Are you selling something with a battery or plug? This is how you arrange it as a small webshop
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by Verpakkingdeals.nl
6 min reading time
A lamp, a battery-operated toy, or a power bank in your product range brings obligations that you had better investigate before your first order. This is the route through the official sources.
Your product range grows a bit haphazardly, as these things go. First, keychains were added, then a light, then a button-cell powered toy, and now there's a power bank on the shelf. The moment you sell something with a battery or a plug, a question arises that doesn't apply to cardboard and tape: who is responsible when that device becomes waste in three years?
In the Netherlands, this question is regulated under the Extended Producer Responsibility (EPR) scheme. Below is how to figure out if it affects you — with references to official sources, because details change, and you want to check them at the source, not in a blog.
Step 1: Are you the 'producer' or not?
In common parlance, a producer is someone with a factory. In these regulations, this concept is broader. Anyone who markets products under their own name or brand, and anyone who imports directly from abroad, can also fall under the definition. If you exclusively purchase from a Dutch wholesaler who is already registered, responsibility usually lies earlier in the chain. If you import a pallet yourself from another country, there is a high chance that you are the point of contact.
The Chamber of Commerce explains the concept in Extended Producer Responsibility (EPR): what is it?. If you can't figure it out with that explanation, this is a question for your accountant or industry association — and not something to answer based on intuition.
Step 2: Two streams, two regulations
In practice, there are two separate tracks you need to keep straight.
Electrical and electronic equipment. Anything with a plug, a rechargeable battery, or a battery generally falls into this category: lighting, gadgets, motor-driven toys, a charging station. Government information on this can be found at Afval Circulair — EPR electrical and electronic equipment and at Ondernemersplein.
Loose batteries and rechargeable batteries. If you sell batteries separately, or if they are included loose in the box, the battery regulation also applies. See Afval Circulair — EPR batteries.
For equipment, there is a central register: the National (W)EEE Register, where producers and importers register and report what they put on the market. Supervision is carried out by the Human Environment and Transport Inspectorate, which explains what they monitor on ilent.nl. Go through those pages calmly once before purchasing a new product group; that's half an hour's work and it saves hassle later.
Step 3: What it requires of you in practice
If you fall under the regulation, it usually comes down to four things: you register, you keep track of how much you put on the market, you contribute to collection and processing, and you inform your customer. The last part is the easiest to get right yourself.
The crossed-out waste bin symbol you see on batteries and devices means the product does not belong with general waste. Put a single line on your product page or in the box confirming this and stating where the customer can dispose of it. If you also sell in a physical store or at a market stall, check which take-back rules apply to your situation — for in-store sales of electrical appliances and batteries, separate agreements exist for taking back old units.
Step 4: The box it goes into
Apart from registration, something changes at your packing station. Items with a battery or loose batteries impose requirements on how you ship them: carriers apply their own conditions for lithium batteries and accumulators, and these differ per carrier and per destination country. Look up your carrier's conditions page once and save the link next to your shipping instructions, so your colleague or temporary worker doesn't have to guess.
Step 5: What you include also determines your obligations
A detail often overlooked: whether you include batteries or not is a choice with consequences. If you include them, you are selling batteries. If you don't include them, you are selling a device that doesn't work upon arrival — and that leads to questions and returns.
Make a list of every item in your range with a battery, rechargeable battery, or plug. Often there are more than you think.
For each item, note where you purchase it: Dutch wholesaler or own import. This almost always determines the subsequent question.
Read the two pages from Afval Circulair above and note which of the two streams may apply to you.
Put one line about disposal on your product pages, and keep your carrier's shipping terms next to your packing table.
This article is a starting point, not legal advice: the precise obligations depend on what you sell, how much, and how you source it. Always verify your situation with the official sources referenced above.
Get started yourself
For batteries, power banks and charging items, check Batteries & Chargers and Computers & Accessories. The material to send them safely can be found in Packaging & Shipping and Tape. Questions about which box or which protection is suitable for an item with a battery? Email info@verpakkingdeals.nl, and we'll help you think about your packaging — for the legal aspect, we refer you to the sources above.
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