What does extended producer responsibility for batteries entail?
Producers bear the costs of collection and recycling
Extended producer responsibility means that whoever places a battery on the market also remains responsible for what happens to that battery once it becomes waste. In concrete terms, this means that the party qualifying as a producer finances the collection, treatment and recycling of spent batteries, regardless of who ultimately uses or returns the battery. The idea behind this principle is that the costs of end-of-life do not fall to the municipality, the consumer or the waste processor, but to the party that placed the product on the market and has benefited from it. This is different from the obligation to make a digital battery passport available: the passport concerns information during the battery's lifespan, extended producer responsibility concerns who pays and organises when that lifespan is over. Both obligations are in the same regulation, but they are separate dossiers with their own scope.
Who this applies to and what it does not
This responsibility affects the party designated as a producer of a battery: typically the manufacturer, or — when a battery is brought in from outside the EU — the importer who places the battery on the EU market under its own name. A distributor or retailer who resells batteries without placing them on the market under its own name generally falls outside this; that link in the chain has other obligations, such as facilitating collection points, but does not bear the same financing burden. It applies to the battery categories covered by the regulation: portable batteries, batteries for light electric vehicles, industrial batteries, EV batteries and starter, lighting and ignition batteries. It does not apply to those who only resell second-hand products with a battery already placed on the market without introducing a new battery, and it does not directly affect the end user — who generally remains free to return a battery without paying separately for it.
The date on which this takes effect is not specified here
Article 56 and Article 57 of the regulation describe the content of this obligation, but this source contains no specific implementation date separate from the rest of the regulation. For a concrete date on which this obligation applies to a specific producer, the official text of the regulation is the appropriate source — this differs from the obligation regarding the digital product passport, which does have a fixed date of 18 February 2027. As long as no date can be established with certainty on the basis of the source text, it is more prudent not to mention one here than to guess a year. What is certain: the articles on producer responsibility are in the same regulation as the passport obligation, which means that anyone already preparing for the passport will also encounter Article 56 and 57 in that same text.
What an importer or trader can do with this
The first step is to check whether your own role in the chain is that of a "producer" within the meaning of the regulation — this is usually the case for anyone placing the battery on the EU market under their own brand or name, even if manufacturing takes place elsewhere. Next, it is useful to establish whether there is already a producer register or producer organisation active for the relevant battery category, since the regulation allows the obligation to be borne individually or collectively placed with such an organisation. Subsequently, it is practical to map which flows — collection, transport, processing — already run via existing waste contracts and which are not yet covered. If you are already working on the digital battery passport, it is advisable to lay both files side by side: the passport and producer responsibility stem from the same regulation and often affect the same internal department, but are legally separate obligations, each with its own scope and timeline.
The legal basis: Article 56 and 57
This obligation follows from Article 56 and Article 57 of Regulation (EU) 2023/1542 (the Battery Regulation), which together regulate extended producer responsibility for batteries: who qualifies as a producer, what that responsibility entails, and how it can be organised. For the precise scope, exceptions and any transitional provisions, the full text of these articles is the appropriate source, since a summary can never cover all nuances of the source text.
Anyone wishing to check whether their own business qualifies as a producer in this sense can test this against Article 56 and 57 of the regulation, preferably in combination with their own preparation for the digital battery passport — both obligations arise from the same law and lend themselves to a joint approach within the same organisation.
What this is based on
The Regulation itself is on EUR-Lex. We refer for each statement; you need not believe us.
What you need to do concretely
Whoever places batteries on the EU market is not finished at the moment the product reaches the customer. The Battery Regulation places on manufacturers the responsibility for what happens to the battery after use as well: collection, treatment and recycling. This is called extended producer responsibility, and it is set out in Articles 56 and 57 of Regulation (EU) 2023/1542. For an importer of e-bikes or a dealer in industrial batteries, this means a set of obligations that is separate from the battery passport, but closely linked to it: whoever is considered a producer for the passport is generally also considered a producer for this responsibility.
What is expected of you
Registration as a producer with the competent authority
A battery producer must register before batteries are placed on the market. This is done with the authority designated by the Member State for this purpose; in the Netherlands this is handled through the designated register. For a company with 10 to 100 employees, this means that registration becomes a fixed part of the process before a new battery type is imported or sold — not something that is rectified afterwards. If you have any doubt about your own position, you will find more guidance in must I register as a battery manufacturer, and where?
Financing of collection and treatment
The producer bears the costs of collection, treatment and recycling of waste batteries. This is generally not done individually by each company, but through participation in a collective system that carries out these tasks on behalf of multiple producers. For a mid-sized company, this means in practice an annual contribution that is linked to the quantity and type of batteries placed on the market. This contribution is separate from the costs for the battery passport, and is budgeted separately.
Setting up collection systems or joining an existing system
The Regulation expects that waste batteries can be returned free of charge for the end-user. A producer ensures this by either organizing a collection point itself or by joining an existing collective system. For an importer of light means of transport, this often means that dealers or service points in the sales network play a role in taking back batteries, and that this arrangement is documented somewhere.
Providing information on collection and risks
A producer informs end-users about the manner in which batteries can be returned, about the effect of batteries on the environment, and about the danger of handling waste batteries incorrectly (think of fire risk with lithium cells). For an online shop or importer, this means that this information must be accessible somewhere — on the packaging, in the instruction manual, or on the website — and not only provided verbally at the point of sale.
Annual reporting
The quantity of batteries placed on the market and the quantity collected is reported periodically to the competent authority. For a company of this size, this means that its own sales administration is organized in such a way that these figures can be provided on request, without requiring a major reconstruction afterwards.
Where things go wrong in practice
An importer of e-bike batteries places a new battery type on the market without registering in advance, because attention was focused entirely on the CE process and the battery passport. Producer responsibility is only discovered afterwards, when a wholesale partner asks about it.
A company sells scooters under its own brand name, with a battery produced by a third party. The assumption is that the original manufacturer bears the producer responsibility, while whoever sells under their own brand can themselves be considered a producer. This position is set out in I sell batteries under my own brand — what obligations do I incur?
A machine builder incorporating industrial batteries above 2 kWh into its own equipment assumes that the battery supplier has already covered all obligations. Whether this is the case depends on what has been precisely agreed and who fulfills which role according to the regulation — a question that is explained in what does the term market participant mean in battery legislation and am I an importer or manufacturer under the Battery Regulation?
A company does join a collective system for financing, but fails to inform the end-user about collection points — with the result that batteries still end up in ordinary waste, despite an organized paper structure.
A manufacturer outside the EU supplies batteries to a Dutch buyer, who assumes that the foreign party bears producer responsibility. Within the EU, however, that responsibility often lies with the party that actually places the battery on the EU market. See on this subject my manufacturer is outside the European Union — who arranges the battery passport then?
What you can record
- Proof of registration as a producer with the competent authority, including the date on which this was done in relation to the moment of first sale
- Agreement or membership of a collective collection system, including agreements on costs and responsibilities
- Internal arrangements with dealers, service points or distributors regarding the take-back of spent batteries
- Documentation provided to end-users about collection and risks, such as texts on packaging or website
- Overview of quantities sold per battery type, suitable as a basis for annual reporting
- Correspondence or contractual agreements with suppliers regarding who bears producer responsibility, especially for sales under own brand or for purchases outside the EU
Those who have not yet clearly defined these responsibilities within their own chain would do well to first establish what role the company itself plays. This is a different question than who compiles the battery passport, although both subjects constantly touch on each other — see also who is responsible for the battery passport?
This is not legal advice. This page provides general information about the legislation that this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-08-22. Is something wrong? Let us know — corrections take priority.