How do I arrange the collection and take-back of batteries?

What you need to do concretely

What is expected of you

The Battery Regulation places responsibility for collection and take-back with the producer, and in practice often with the importer who first places a battery on the European market. Anyone importing or trading e-bikes, scooters or industrial batteries generally falls under this. This is a different issue from the passport itself, but the two are related: some of the data needed to properly collect and process a battery will soon be in the passport. For the question of whether this applies to a specific assortment, see the page on whether the battery passport applies to your batteries.

Extended producer responsibility arrangements

Articles 56 and 57 of the Battery Regulation require producers to participate in an extended producer responsibility scheme, usually through membership of a collective scheme or, where permitted, an individual arrangement. For a company with 10 to 100 employees, this means in practice: determining which producer organisation membership is required, calculating a financial contribution based on the quantity and type of batteries placed on the market, and keeping that membership demonstrably in order. This is a structural, recurring obligation, not a one-off action at the start.

Organising collection points and systems

Articles 59 to 62 describe the obligation to collect end-of-life batteries free of charge, regardless of brand, origin or age. For light transport vehicles and industrial batteries, this means that an operational collection channel must exist: via own points of sale, via distributors, or via the collective scheme to which membership is held. For an importer with its own dealer network, this often means making agreements with those dealers about acceptance and forwarding of end-of-life batteries, and providing collection equipment such as containers or return boxes.

Take-back obligation towards end-users and distributors

The Regulation provides that end-users must be able to return an end-of-life battery free of charge, without obligation to purchase a new battery. In practice, this means that a shop or service point may not require that something new is bought before an old battery is accepted. Distributors selling batteries thus take on a role in the chain that goes beyond sales alone: they become part of the collection network, even if they are not producers themselves.

Registration and reporting of quantities collected

In addition to physically collecting batteries, the Regulation requires keeping track of how many batteries have been placed on the market and how many of these have been collected, as a basis for reporting to the collective scheme or the competent authority. For a medium-sized company, this means record-keeping that cannot be separate from inventory management: quantities, weight, battery type and chemistry must be traceable to what is sold.

Disposal and processing via recognised processors

Collected batteries must ultimately reach a recognised processor for recycling or safe processing. The choice of that processor and the traceability of that chain are usually the responsibility of the collective scheme, but a company that collects itself — for example during repair or return of industrial batteries — bears its own responsibility for this until the point of handover.

Where things go wrong in practice

An imported batch of e-bike batteries is sold through multiple dealers, but no one has recorded who is permitted to take back the discarded units; customers are given the runaround. A machinery manufacturer processes industrial batteries above 2 kWh in its own equipment, but treats this as part of a regular warranty arrangement, without recognizing that a separate collection obligation applies here. A company is affiliated with a collective system for one battery type, but not for a new product line added later, so the affiliation is no longer complete. A scooter importer lets take-back run through a third party, but has no insight into the quantities actually collected and processed, so reporting upon request is incomplete. And in a takeover of a trading inventory, collection of existing, already-sold batteries is overlooked, while that obligation continues for as long as those batteries are in use — this connects to the broader question of what must happen with batteries already in stock.

What you can record

• Proof of affiliation with a producer organization or collective system, with an overview of which product lines fall under it.
• An overview of collection points: own locations, dealers, service points, with agreements on acceptance obligation and free of charge provision.
• A record of quantities placed on the market and collected, per battery type and chemistry, in line with inventory administration.
• Agreements with processors or the collective system on disposal and processing of collected batteries.
• Instructions for staff at sales points on the take-back obligation, so that an employee knows what is being asked without requiring purchase of a new battery as a condition.

This documentation overlaps with what a supervisory authority may request upon inspection; see what a supervisory authority requests during an inspection on batteries for the connection to it. For batteries that receive a new application after collection instead of being immediately recycled, separate points of attention apply, described at what is regulated when a battery gets a second life. And because the setup of collection and take-back often runs simultaneously with the preparation of the digital product passport, it is practical to include both in the same planning — a starting point for that is at the step-by-step approach to the battery digital product passport.