What exactly happens on 18 August 2025?
From this date onwards, further comprehensive obligations under the new EU Batteries Regulation will apply. The old Battery Directive 2006/66/EC will be definitively replaced. The new regulation is directly applicable in all EU member states and should therefore be implemented by all of them from 18 August. However, this is not yet the case. You can see the actual implementation status and which EU member states already have further information on the application of the EU Batteries Regulation here:
To the Batteries Regulation Country Overview
What does this mean for me as a retailer selling batteries in various EU countries?
You must:
Be registered as a producer (EPR – Extended Producer Responsibility) in every EU country where you place batteries on the market for the first time.
Register separately for the different battery categories: portable batteries, industrial batteries, batteries for light vehicles, electric vehicle batteries and starter batteries.
Comply with national take-back and disposal obligations (in accordance with the EU Batteries Regulation via organisations for producer responsibility i.e. compliance schemes)
Submit reports and quantity reports regularly
Good to know: Compliance and registration are not organised by a central EU authority, but rather on a country-specific basis.
What exactly is the EPR registration obligation?
You must register as a ‘manufacturer/initial distributor’ with the competent authorities in each EU country where you sell batteries or devices containing batteries. This includes:
Producer ID or national registration number
Certificate or proof of participation in an organisation for producer responsibility
Regular quantity reports
Cost coverage for collection, recycling and information campaigns.
Please note: Retailers who import products with built-in batteries or sell them via e-commerce are also considered producers!
Do I have to register separately in each country?
Yes. There is no central EU registration office. You must register separately in each country where you sell. In countries where you do not have a branch, an EPR authorised representative is required.
Are there any technical requirements for the batteries themselves?
Yes. The following are binding as of 18 August 2025:
CE marking on batteries and preparation of a Declaration of Conformity (required since 18 August 2024)
Symbol for separate collection (crossed-out wheelie bin), exception: if the size of the ‘separate collection’ symbol would be less than 0.47 x 0.47 cm due to the dimensions of the battery, the battery does not have to be marked with this symbol; instead, the symbol must be printed on the packaging in a size of at least 1 x 1 cm.
Information on capacity, chemical composition, manufacturer name, shelf life, etc. will follow on 18 August 2026.
What about due diligence?
Originally planned for 18 August 2025, but:
The application has been postponed to 18 August 2027
The guidelines are to be published by 26 June 2026
Requirements: Strategy for fulfilling due diligence obligations, management system, risk management, third-party verification, disclosure of information
Tip: It is worth making initial preparations (e.g. supply chain mapping) now.
What applies to the carbon footprint and battery passport?
Possibly from 2027: Batteries in certain categories (e.g. EV, LMTLV, industrial batteries) will require CO₂ footprint data (declaration)
From 18 February 2027: Digital battery passport will be mandatory for the same categories – accessible via QR code
What quotas apply to take-backs?
Collection quota for portable batteries: 45% (2023), 63% (2027), 73% (2030)
Collection quota for batteries for light vehicles (LV batteries): 51% (2028), 61% (2031)
You or the organisations for producer responsibility in which you participate must demonstrably and permanently achieve and fulfil these targets.
Which batteries are affected by the EU Batteries Regulation?
All types of batteries:
Device batteries (e.g. batteries in common formats such as button cells, D, C, AA, AAA) or rechargeable batteries in small electrical appliances)
Starter batteries
Industrial batteries
Electric vehicle batteries
Batteries for light transport
What do I have to do now?
Immediate action:
Apply for EPR registration in every EU country in which you sell goods
If you do not have a branch in the EU country in which you sell directly to end users via distance contracts, you will need an authorised representative in that country for extended producer responsibility.
Organise and apply for a producer responsibility organisation or participate in one in the respective EU member state
Check labelling and technical requirements
Document internal processes (for quantity reporting, product specifications, etc.)
Prepare for the medium term (until 2027):
Collect CO₂ data and lifecycle information
Document the supply chain (for due diligence, if applicable)
Plan battery passport infrastructure
Which sanctions and penalties can be imposed for non-compliance with the EU Batteries Regulation?
Fines of up to €100,000 per violation (depending on the Member State and the severity of the breach)
Sales ban / marketing ban (products without valid registration / participation in an organisation for producer responsibility or CE marking may not be sold).
Compulsory recalls / market surveillance measures (authorities may order the recall of non-compliant batteries)
Civil liability / claims for damages (in the event of environmental damage or defective return)
Exclusion from marketplaces or major customers (lack of EPR registration can lead to suspension by platforms, e.g. Amazon)
Reputational damage & public naming (by supervisory authorities or NGOs – ‘naming and shaming’)
Where can I get quick support to comply with the EU Batteries Regulation?
take-e-way helps you fulfil your obligations under the EU Batteries Regulation:
take-e-way will be happy to advise you on the EU Batteries Regulation by phone.
take-e-way takes care of the EPR registration of your batteries in the countries where you sell them.
take-e-way offers you an authorised representative for batteries in all EU countries.
take-e-way can help you with all other issues such as CE, Declaration of Conformity, labelling, battery passport, participation in take-back schemes, participation in producer responsibility organisations, due diligence obligations, etc.
take-e-way is your central point of contact for all requirements of the EU Batteries Regulation.
Questions about the EU Batteries Regulation? Our take-e-way consulting team is happy to help you at +49 40/750687-0 or send us an email.
