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.