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    The modified law of 19/12/2008 on batteries and accumulators and waste batteries and accumulators transposing Directive 2006/66/EC extends the principle of PRODUCER RESPONSIBILITY. Companies which produce or import batteries and accumulators are called to accept their responsibilities in terms of the collection and treatment of waste batteries and accumulators that they market in the Grand Duchy of Luxembourg.

    The non-profit organisation Ecobatterien is a private initiative set up by the clc, the Fédération des Artisans, Fedil – Business Federation Luxembourg and Ecotrel ASBL. Its aim is to help producers and importers of batteries and accumulators to fulfil their legal obligations. Ecobatterien ASBL organises the removal and treatment of batteries and accumulators through infrastructures for the selective collection of problematic waste in accordance with legal requirements.

    The legal framework defines three groups of batteries and accumulators:
    Portable batteries and accumulators
    Automotive batteries and accumulators
    Industrial batteries and accumulators

    Producers and importers of one or more of these categories of batteries and accumulators, whether they are sold separately or incorporated into appliances or vehicles, must comply with the provisions of the modified law of 19/12/2008.

  • Who is Ecobatterien?

    History

    06/09/2006 : Publication of Directive 2006/66/EC on batteries and accumulators and waste batteries and accumulators and repealing Directive 91/157/EEC

    19/12/2008 : Publication of the law on batteries and accumulators and waste batteries and accumulators

    15/10/2009 : Creation of Ecobatterien ASBL by the clc, the Fédération des Artisans, Fedil – Business Federation Luxembourg and Ecotrel ASBL to meet the legal obligations incumbent upon producers and importers of batteries and accumulator

    21/03/2012 : Publication of the law on waste management.

    Aim

    The aim of Ecobatterien is to help producers and importers of batteries and accumulators to fulfil their legal obligations. Ecobatterien ASBL organises the removal and treatment of batteries and accumulators through infrastructures for the selective collection of problematic waste in accordance with legal requirements.

  • Legal framework

    European Directive

    Directive 2006/66/CE : The aim of this Directive on batteries and accumulators and waste batteries and accumulators is to make producers, in the broad sense of the term, aware of their responsibilities.

    Act of 19/12/2008 : Directive 2006/66/EC was transposed into Luxembourg law by the law of 19/12/2008

    Who is affected?

    1. Producers and importers of batteries and accumulators.
    Companies located outside the Grand Duchy of Luxembourg which sell directly to users in Luxembourg are considered as importers.
    2. Distributors and end dealers.
    3. The government and local authorities.

    Obligations

    What are their obligations?

    • For producers and importers

      Obligation to register
      All producers or importers of batteries and accumulators must register with the Ministry of Sustainable Development and Infrastructures. They must declare all the batteries and accumulators that they have placed on the Luxembourg market and prove that they satisfy the obligations incumbent upon them or notify that they have joined an authorised organisation such as Ecobatterien ASBL which will help them to fulfil their obligations.

      Obligation to take back
      Producers, individually or collectively, or third parties acting on their behalf, finance any net costs arising from operations of collection, treatment and recycling of all waste portable and automotive batteries and accumulators collected through existing public infrastructures for the selective collection of problematic waste or through alternative or complementary collection systems to the existing public infrastructures, providing these systems offer the same countrywide coverage.

      The producers of automotive batteries and accumulators shall ensure the availability of systems for the collection of automotive batteries and accumulators from end-users or from accessible collection points in their vicinity.

      The producers of industrial batteries and accumulators, individually or collectively, or third parties acting on their behalf, may not refuse to take back waste industrial batteries and accumulators from end-users, regardless of chemical composition and origin.

      Obligation to inform
      Producers or importers must inform the environment administration by 30th April of each year of the quantities of batteries and accumulators that they have placed on the Luxembourg market and of the quantities of waste batteries and accumulators that they have collected and treated, as well as the rates of recovery effectively achieved.

      Obligation to label

      Manufacturers of batteries and accumulators must label their products with the symbol of the crossed-out wheeled bin to indicate that they are to be collected separately.



    • For end dealers

      Obligation to collect
      Distributors which supply portable batteries and accumulators must take back waste portable batteries or accumulators at no charge.

    • For the government

      Obligation to collect
      The government and local authorities must ensure the availability of structures that accept waste of batteries and accumulators, at no charge.
      By 26/09/2012, a collection rate of 25% must be achieved for the entire country.
      By 26/09/2016, a collection rate of 45% must be achieved for the entire country.

  • Contributions

    Why a recycling fee?

    Producers and importers which are members of Ecobatterien ASBL pay a recycling fee per battery or accumulator placed on the market to finance the activities of Ecobatterien ASBL.

    The recycling fee is not a tax or duty but rather a participation in the costs of processing batteries and accumulators.

    The recycling fee is payable for all batteries and accumulators placed on the Luxembourg market.

    When do you pay your recycling fee?

    As a producer or importer and member of Ecobatterien ASBL, you pay the recycling fee when batteries and accumulators are placed on the market within the meaning of the VAT code. Placing on the market refers to the moment when VAT is payable for the first time in Luxembourg, i.e. at the moment of sale of batteries and accumulators that you have manufactured or at the moment of purchase of batteries or accumulators that you have imported.

    If you are a foreign supplier commissioned by one or more Luxembourg importers or if you are an automotive constructor, you pay the recycling fee when you export batteries and accumulators to Luxembourg.

    If you buy your batteries and accumulators from a Luxembourg supplier, you pay the recycling fee to the supplier when you pay for the batteries and accumulators in question.

    Information for clients

    The modified law of 19/12/2008 stipulates that the costs arising from collection, treatment and recycling shall not be communicated separately at the moment of sale of batteries and accumulators to end-users.

    Nevertheless, Ecobatterien offers its members the possibility of mentioning the amount of the recycling fee on invoices in the event of a B-to-B sale to a dealer liable for VAT.

    Amount due in recyling fees

    You can download the 2016 recycling fees here.
  • List of batteries and accumulators

    You pay a recycling fee for all batteries and accumulators marketed in Luxembourg.

    Categories :
    A: Batteries sold separately
    B: Batteries incorporated into appliances
    S: Automotive batteries

  • Collection of batteries and accumulators

    Portable batteries and accumulators

    Ecobatterien ASBL organises the separate collection of portable batteries and accumulators from selective collection points for problematic waste. Subject to regulations specific to local authorities and local authority joint associations, Luxembourg consumers, distributors, importers and producers can dispose of their batteries and accumulators at these points at no charge.

    Moreover, Ecobatterien ASBL provides one or more sorting and regrouping centres for Luxembourg distributors, importers and producers of batteries and accumulators. Subject to regulations specific to the sorting and regrouping centre(s), professionals may access the centre(s) at no charge.

    Automotive batteries and accumulators

    Ecobatterien ASBL organises the separate collection of automotive batteries and accumulators from selective collection points for problematic waste. Subject to regulations specific to local authorities and local authority joint associations, Luxembourg consumers, distributors, importers, garage owners and producers can dispose of their automotive batteries at these points at no charge.

    Moreover, Ecobatterien ASBL selects and accredits one or more collectors for the collection of automotive batteries from distributors, importers, garage owners and producers located in Luxembourg. Rates are negotiated directly between the holder of the automotive batteries and the collector(s) accredited by Ecobatterien ASBL.

    Industrial batteries and accumulators

    Ecobatterien ASBL provides one or more sorting and regrouping centres for Luxembourg distributors, importers, garage owners and producers of industrial batteries and accumulators. Subject to regulations specific to the sorting and regrouping centre(s), professionals may access the centre(s) at no charge.

    Moreover, Ecobatterien ASBL selects and accredits one or more collectors for the collection of industrial batteries and accumulators from distributors, importers, garage owners and producers located in Luxembourg. Rates are negotiated directly between the holder of the industrial batteries and accumulators and the collector(s) accredited by Ecobatterien ASBL.

    List of collectors accredited by Ecobatterien

    Portable batteries Lead-acid batteries Industrial batteries
    Assainissement Urbain J.P. Feidert & Cie SA - x -
    BST Grand-Duché de Luxembourg SA - x -
    Concept4 SA x - x
    Dussmann Service SARL x x x
    Ecore Luxembourg - x -
    François Entsorgung SARL x x x
    Hein Déchets SARL x x x
    Innoclean SA x - x
    International Cores Luxembourg x x x
    ISS Facility Services SA x x x
    Lamesch SA x x x
    Netto-recycling x - x
    Nettoservice SA x - x
    Nouveaux Etablissements Liébaert SARL x x x
    Polygone SARL x x x
    Presta Bennes x - x
    Remondis Luxembourg SARL x x x
    Steichen Environnement SARL x x x
    Streff Data Protection Services SARL x x x
    WS Logistics - x -
  • Processing of batteries and accumulators

    Pursuant to its legal obligations, Ecobatterien ASBL uses collectors and recyclers with all the necessary authorisations to remove batteries and accumulators from the selective collection points. The various materials are then recycled and recovered in accordance with good practice.
  • How to join

    Who can join?

    Luxembourg producers as well as importers of batteries and accumulators, including those incorporated into appliances or vehicles.
    Companies established in another country which supply batteries or accumulators directly to an end-user in Luxembourg, including those incorporated into appliances or vehicles.

    Foreign suppliers may join Ecobatterien ASBL if they are commissioned by their Luxembourg importer clients.

    With regard to the automotive industry, a supplier located abroad may directly join Ecobatterien ASBL on behalf of its Luxembourg dealers. The supplier must then inform its dealers in writing and notify them of their obligations with regard to the collection of automotive batteries and accumulators.

    How do I join?

    Firstly you must be a member of one of the federations of the clc, the Fédération des Artisans or Fedil – Business Federation Luxembourg, or pay an annual fixed contribution which depends on your recycling contributions.

    You may join Ecobatterien ASBL by filling in the first page of the two copies of the accession agreement, initialling each page and signing the last page. Moreover, we ask that you fill in the identification form reproduced in annex 2 of the agreement, and send all the documents off to us.

    Upon receipt of the agreement, we will send you your countersigned copy. We will then contact you to give you all the information you need to fill in your first declaration.

    Retroactive membership of Ecobatterien

    You can join Ecobatterien at any time.

    Producers and importers who conclude a membership agreement with Ecobatterien ASBL after the system has come into force must:

    - pay retroactively the fixed contributions due since the date on which the system came into force. Luxembourg companies must only pay the fixed contributions if they do not belong to a federation that is part of the clc, the Fédération des Artisans or Fedil – Business Federation Luxembourg

    - pay the recycling fee for the batteries and accumulators that they have placed on the Luxembourg market since the date on which the system came into force

    Producers or importers may be exempted from the contributions detailed above:

    - If they present an individual plan for the management of batteries and accumulators that has been approved by the Ministry of Sustainable Development and Infrastructures for the period prior to their membership;

    - If they can prove that all their Luxembourg clients are members of Ecobatterien ASBL (valid for commissioned foreign suppliers and automotive constructors).

    This rule avoids any discrimination against producers and importers who were ready in good time.

  • Declaration

    Making your declaration

    The activities of Ecobatterien ASBL are financed by producers and importers of batteries and accumulators. They pay Ecobatterien ASBL a recycling fee per battery or accumulator that they place on the Luxembourg market.

    Ecobatterien ASBL must be informed of the types of batteries and accumulators and the quantities that you market in Luxembourg. The contribution is calculated on the basis of this information and is then charged to the producer or importer in question.

    On the declaration form, you should indicate the number of batteries and accumulators that you have placed on the market by category.

    - Category A concerns batteries and accumulators imported separately.

    - Category B concerns batteries and accumulators imported in appliances or vehicles.

    - Category S concerns automotive batteries imported separately or in vehicles.

    Who makes the declaration?

    In principle, all declarations are made by the producers or importers themselves.

    However, importers may commission one or more foreign suppliers to meet their obligation to make a declaration regarding the batteries and accumulators delivered by the supplier(s) concerned. For other batteries and accumulators, importers must always make all declarations themselves.

    With regard to the automotive sector, suppliers located abroad who have directly joined Ecobatterien ASBL on behalf of their Luxembourg dealers make the declaration.

    When should declarations be made?

    You should make a quarterly or annual declaration, depending on your total annual contribution. Quarterly declaration (only if your total annual contribution is greater than or equal to €250 ex. VAT). Annual declaration (only if your total annual contribution is less than €250 ex. VAT).

    How do I make my declaration to Ecobatterien?

    • By internet (detailed or simplified declaration). You can encode your declaration on the Ecobatterien ASBL website using the user code and password that you received on conclusion of the membership agreement. This means that the data communicated will be processed electronically and the risk of error is reduced to a minimum.

    • By post, fax or email (simplified declaration only). You can use the declaration form annexed to the membership agreement or you can download it on this site and send it by post, fax or email to:


      Ecobatterien ASBL
      Square Mile Belval
      11, Boulevard du Jazz
      L-4370 Belval
      Tel : (00352) 26.0.98.735
      Fax : (00352) 26.0.98-736

    Refunds

    Importers are entitled to a refund of the recycling fees paid to Ecobatterien ASBL or to their suppliers upon acquisition of batteries or accumulators that they have (then) exported, unused, to natural or legal persons established abroad. Producers or importers are entitled to a refund of the recycling fees paid to Ecobatterien ASBL or to their suppliers for batteries or accumulators which they have been obliged to take back due to faulty condition.

    Invoicing

    On the basis of the declarations made by the producer or importer, Ecobatterien ASBL calculates the total amount of the recycling fees that the producer or importer must pay, after deduction of any recycling fees that Ecobatterien ASBL must refund under the refund regulation. This amount will be invoiced and is payable in full without discount.

ECOBATTERIEN ASBL

Square Mile Belval
11, Boulevard du Jazz
L-4370 Belvaux

TEL (352) 26 09 87 35
FAX (352) 26 09 87 36