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Sun Re-Pack - Faqs

We solve your doubts

Frequently Asked Questions

Who should register with the RII-PYA?

All manufacturers of batteries and accumulators, importers, as well as distributors in certain cases must register in this Registry of Batteries and Accumulators.

What types of producers are there?

In the Royal Decree of batteries and accumulators 106/2008, regardless of whether it is a natural or legal person, the following types of producers are distinguished:
  • Manufacturer: manufactures in Spain (unless it manufactures for third parties under the brand of another company, in which case the latter may, by agreement between the parties, assume the status of producer).
  • White label seller: own brand or distribution brand. You can assume the condition of producer of the batteries and/or accumulators that you sell, even if they are manufactured in Spain by another company in your name.
  • Importer: imports batteries and/or accumulators from a Member State of the European Union or from a third country for sale in Spain.
  • Distributor: if you import batteries and/or accumulators that you sell, you become a producer (importer) in relation to those batteries and/or accumulators. If all the batteries and/or accumulators that it sells have been purchased from manufacturers or importers that are already producers in Spain, the distributor is not a producer.
  • Remote seller: if you are established outside of Spain and sell batteries and/or accumulators by means of distance communication directly to private households or professional users in Spain, you are a producer.
[Note: it is also valid if you are established in Spain and fall into any of the above cases. For example, if you import batteries and/or accumulators to sell them at a distance over the Internet, you would be an importer].

In all these cases, the producer must register and declare his condition as a producer.

What type of batteries and accumulators does the regulation affect?

It affects all types of batteries, accumulators and batteries, regardless of their shape, volume, weight, composition or use:
  • Button Cells (Diameter > Height)
  • Standard Battery (Not button, weight < 1k)
  • Portable batteries (Not industrial or automotive)
  • Batteries, Accumulators and Automotive Batteries
  • Batteries, Accumulators and Industrial Batteries with Cadmium
  • Batteries, Accumulators and Industrial Batteries with Lead
  • Batteries, Accumulators and Industrial Batteries without Cadmium and without Lead
  • Other types
It includes batteries, accumulators and batteries from vehicles at the end of their useful life and also electrical and electronic equipment. The only exceptions are cells, accumulators and batteries used in equipment designed for military purposes or intended to be sent into space.

What obligations does a producer have that incorporates non-removable batteries and/or accumulators in their electrical and/or electronic devices?

The placing of batteries on the market is carried out considering the national regulations for batteries and accumulators (Royal Decree 106/2008, of February 1, on batteries and accumulators and the Environmental management of their waste, modified by Royal Decree 710/2015, of July 24).

These Royal Decrees affect all the batteries and accumulators included in EEE, regardless of whether or not they can be extracted from them.

In any case, the producer who places batteries and/or accumulators on the national market for the first time, whether or not they are incorporated into electrical and/or electronic devices, must be registered with the RII-PYA regardless of the reporting channel used and declare the quantities put on the market.


Do the producers of devices that work with removable batteries have to register with the RII – AEE and the RII – PYA?

Option 1: Yes, according to the latest updates of the RD of Batteries and Accumulators. Batteries and/or accumulators must be declared separately from the EEE.

Option 2: The EEE must be declared without the weight of the batteries that they carry inside, as well as the batteries must be declared separately. Therefore, the producer who imports a product that contains batteries must be registered in the two registries RII-AEE and RII-PYA and make the two declarations separately.

What are the residues of Batteries and Accumulators considered as dangerous?

16 06 01* (Accumulators and lead batteries).
16 06 02* (Accumulators and nickel-cadmium batteries).
16 06 03* (Batteries containing mercury).
20 01 33* (Batteries, accumulators and batteries, specified in the previous codes, generated as domestic waste or assailable waste, coming from homes, businesses, industries and institutions, as well as the fractions that these batteries, accumulators or batteries contain). »