EU Battery EPR: Producer Registration, Take-Back, Collection Targets and Costs under Regulation (EU) 2023/1542

It attaches to each member state separately.

Chapter VIII covers Articles 54 to 76 and replaced the producer responsibility rules of Directive 2006/66/EC, which Article 95 repealed with effect from 18 August 2025. Battery EPR is one chapter of the EU Battery Regulation, in force since 17 August 2023.

The sections below set out who counts as a producer, when the duties apply and how registration and authorisation work. They then cover costs, the targets by battery category, take-back, end-user information, the first reporting deadline and the two Commission proposals pending as of 13 November 2026.

What Extended Producer Responsibility Means under the Regulation

Under Article 56(1) of Regulation (EU) 2023/1542, producers have extended producer responsibility for the batteries they make available on the market for the first time in the territory of a member state, and they comply with Articles 8 and 8a of Directive 2008/98/EC as well as Chapter VIII. Directive 2008/98/EC is the Waste Framework Directive.

The Regulation is lex specialis to those waste framework rules for the EPR minimum requirements on collection and recycling targets, distributor take-back and second life (recital 103 of Regulation (EU) 2023/1542). Where Chapter VIII sets a battery-specific rule on one of these points, the battery rule takes precedence over the general waste framework.

The main articles of Chapter VIII, in their order in the Regulation, are listed below.

• Article 54: the competent authorities of the member states.
• Article 55: the register of producers.
• Article 56: extended producer responsibility, the EPR authorised representative and the costs.
• Articles 57 and 58: producer responsibility organisations and their authorisation.
• Articles 59 to 61: collection of waste batteries by category.
• Article 62: the take-back duties of distributors.
• Article 63: the Commission's assessment of deposit return systems.
• Article 69: the collection duties of the member states.
• Articles 70 to 73: treatment, recycling, shipments and end-of-waste status.
• Article 74: information for end-users.
• Articles 75 and 76: reporting by producers and member states.

Each duty attaches to the member state where a battery is first made available, so a producer selling in three member states carries three sets of obligations (Articles 55(2) and 56(1)).

Producer responsibility schemes for batteries established before 4 July 2018 had to comply with Article 8a of Directive 2008/98/EC by 18 August 2025, a deadline added by Article 92.

The Four Kinds of Producer in Article 3(1), Point (47)

A producer under Article 3(1), point (47), is any manufacturer, importer, distributor or other natural or legal person that, irrespective of the selling technique used, including distance contracts, first supplies batteries in a member state in one of four ways.

Every one of the four limbs includes batteries incorporated in appliances, light means of transport or other vehicles.

Limb (a) covers a maker established in the member state that supplies batteries under its own name or trademark, and limb (b) a reseller of own-brand batteries without the original maker's mark.

Limb (c) covers the first professional supplier of batteries from another member state or a third country, and limb (d) a distance seller to end-users from abroad.

One company can be a producer in several member states at once, for example under limb (a) at home and under limb (d) where it ships batteries directly to end-users in another member state. The obligations, documents and deadlines of producers under the EU Battery Regulation are set out on their own page.

Battery EPR Guides: Registration, Organisations, Collection, Take-Back and Reporting

Five guides cover the battery EPR duties in detail: registration in each producer register, producer responsibility organisations and their authorisation, collection targets, distributor take-back and the yearly reports. Every guide gives the article behind each duty, and all five duties belong to Chapter VIII and share its application date.

The table lists each guide with the question it answers and its legal hook in Regulation (EU) 2023/1542. Registration comes first because Article 55(2) bars a producer from making batteries available in a member state before it, or its EPR authorised representative, is registered there.

Need help with battery EPR registration and take-back? How EPR fits with the other duties is set out under how to comply with the EU Battery Regulation.

When Battery EPR Applies and Who Enforces It

Battery EPR has applied since 18 August 2025, the date from which Chapter VIII of Regulation (EU) 2023/1542 applies under Article 96(2)(c) and Directive 2006/66/EC is repealed under Article 95. Member states had to lay down their rules on penalties for infringements of the Regulation by the same date (Article 93).

Member states also had to notify the Commission of the competent authorities designated under Article 54 by 18 November 2025 (Article 54(4)). The Regulation applies directly in every member state and needs no transposition, while national acts designate the authorities, run the producer registers and set the penalties.

The Commission's list of competent authorities under Article 54 (last update 31 May 2026, checked 13 November 2026) has no entry for Croatia, Poland, Portugal or Romania.

A blank entry records the state of the Commission's list, not the state of national law. National acts, registers and penalties are compared under EU Battery Regulation by country.

Selling from Another Country: The EPR Authorised Representative

A producer under Article 3(1), point (47)(d), that sells batteries by distance contracts directly to end-users in a member state where it is not established appoints, by written mandate, an authorised representative for extended producer responsibility in each member state of sale (Article 56(3)). The duty is part of Chapter VIII and shares its application date.

Article 3(1), point (48), defines this representative as a person established in a member state in which the producer places batteries on the market and which is different from the member state where the producer is established.

The representative may register on the producer's behalf and lists each represented producer's name and contact details separately (Article 55(7)).

COM(2025) 982, a Commission proposal of 10 December 2025 (procedure 2025/0395(COD)), would suspend Article 56(3) until 1 January 2035. It is pending: after a partial first-reading vote on 20 October 2026 (T10-0345/2026), the European Parliament referred it back to committee for interinstitutional negotiations, and no agreement had been reached as of 13 November 2026.

The Council's negotiating mandate, agreed by Coreper on 21 October 2026 (Council document ST 14765/26), removes batteries from the proposal by deleting its batteries article, and the Council text does not change Article 56(3). Article 56(3) applies unchanged. The tasks of an EPR authorised representative are set out with the product-law representative.

When Another Operator Becomes the Producer: Article 56(2)

Under Article 56(2), the operator that first makes available a battery after preparation for re-use, preparation for repurposing, repurposing or remanufacturing is its producer and carries extended producer responsibility for it.

The producer role follows the act of making the battery available again, not the original manufacture, so the second-life operator takes on the producer duties of Chapter VIII.

Article 56(5) allows an optional cost-sharing mechanism between the original producer and the new one for the costs under Article 56(4), points (a), (c) and (d). Under that mechanism, the producer that first made the battery available bears no additional costs.

Registering as a Producer in Each Member State

Every producer registers in each member state where it first makes a battery available, through that state's electronic register, and may not make batteries available there until it or its EPR authorised representative is registered (Article 55(2)). The bar also covers batteries incorporated in appliances, light means of transport and other vehicles.

The application covers identity and brands, national identification and tax numbers, battery categories and chemistries, the EPR measures including any organisation mandate, and a statement of truth (Article 55(3), points (a) to (e)).

The authority grants the registration number within a maximum of 12 weeks of complete information (Article 55(9)(b)) and may charge cost-based, proportionate fees (Article 55(10)(b)).

Distributors verify that the producer is registered before making a battery available (Article 42(2)(a)), and online platforms obtain each producer's registration number and a self-certification of compliance (Article 62(6)).

The Regulation itself requires no display of the number on offers, invoices or the battery. What this means for online sellers and marketplaces is set out separately.

Individual or Collective: Authorisation under Articles 57 and 58

A producer fulfils its extended producer responsibility either individually or collectively through a producer responsibility organisation, and either route needs an authorisation from the competent authority (Articles 57(1) and 58(1)). Such an organisation is a legal entity that financially, or financially and operationally, organises that fulfilment on behalf of several producers (Article 3(1), point (49)).

Appointing an organisation is optional unless a member state makes it mandatory, justified by the characteristics of a battery category (Article 57(1)).

The authority verifies an application within a maximum of 12 weeks of a complete dossier (Article 58(3)), requires a financial guarantee (Article 58(7)) and may revoke an authorisation where the collection targets are not met (Article 58(6)).

Organisations treat producers equally regardless of origin or size, without a disproportionate burden on small-quantity producers, including SMEs (Article 57(2)).

The Commission's Article 54 list names the stiftung elektro-altgeräte register as Germany's national register and authority for authorisation on fulfilment of extended producer responsibility. The German route is set out under EU Battery Regulation in Germany.

What Producers Pay For under Article 56(4)

Producers' financial contributions cover four kinds of cost under Article 56(4) of Regulation (EU) 2023/1542: separate collection, transport and treatment net of revenues, the compositional surveys of Article 69(5), end-user information under Article 74, and data gathering and reporting under Article 75. The revenues deducted come from preparation for re-use or repurposing and from secondary raw materials.

Where an organisation acts for producers, their contributions are modulated at least by battery category and chemistry and, as appropriate, by rechargeability, recycled content, re-use, repurposing or remanufacturing, and carbon footprint (Article 57(2)(a)). The contributions are also adjusted to take account of the revenues gained from waste batteries (Article 57(2)(b)).

Article 57(7) provides for an implementing act on the modulation criteria. As of 13 November 2026, no such act has been adopted and the Commission has no Have Your Say initiative for it. The modulation criteria therefore stand as Article 57(2) sets them.

The compositional survey was due by 1 January 2026 and recurs every five years (Article 69(5)). All four cost heads also reach the buyer, because Article 74(5) requires them to be shown separately to end-users at the point of sale of a new battery, as set out below.

Collection Targets: Portable, LMT and the Other Categories

Regulation (EU) 2023/1542 sets percentage collection targets only for waste portable batteries, 45 % by 31 December 2023, 63 % by 31 December 2027 and 73 % by 31 December 2030 (Article 59(3)), and for waste LMT batteries, 51 % by 31 December 2028 and 61 % by 31 December 2031 (Article 60(3)). Producers or their organisations attain and maintain them durably.

Member states ensure that the targets are met (Article 69(1)). The rate divides the weight of waste batteries collected in a year by the average weight made available in the three preceding years (Annex XI, point 1).

A delegated act on the calculation methodology (Articles 59(7) and 60(8)) is planned, with adoption foreseen for the third quarter of 2027.

SLI, industrial and electric vehicle batteries have no percentage target. Producers take back all waste batteries of these categories free of charge instead (Article 61(1)), and private non-commercial users of industrial batteries bear no collection or dismantling costs (Article 61(1), third subparagraph).

Eurostat puts the 2023 EU collection rate for portable batteries at 49 %, with 17 member states at 45 % or more, measured with average sales from 2021 to 2023. Its next update is planned for 4 December 2026. That measurement method came from the Batteries Directive 2006/66/EC, not from Annex XI of the Regulation.

Free Take-Back by Distributors

Distributors take back waste batteries free of charge and without an obligation to buy a new battery, regardless of chemistry, brand or origin (Article 62(1)): portable batteries at or in the immediate vicinity of the retail outlet, other categories at or in its vicinity. The duty does not depend on where the battery was bought.

Article 62(2) sets three limits: no waste products containing batteries, only categories the distributor offers now or offered before, and portable batteries only in the quantities non-professional end-users normally discard. Distributors hand the batteries over to producers, organisations or the waste management operators selected under Article 57(8) (Article 62(3)).

Distance sellers apply these rules mutatis mutandis, with collection points covering the whole territory (Article 62(4)), and sellers that deliver offer free take-back at the point of delivery or a local point (Article 62(5)).

The Commission assesses deposit return systems by 31 December 2027 (Article 63). The other duties of distributors and retailers start before the sale.

Article 74: End-User Information and the Visible Fee

Article 74 of Regulation (EU) 2023/1542 requires information for end-users on the prevention and management of waste batteries, in six points from the end-user's role in waste prevention to the impact of hazardous substances (Article 74(1)(a) to (f)). The six points of Article 74(1) are listed below.

• (a) the role of end-users in waste prevention;
• (b) the role of end-users in the separate collection of waste batteries;
• (c) the collection, take-back, re-use and treatment options available;
• (d) safety instructions, including for batteries containing lithium;
• (e) the meaning of labels and symbols;
• (f) the impact of hazardous substances.

Producers, or their producer responsibility organisation where one is appointed under Article 57(1), make this information available to end-users and distributors for the battery categories they supply in a member state (Article 74(1)). Information on dismantling is available free of charge on request (Article 74(3)).

Distributors provide the information permanently, easily accessible and clearly visible, also when they sell through online platforms (Article 74(4)). At the point of sale of a new battery, the Article 56(4) costs are shown separately to the end-user (Article 74(5)).

Reporting under Articles 75 and 76

Producers of portable and LMT batteries, or their organisations, report each calendar year the batteries placed on the market, collected, delivered for treatment, exported and delivered for preparation for re-use or repurposing, with the collection rate (Article 75(1)), while SLI, industrial and EV producers report a shorter list (Article 75(2)). Reports go to the competent authority.

Reports are due within six months of the end of the reporting year (Article 75(7)).

The format is set by Implementing Regulation (EU) 2025/2289, in force since 11 December 2025, so 2026 is the first reporting year and the first reports are due by 30 June 2027. Member states publish the data within 18 months (Article 76(1)).

Treatment operators and recyclers report per member state of collection, and waste batteries sent to another member state for treatment count towards the Annex XII targets of the member state of collection (Article 75(5)). Their treatment and recycling duties are covered under waste batteries under the EU Battery Regulation.

Pending Changes to Battery EPR

As of 13 November 2026, no adopted act has amended Chapter VIII of Regulation (EU) 2023/1542, and two Commission proposals of 10 December 2025 that would change parts of battery EPR are pending. The three amending acts in force, Regulations (EU) 2024/1781, 2025/1561 and 2026/1738, change other parts of the Regulation.

COM(2025) 981 (procedure 2025/0397(COD)) would replace Article 3(1), point (47)(d), the distance-seller limb of the producer definition, and delete the second to fourth sentences of Article 76(4). It sits with the ENVI committee as "Awaiting committee decision", with an indicative plenary date of 14 December 2026.

COM(2025) 982 concerns Article 56(3) only, and its procedural status and the Council's mandate are set out above with the EPR authorised representative. Until an amending act is published in the Official Journal, Chapter VIII applies as adopted. Each proposal is tracked under Battery Regulation amendments.

Battery EPR FAQ

Six questions come up when battery EPR meets neighbouring rules or is read in a hurry; each answer gives the article behind it.

Battery EPR and Neighbouring Rules

Two neighbouring regimes are often confused with battery EPR: appliance rules and packaging rules.

Do batteries built into appliances fall under battery EPR?

Yes: the producer definition in Article 3(1), point (47), covers batteries incorporated in appliances, light means of transport or other vehicles, and Article 55(2) bars making them available unless the producer is registered. How this meets the appliance's own rules is set out under Battery Regulation vs WEEE Directive.

Is packaging EPR the same as battery EPR?

No: battery EPR follows Chapter VIII of Regulation (EU) 2023/1542, while packaging and packaging waste fall under separate EU packaging law with its own producer responsibility rules. A registration in a battery producer register under Article 55 covers batteries only.

Common Misreadings of Battery EPR

Four claims about battery EPR recur in vendor and media summaries and are wrong under the Regulation's text.

Is there one EU-wide producer register?

No: a producer registers in each member state where it first makes a battery available, under Article 55(2), and each authority grants its registration number within a maximum of 12 weeks of complete information (Article 55(9)(b)). A producer selling in three member states therefore holds three registrations.

Is there a collection target for SLI, industrial and EV categories?

No: Article 61(1) sets no percentage target for SLI, industrial and electric vehicle batteries; producers take back all waste batteries of the category free of charge instead. Percentage targets exist only for portable batteries under Article 59(3) and LMT batteries under Article 60(3).

Has the EPR authorised representative duty been suspended?

No: Article 56(3) has applied since 18 August 2025. The proposal COM(2025) 982 to suspend it is pending: Parliament referred it back to committee after its partial first-reading vote of 20 October 2026, and no agreement had been reached as of 13 November 2026.

Does EPR stay with the original producer after repurposing?

No: under Article 56(2), the operator that first makes a repurposed or remanufactured battery available is its producer, and the original producer bears no additional costs under Article 56(5). The full rules for second-life batteries sit on their own page.