Do you need to register separately in each EU country for batteries?
Yes, that may be the case. Apart from the digital battery passport, which will soon work in the same way across the entire European Union, there has long been an obligation for you as a producer or importer of batteries to register in a national register. That registration is linked in the battery regulation to the place where you first place the battery on the market, and that register is maintained per Member State — not centrally from Brussels.
For a company that only sells in the Netherlands, this remains straightforward. If you also sell in Germany, Belgium or France, then that same battery may require its own registration in each of those countries, with its own authority, with its own notification procedure. That is a different matter from the question of whether supervision is the same everywhere. answer to related questions about the regulation — registration is about who you are in the supply chain per country, supervision is about who checks.
Why registration is regulated nationally
The battery regulation builds on this point from a system that already existed: the so-called extended producer responsibility. That principle — whoever places a product on the market is also responsible for what happens to it when it becomes waste — already existed for batteries and for electrical equipment, and was traditionally organised per Member State. The Netherlands has its own implementing organisation for this; other countries have their own counterpart, with their own fees, their own reporting obligations and their own deadlines.
The digital passport, on the other hand, is set up the same way across the EU: the same fields, the same QR data carrier, the same accessibility for those entitled to it. That distinction is confusing for many companies, because both obligations stem from the same regulation and in practice often come into play at the same time: when you first place a battery on the market in a country.
What this means if you sell in multiple countries
For an importer who offers batteries in multiple Member States, this can mean that a separate registration process runs per country, each with its own national point of contact. Who in that supply chain exactly fulfils the role of producer or importer can moreover be filled in slightly differently per country — a party that is considered a distributor in one country may, in another country, depending on how the goods are imported, be classified as an importer. This affects the question of what obligations rest on you, and that question cannot be answered with a general rule of thumb.
This is immediately one of the points where companies confuse the registration obligation and the passport obligation in their procurement process. A supplier who says the passport is arranged has said nothing about registration in the country of destination, and vice versa. Both should have their own place in the procurement conversation and the contract the knowledge base with explanations per situation, if only to establish who carries out which part of the process.
What is certain and what is not
What is certain is that the obligation to have a digital passport will soon apply in the same way across the EU. What may differ per country is the registration that continues to exist in addition, and the way a national supervisory authority supervises it. Which authority in which country is the point of contact for your situation, and whether or not your business must be registered there, is something you can best inquire about with the competent supervisory authority in the Member State in question, or have assessed by a lawyer familiar with cross-border producer responsibility.
For the Dutch situation, the official text of the regulation on EUR-Lex serves as the starting point; the national implementation of the registration is not included there and therefore differs per country how we maintain traceability of the source data.
Would you like to first clarify for yourself what role you fulfil in the chain, before you enter into a discussion with a foreign authority? do the free quick-scan in a few questions and read the background in the knowledge bank.