Batteries: Am I a battery producer?

The Batteries Directive defines a producer as:

any person in a Member State that, irrespective of the selling technique used, including by means of distance communication as defined in Directive 97/7/ EC of the European Parliament and of the Council of 20 May 1997 on the protection of consumers in respect of distance contracts (1), places batteries or accumulators, including those incorporated into appliances or vehicles, on the market for the first time within the territory of that Member State on a professional basis

You are therefore a battery producer in an EU Member State if you manufacture batteries in that EU Member State, import batteries into the EU Member State or import electrical equipment which contains batteries into the EU Member State. If you buy batteries from a supplier in a particular EU Member State and fit them into equipment for sale in that EU Member State then you are not a battery producer in that particular EU Member State (because the batteries had already been put on the market in that particular country). However, if you supply equipment containing batteries into other EU Member States then you may be a battery producer in these other countries.