Industrial batteries

UPV stands for Extended Producer Responsibility. This means that producers are responsible for their batteries, even once they have been discarded.

For industrial batteries, you must, amongst other things, ensure registration, collection, transport, processing, financing and reporting.

You can fulfil these obligations yourself or join a collective that organises some of these tasks on your behalf.

The rules do not apply solely to manufacturers of industrial batteries. Under the law, importers and distributors may also be regarded as manufacturers. What matters is who places the industrial battery on the market in the Netherlands for the first time.

For example, you may be considered a producer if you:

• manufacture industrial batteries and sell them in the Netherlands
• place batteries on the market under your own brand name
• import industrial batteries
• import machinery or equipment containing industrial batteries
• sell industrial batteries directly to Dutch customers from abroad

A battery that forms part of a machine or piece of equipment may also fall under the producer’s responsibility.

The UPV Industrial Batteries Foundation focuses on industrial batteries.

In the initial phase, this will certainly include:

• home batteries;
• commercial and large-scale energy storage systems;
• forklift and other traction batteries for industrial applications;
• batteries for construction and earth-moving machinery;
• batteries for agricultural machinery

The exact scope is still to be determined. In a later phase, the scheme may be extended to include other industrial batteries.

Yes. If you are a producer, you must be registered before placing industrial batteries on the market in the Netherlands. You can register via the Rijkswaterstaat Producers’ Register.

You must also specify how you meet your statutory UPV obligations: individually or through a collective.

A well-functioning Producers’ Register, set up by Rijkswaterstaat (RWS), forms the basis of a fair and effectively enforceable system. All producers of (industrial) batteries must be registered in the Producers’ Register. The basic principle is: no registration means no access to the Dutch market. A condition for registration in the Producers’ Register is compliance with producer responsibility by applying to Rijkswaterstaat for approval of an individual UPV scheme or by joining an approved collective UPV scheme.

No, joining is not compulsory. If a collective solution is put in place, the statutory UPV obligations can be organised jointly. This means you do not have to set up a nationwide system yourself for, amongst other things, safe collection and processing, administration, financing and reporting. By organising this jointly, you also benefit from economies of scale and cost-effective implementation.

If you choose not to join, you will be personally responsible for the full implementation of the UPV obligations and for obtaining the necessary government approval.

You will remain responsible for product requirements not covered by the collective UPV scheme, such as requirements relating to safety, labelling and product information.

No. The three trade associations are involved in the potential establishment of the collective and are contributing expertise from their respective sectors.

You do not need to be a member of any of these trade associations. Other manufacturers may also participate provided their industrial batteries fall within the collective’s defined scope.

If a decision is taken to adopt a collective solution whereby Stichting OPEN becomes the implementing body, Stichting OPEN will, amongst other things, be responsible for:

registering producers of industrial batteries from the specified segments as participants in the collective scheme

registering batteries placed on the market by affiliated producers;

• Levying a waste management contribution based on the industrial batteries placed on the market by affiliated producers to cover the costs of collection and treatment.
• collection and registration of waste batteries
• organisation of safe transport and treatment
• financial administration
• required reporting to the government
• The precise tasks and responsibilities are yet to be determined.

You can start preparing your business now:

determine which types of industrial batteries your company manufactures

check that your manufacturer registration is up to date and find out which Rijkswaterstaat procedure applies via www.afvalcirculair.nl/upv

identify how many batteries you place on the market in the Netherlands

ensure you have details available on, amongst other things, the type, weight, chemical composition and application of those batteries

keep records of existing arrangements for collection and processing

Via this website, we will keep you informed of the conditions, rates, registration and launch of the collective scheme. See the form on this page.