at least 90% by 26 September 2016.

Economic operator shall achieve the following minimum recycling efficiencies:
1) recycling of 65% by average weight of lead-acid batteries and accumulators, including recycling of the lead content to the highest degree that is technically feasible while avoiding excessive costs;
2) recycling of 75% by average weight of nickel-cadmium batteries and accumulators, including recycling of the cadmium content to the highest degree that is technically feasible while avoiding excessive costs; and
3) recycling of 50% by average weight of other waste batteries and accumulators.

Requirements for information and information campaigns

In every point of sale where can buy portable or automotive batteries and accumulators should be a sign where is written that in that point of sale can bring back waste batteries and accumulators. If there is container for batteries and accumulators and consumer can see it when (s)he enters to the point of sale, then the sign is not needed.

At least once in a year producer has to make public information campaign through different media channels like TV, radio, county newspapers or outdoor advertisers.

Through information campaign producer has to inform consumers of batteries and accumulators:
1) the potential effects on the environment and human health of the substances used in batteries and accumulators;
2) the desirability of not disposing of waste batteries and accumulators as unsorted municipal waste and of participating in their separate collection so as to facilitate treatment and recycling;
3) the collection and recycling schemes available to them;
4) their role in contributing to the recycling of waste batteries and accumulators;
5) the meaning of the symbol of the crossed-out wheeled bin and the chemical symbols Hg, Cd and Pb.

Producers can organise common information campaigns for saving costs. Obligation of information campaigns entered into force in 1 January 2009.

Requirements for labelling

All batteries and accumulators placed on the market have to be marked with the symbol of separate collection mark.

Producer has to ensure that all batteries and accumulators placed on the market are marked with the chemical symbol Hg, if battery, accumulator or button cell contains more than 0,0005% mercury; with the symbol Cd, if battery, accumulator or button cell contains more than 0,002% cadmium; with the symbol Pb, if battery, accumulator or button cell contains more than 0,004% lead.

Producer has to ensure that on all portable and automotive batteries and accumulators are indicated their capacity.

All marks mentioned above have to be printed visibly, legibly and indelibly.

Restricted substances

Same requirements as provided in Directive 2006/66/EU. All are listed in the Regulation of Minister of Environment No. 30, 09.05.2011.

Requirements for treatment facility and storage place

For treatment facilities and storage places (including temporary storage places) are provided certain requirements. Treatment facility and storage place ought to have impermeable surface and weatherproof covering besides general requirements for treatment facilities and storage places provided by Waste Act. Waste batteries and accumulators can storage also in suitable containers. Suitable container is closed container which is weatherproof, impermeable, acid-proof and from where third persons cannot take the batteries out without using special tools or breaking the container.

Treatment facility must have waste permit or IPPC permit and hazardous waste handling licence.

There is two Estonian collective schemes of WEEE who collect waste portable batteries and accumulators: MTÜ EES-Ringlus and MTÜ Eesti Elektroonikaromu. All collected waste portable batteries and accumulators are treated outside Estonia, most of waste automotive batteries and accumulators are treated in Estonia (in AS Ecometal).

You can get information about collective schemes of WEEE:
MTÜ EES-Ringlus,
MTÜ Eesti Elektroonikaromu.






Last updated: 22 March 2018

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