Batteries Directive 2006/66/EC: What It Required, What Replaced It and the Transitional Rules

The successor is a regulation, not a new directive.

The Directive reached companies through national transposing acts, while the Regulation has applied directly since 18 February 2024. The sections below cover the Directive's requirements and acts, the repeal, the comparison, national law and the steps to take under the EU Battery Regulation.

What Did Directive 2006/66/EC Require?

Directive 2006/66/EC required member states to restrict mercury and cadmium in batteries, collect and recycle waste batteries against set rates and efficiencies, register producers, finance collection through producers and label batteries with the crossed-out wheeled bin and their capacity. Its annexes held the collection formula, the bin symbol, the recycling efficiencies and the registration items.

The Directive of 6 September 2006 rests on Article 175(1) EC, with Article 95(1) EC as the basis for Articles 4, 6 and 21. It repealed Directive 91/157/EEC with effect from 26 September 2008; its last consolidated version, 02006L0066-20180704, underlies the table.

Table 1: Main provisions; full text and amendments on EUR-Lex.

Three Battery Categories and the Directive's Scope

The Directive applied to all types of batteries and accumulators regardless of shape, volume, weight, material composition or use (Article 2), and sorted them into three categories: portable, automotive and industrial (Article 3, points 3, 5 and 6). Two uses were excluded: military and security equipment, and equipment intended to be sent into space.

Electric vehicle batteries had no category of their own: the Directive's definition of an industrial battery covered batteries used in any type of electric vehicle. Traction batteries therefore followed the industrial rules, including the Article 14 ban on landfilling and incineration.

Substance Limits, Collection Rates and Recycling Efficiencies

Article 4(1) of the Directive banned batteries containing more than 0.0005 % mercury by weight and portable batteries containing more than 0.002 % cadmium by weight. Article 4(2), as amended by Directive 2013/56/EU, let button cells hold up to 2 % mercury until 1 October 2015.

Article 4(3) exempted portable batteries for emergency and alarm systems including emergency lighting, medical equipment and cordless power tools from the cadmium limit, the last only until 31 December 2016. The current limits on these restricted substances are set out under restricted substances.

Article 10(2) obliged member states to collect 25 % of waste portable batteries by 26 September 2012 and 45 % by 26 September 2016. Annex I divided the yearly collection by the average sales of that year and the two before (CR = 3 x C / (S1 + S2 + S3)).

The table adds the recycling efficiencies of Annex III, Part B.

Table 2: Directive values.

Labelling, Producer Registration and Financing Rules

Article 21 of the Directive required the crossed-out wheeled bin of Annex II on every battery, the symbols Hg, Cd or Pb above 0.0005 %, 0.002 % or 0.004 %, and a capacity label (Article 21(2)). A bin below 0.5 x 0.5 cm moved to the packaging at 1 x 1 cm minimum (Article 21(5)).

Article 17 required each producer to be registered, and Annex IV listed seven information items: name and brand names, address and contact details, battery type, individual or collective scheme, date of application, national identification code and a declaration of truth. Changes had to be notified within one month. The duty continues as battery producer registration.

Article 16 set the financing rules, which Annex XV pairs with Article 56 on extended producer responsibility. Article 16(4) barred showing collection, treatment and recycling costs separately to end-users when new portable batteries were sold, a rule carried into Article 74(5).

Amendments and Implementing Acts Adopted Under the Directive

Four directives amended Directive 2006/66/EC (2008/12/EC, 2008/103/EC, 2013/56/EU and Article 2 of Directive (EU) 2018/849), and EUR-Lex records all four as implicitly repealed from 18 August 2025. Directive 2013/56/EU, on cadmium in cordless power tools and button cells with low mercury content, had to be transposed by 1 July 2015.

Five Commission acts implemented the Directive, and one of them, Decision 2009/603/EC on producer registration, has been out of force since 30 June 2015. The Commission reported on its implementation in COM(2019) 166 of 9 April 2019. The Regulation's own delegated and implementing acts form a separate set.

Table 3: Directive-era acts.

When Was the Directive Repealed? Article 95 and the Transitional Rules

Article 95 of Regulation (EU) 2023/1542 repealed Directive 2006/66/EC with effect from 18 August 2025, the same day Chapter VIII on extended producer responsibility, collection and treatment started to apply. The Regulation itself entered into force on 17 August 2023 (Article 96(1)), two years before the repeal.

Three Directive provisions continue, so EUR-Lex lists 17 August 2025 as the last day of general validity and 30 June 2027 as the final end, which is why 30 June 2027 is sometimes given as the repeal date. The table sets out each step.

Table 4: Repeal steps under Article 95; every other date sits in the EU Battery Regulation timeline.

Directive Provisions That Outlived the Repeal

Three provisions of the Directive outlived the repeal under Article 95, points (a) to (c). They are Article 11 on removal of batteries from appliances until 18 February 2027, Article 12(4) and (5) on recycling efficiencies and their reporting until 31 December 2025, and Article 21(2) on capacity labelling until 18 August 2026.

Article 11 hands over on one date: the Directive rule ends on 18 February 2027, when Article 11 of the Regulation starts to apply (Article 96(2)(a)). Its Article 11(2) was already replaced by Delegated Regulation (EU) 2026/1770, in force since 11 November 2026, as set out under removability and replaceability.

Article 12(4) maps to Article 71(2) and (3), and Article 12(5) data reach the Commission until 30 June 2027. Article 21(2) maps to Article 13(2) of the Regulation, which applies from 18 August 2026 or 18 months after the entry into force of the implementing act under Article 13(10), whichever is the latest.

Why the Repeal Waited Until 18 August 2025

Recital 141 gives the reason: the delay let member states adapt the producer registers set up under the Directive and organise authorisation procedures while keeping continuity for economic operators. Registration (Article 55) and authorisation (Article 58) both sit in Chapter VIII, which applies from the repeal date.

The Commission's proposal COM(2020) 798 of 10 December 2020 had planned the repeal for 1 July 2023 (Article 78 of the proposal) and four categories: portable, automotive, industrial and electric vehicle batteries, with LMT batteries counted as portable. The final act made LMT a category of its own.

Directive 2006/66/EC vs the Regulation: What Carried Over and What Changed

Regulation (EU) 2023/1542 carries over the Directive's substance limits, collection, recycling, registration, producer financing and labelling rules, mapped article by article in its Annex XV correlation table, and adds product, information and due diligence obligations the Directive never had. Table 5 sets out each pair.

The Directive bound member states, while the Regulation binds companies directly. Member states only had to set penalty rules by 18 August 2025 (Article 93) and notify competent authorities by 18 November 2025 (Article 54(4)). Annex XV closes the Regulation (EU) 2023/1542 full text.

Table 5: Annex XV pairs.

From Three Battery Categories to Five

The Regulation replaces the Directive's three categories with five (Article 1(3)): portable, LMT, SLI, industrial and electric vehicle batteries. Annex XV maps the Directive's portable, automotive and industrial definitions to Article 3(1), points (9), (12) and (13), so the automotive battery continues as the SLI battery.

Weight separates two categories: a portable battery is sealed and weighs 5 kg or less (point (9)), and an LMT battery is sealed and weighs 25 kg or less (point (11)).

Electric vehicle batteries left the industrial group, which now covers batteries designed for industrial uses and any other battery above 5 kg that is not an EV, LMT or SLI battery.

Table 6: The five battery categories of Article 1(3) and their Directive origin.

Obligations With No Directive Equivalent

Annex XV pairs no Directive article with Articles 7, 8, 9, 10, 12, 14, 17, 18, 47 to 53 or 77 of the Regulation. Carbon footprint, recycled content, performance, stationary storage safety, battery management data, conformity assessment, due diligence and the battery passport are therefore new obligations.

Four of them have applied since 18 August 2024: conformity assessment (Article 17), performance documentation (Article 10(1)), stationary storage safety (Article 12) and battery management systems (Article 14).

The passport follows from 18 February 2027 (Article 77(1)) and due diligence from 18 August 2027 (Article 48(1), as amended by Regulation (EU) 2025/1561); all sit among the EU Battery Regulation requirements.

Carbon footprint runs on a conditional date: the first declaration, for electric vehicle batteries, applies from 18 February 2025 or 12 months after the methodology delegated act and the format implementing act, whichever is the latest (Article 7(1)). Minimum recycled content shares, such as 16 % cobalt, follow from 18 August 2031 (Article 8(2)).

National Laws That Transposed the Directive

Directive 2006/66/EC had to be transposed into national law by 26 September 2008 (Article 26(1)), and Germany notified the Batteriegesetz (BattG, Battery Act) of 25 June 2009 (BGBl. I S. 1582) to the Commission as its transposition measure.

The second was the ordinance BattGDV (BGBl. I Nr. 74, p. 3783), and both are listed on EUR-Lex.

As of 13 November 2026 the BattG is replaced by the Batterierecht-Durchführungsgesetz (BattDG, Battery Law Implementation Act, BGBl. 2025 I Nr. 233), in force since 7 October 2025.

Under § 64 BattDG, BattG registrations continued in the new categories until the end of 15 January 2026 at the latest, except for registrants not established in Germany (national law in Germany).

In the EEA, the Directive applied through Joint Committee Decision 141/2007, in force there from 1 November 2010. Regulation (EU) 2023/1542 is under scrutiny for incorporation into the EEA Agreement, with no Joint Committee Decision adopted as of 13 November 2026.

How to Move from Directive Compliance to the Regulation

Treat every Directive-era registration, label and document as something to re-check against the Regulation, because the Directive's own rules ended on 18 August 2025 except for the three survivals. The six steps below follow the order in which the Regulation's obligations reach a producer.

1. Re-classify each battery and confirm which battery category applies.
2. Register as a producer in each member state where you first make a battery available (Article 55(2)).
3. Check the separate collection symbol of Article 13(4), required since 18 August 2025, and the Cd or Pb symbol of Article 13(5); the Regulation has no Hg symbol.
4. Run the battery conformity assessment of Article 17; keep the EU declaration of conformity 10 years (Article 38(4)).
5. Plan removability under Article 11 and the QR code of Article 13(6), both applying from 18 February 2027.
6. Check national rules per market under EU Battery Regulation by country.

Need help moving from the Batteries Directive to the Regulation? The full sequence by role and category is set out under the battery regulation compliance programme.

Collection Results Under the Directive and the Targets That Replace Them

In 2023 the EU reached a collection rate of 49 % for portable batteries, above the 45 % rate of Article 10(2)(b) of the Directive, with 17 member states at 45 % or more (Eurostat). Seven stayed below 40 %: Greece, Italy, Malta, Hungary, Portugal, Slovenia and Spain.

The Regulation moves the targets to producers and their producer responsibility organisations: 63 % of portable batteries by 31 December 2027 and 73 % by 31 December 2030 (Article 59(3)), and 51 % of LMT batteries by 31 December 2028 (Article 60(3)).

The 2023 figures, 117,000 tonnes collected against 231,000 tonnes sold, come from Eurostat; the new collection targets are explained separately.

Directive Questions

Four questions recur about the Directive and its successor.

Is Directive 2006/66/EC still in force?

No: Article 95 of Regulation (EU) 2023/1542 repealed it with effect from 18 August 2025, and only Article 11 still applies, until 18 February 2027. The transmission of Article 12(5) data to the Commission also runs until 30 June 2027.

Has a new directive replaced Directive 2006/66/EC?

No: the successor is Regulation (EU) 2023/1542 of 12 July 2023, which has applied directly in every member state since 18 February 2024. It has been amended by Regulations (EU) 2024/1781, 2025/1561 and 2026/1738 and by Delegated Regulation (EU) 2026/1770, as tracked under battery regulation amendments.

Is an EU directive mandatory?

Directive 2006/66/EC bound member states to bring national laws into force by 26 September 2008 (Article 26(1)), so companies followed the national transposing acts. A regulation such as Regulation (EU) 2023/1542 is binding in its entirety and directly applicable, so it binds companies without any national transposition.

Must batteries placed on the market under the Directive be relabelled?

No: recital 11 of the Regulation states that batteries placed in stock in the Union by distributors before the date of application of relevant requirements do not need to meet those requirements. A battery placed on the market from 18 August 2025 needs the separate collection symbol of Article 13(4).