Battery and batteries (EPR registration)

• Regulation (EU) 2023/1542 — Batteries and waste batteries
• Directive 2012/19/EU — WEEE for the appliance
• Regulation (EU) 2019/1020 — market surveillance

Who has to appoint one

Anyone who first makes batteries available on the market of a member state on a professional basis, including batteries incorporated in appliances and vehicles. For a seller not established in that member state, the Regulation requires an authorised representative for producer responsibility established there. Distance sellers shipping into a country are producers in that country from the first parcel, which catches marketplace sellers who assume the marketplace handles it.

Thresholds and exemptions

No de minimis in most member states for distance sellers. Portable, LMT, industrial, SLI and electric vehicle batteries each have their own rules, and the carbon footprint and due diligence obligations phase in by category and size, with reliefs for small and medium enterprises on due diligence only.

What must appear on the label

The crossed-out wheelie bin symbol. Capacity for portable and industrial batteries, and minimum average duration for portable general use. The chemical symbols Hg, Cd or Pb where thresholds are exceeded. From 18 August 2026 a QR code giving access to the required information, and for certain categories a carbon footprint declaration and later a performance class. The producer's identification and registration number where national law requires it on the invoice or listing.

Marketplace fields

Amazon, eBay and other marketplaces require a battery producer registration number for every country you ship into, alongside the WEEE and packaging numbers, and suspend listings without them. Germany's BattG register and France's UIN are verified automatically, and an expired registration is treated as none at all.

Documentation you must hold

Producer registration in the national register of each member state. A contract with a producer responsibility organisation or an approved individual compliance scheme. Financial guarantee where the state requires it. Annual reporting of quantities placed on the market by chemistry and category. Declaration of conformity and technical documentation for the battery itself. Due diligence policy on cobalt, lithium, nickel and natural graphite for larger operators, third-party verified.

Standards and testing

Safety testing per battery type, in practice IEC 62133 for portable cells, UN 38.3 for transport, and the electrochemical performance and durability requirements phased in for portable general-purpose and LMT batteries. Carbon footprint calculation follows the delegated acts as they come into force, by category.

Language requirements

Labelling, take-back information and the QR-linked information in the language of each member state where the battery is made available.

When it applies

Registration before the first shipment into a country. Removability and replaceability requirements for portable batteries in appliances apply from 18 February 2027, and carbon footprint declarations phase in from 2025 onwards by category. Reporting deadlines are annual and national.

How long records are kept

Registration and reporting records per national law, generally five to ten years. Conformity documentation for ten years after placing on the market.

What happens if you do not comply

A ban on selling in the member state concerned, retroactive recycling fees for volumes placed on the market without registration, marketplace suspension, and national fines. Germany and France both pursue non-registered distance sellers actively, and back-fees can exceed the value of the sales.

Who enforces it

National battery registers and environmental agencies, market surveillance authorities for the product requirements, and customs at import.

Where the boundary lies

This is the point that costs sellers the most money: producer responsibility is national, not EU-wide. An Article 27 GDPR representative in Prague, or an Article 16 GPSR responsible person, covers none of it. Batteries, WEEE and packaging are three separate registrations in each member state, each with its own register, fee, scheme contract and annual declaration.

Questions we are asked

Can one EU representative handle batteries for all countries?

No. The mandate is per member state and must be given to an entity established in that state. There is no single-registration route.

Our product contains a battery but we sell the appliance — does this apply?

Yes. Batteries incorporated in appliances are still placed on the market, and you register as a battery producer as well as an electrical equipment producer.

Does Amazon register on our behalf?

No. Marketplaces verify that you hold a number; they do not obtain one for you, and they suspend the listing if you cannot supply it.