Are automobile batteries at a wholesaler exempted from EPCRA 311 and 312?

A facility sells automobile batteries wholesale.  Are these batteries at the wholesaler's facility exempt from reporting under SARA Sections 311/312 due to the household product exemption under SARA section 311(e)(3)?

Section 311(e)(3) exempts from the definition of hazardous chemical "(a)ny substance to the extent is used for personal, family, or household purposes, or is present in the same form and concentration as a product packaged for distribution and use by the general public."  This exclusion applies to household or consumer products either in use by the general public or in commercial or industrial use when the product has the same form and concentration as that intended for use by the general public.  The term "form" refers to the packaging, rather than the physical state of the substance.  Therefore, car batteries held for sale by a wholesaler are exempt from reporting since the hazardous chemicals contained are in the same form and concentration as batteries sold for use by the general public.