Must I register as a battery producer, and where?

What you need to do concretely

What is expected of you

Registration before a battery is placed on the market

Anyone placing batteries on the market registers as a producer before those batteries are actually made available. This is stated in Article 55 of Regulation (EU) 2023/1542 (batteries regulation). Registration takes place via the producer register of the Member State where the batteries are first placed on the market. For a company with 10 to 100 employees, this means in practice that registration becomes a fixed step in the process before launching a new product — just like CE marking or the choice of a logistics partner. Failure to build this in runs the risk that a battery is already in transit to the customer while registration is still pending.

What also matters is who exactly is a "producer" in this context. This is not automatically the person who physically manufactures the battery: anyone who sells a battery under their own brand or is the first to import it into the EU may also fall under this definition. Doubt about this can be clarified by reference to Am I an importer or manufacturer according to the battery regulation? and, specifically for own-brand sales, I sell batteries under my own brand — what obligations do I get?

Registration in each Member State where you are active

The registration obligation is organised nationally: each Member State maintains its own producer register. For a company that sells in multiple EU countries, this means that registration in one country is not automatically valid in another country. In practice, an e-bike importer selling in the Netherlands, Germany and France will need to account for three separate registrations, each with its own application procedure and its own point of contact. This requires an overview: which brand, which battery type and which sales channel is active in which country.

Providing data and keeping it up to date

Registration involves data about the company and about the batteries being placed on the market. That data forms the basis for oversight of extended producer responsibility, as set out in Articles 56 and 57 of the batteries regulation. For a mid-sized company, this means that registration data is not filled in once and then forgotten: changes in the product range, a new importer within the group, or a change in legal form are reasons to review the registration. Failure to build a fixed moment for this into your procedures — for example during the annual assortment update — runs the risk that the register no longer matches the actual situation.

Registration as a condition for extended producer responsibility

Registration does not stand alone. It is the gateway to the broader obligations that come with being a producer, such as contributing to collection and recycling. What extended producer responsibility entails is explained in What does extended producer responsibility for batteries entail? For a company that sells batteries itself from stock to end-users, this is particularly relevant: registration and producer responsibility go hand in hand in practice, and anyone selling from stock would do well to view this in combination — see also what do I need to arrange as an online shop if I stock batteries for sale myself

Where things go wrong in practice

Registration is seen as a one-off action. A company registers when launching its first product, but forgets that a new product line, a new brand within the company, or expansion to a new country may require a new or amended registration.

Confusion about who the producer is within a supply chain. With an importer who has batteries assembled into a package for light means of transport, it is not always immediately clear whether the importer, the assembly partner or the original manufacturer should be registered as the producer. This leads to situations where no one registers, assuming that someone else in the chain is already doing so.

Sales via a marketplace without registration in the customer's country. A company targets customers in an EU country other than where it is established via an online marketplace, without realizing that the customer's country is decisive for the registration requirement. This touches on the question dealt with in What does the battery regulation mean if I sell via an online marketplace?

Manufacturer outside the EU, registration remains outstanding. When a manufacturer is established outside the EU, it is sometimes assumed that the registration obligation lies with the manufacturer itself. In practice, it is often the party within the EU — importer or authorised representative — that must take this step. See on this point My manufacturer is located outside the European Union — who arranges the battery digital product passport then?

Registration data and passport data do not match. When the data in the producers' register deviate from what appears in the digital battery passport — a different company name, an outdated address — an inconsistency arises that raises questions upon inspection, even if there is nothing substantively wrong with the product itself.

What you can record

• An overview per country in which products are sold, together with the status of the registration in that country's producers' register.
• The name and role of the party identified as producer for each brand or product line, including justification for why that party holds that role — relevant in case of doubt about which party in the chain acts as the market operator
• A fixed control moment (for example annually or with each new product launch) at which it is checked whether the registration data are still current.
• Correspondence with the national register: confirmations of registration, requests for changes and any communication on the status.
• An internal arrangement concerning who within the company is responsible for maintaining the registration — particularly relevant when purchasing, compliance and marketing operate independently of each other. This connects to the broader question Who is responsible for the battery passport?
• Documentation of the relationship with distributors, so that it is clear which obligations lie with the distributor and which with the registered producer — see What obligations does a distributor of batteries have?