Full service
BATTery compliance
Your One-Stop-Shop Solution for the 27 EU Member States,
Switzerland, Norway and UK
The battery regulation
What is it?
The battery regulation aims to set out rules on the sustainability, performance, safety, collection, recycling and second life of batteries as well as on information about batteries for end-users and economic operators. It is intended to create a harmonised regulatory framework for dealing with the entire life cycle of batteries that are placed on the market in the European Union.
In addition, the regulation intends to take measures to protect the environment and human health by reducing waste and by improving resource efficiency.
Why battery compliance?
Did you know that it is not only the actual manufacturers of batteries that are regarded as “producers” for the purposes of international legislation?
Whenever you sell a product that contains a battery or accumulator, you are always required by national legislation to collect and recycle these batteries in an environmentally sound manner as well. And this includes both batteries and accumulators that are sold separately and batteries and accumulators included in an electrical product. Similar to the producer obligations for electrical appliances, also BATT producers face several obligations to meet in each country.
And even though the previous European Battery Directive 2006/66/EC has now been replaced by a European regulation (2023/1542) that is automatically existing law in all EU Member States without local implementation, several differences between the countries will remain and need special attention.
That forces producers to manage compliance processes individually per all 27 European countries plus Switzerland, Norway and the UK.
Who is considered a producer?
Producers include manufacturers, importers and cross border distance sellers who put batteries and accumulators (even in electrical products) on one or more markets in Europe. It is not only the manufacturer of a battery or accumulator who is considered the „BATT producer“ in a European state. To identify the BATT producer in each market, it is necessary to analyse the sales channels and the organisational structure of a company. In many cases it will even be the WEEE Producer, who’s products include batteries.
We support you managing your obligations
Being fully compliant with the battery legislation in one European country can already be a challenge. Ensuring full compliance in several countries is a massive challenge for companies of all sizes. We are here to help you selling your products in compliance with the battery legislation in Europe with our One-Stop-Shop approach.
the EU Battery Regulation
General Battery responsibilities across the EU 27, Switzerland, Norway and the UK
Registration
As a producer, many countries in Europe will oblige you to register with the national BATT authorities. Without being registered, the Put on Market in a country is not permitted and may be subject to penalties.
Financing Take-Back
Producers are obliged to finance the collection and recycling of batteries. You can do this by setting up your own take-back solution or by joining a collective scheme. We cooperate with the leading collective Producer Responsibility Organisations (PROs) in each market.
Information obligations by producers
The new battery regulation requires to provide a large variety of information about the battery, including
- crossed out bin in order not to be disposed of with unsorted waste
- weight, capacity and chemistry of batteries
- information on state of health / expected lifetime of specific types of batteries
- hazardous substances present in batteries, other than mercury, cadmium or lead
- critical raw materials present in batteries in a concentration of more than 0,1 % weight by weight.
Reporting
Producers must regularly report the quantities of batteries and accumulators placed on the market in each country. Based on this reporting, the PROs will charge you with the recycling fees. In addition, they usually also take care of the reporting towards the national authorities.
Blog
To get a first overview of your producer obligations have a look at these articles regarding everything you need to know about BATTERY compliance.
Batteries Recycling of E-waste and Batteries – The WEEE Directive
Batteries The New EU Battery Regulation – A Comprehensive Overview
Practical Steps to Compliance
How do you comply with the Battery Regulation?
Assess your producer status by country
Depending on your organisational structure and the sales channels you are operating in, you may be considered producer in a country with subsequent obligations or alternatively can fulfil such producer obligations voluntarily on behalf of your clients. When fulfilling producer obligations in countries where you are not represented with an own legal entity, legislation in most of these countries requires you to appoint a so called Authorised Representative (AR). We provide you with the necessary solutions, either through our PROs who offer this kind of service themselves or through external service providers with extensive knowledge on the topic. Our first step in leading you to compliance is the detailed assessment of your individual situation with a detailed overview of obligations, fixed and variable costs and ongoing tasks you need to fulfil. You receive the information you need, while we make sure that we arrange for everything you need during the contract phase.
Join a PRO to finance collection and recycling
In each country we work with our network of market leading Producer Responsibility Organisations (PROs) to ensure you fulfil your compliance obligations. We will set up the necessary contracts between you and the PROs in each country and coordinate the process of signing and transmission by country. This is why we will ask for detailed company information as well as some additional documents or other details from you.
Report the amount of Batteries and Accumulators placed on the market
When being registered, one of your main producer obligations is the regular reporting of the quantities placed on the market in each of your relevant countries. Unfortunately, the reporting does not only vary only in frequency, but also in the categorisation used by the different PROs in each country and whether the reporting needs to be done in pcs or kg.
Many countries / PROs also require a differentiation of batteries and accumulators sold within electrical products or are being put on the market as separate product.
To simplify this, PRONEXA has developed a unique reporting platform allowing you the declaration of all of your products in one format and at one single place. Batteries and accumulators included in electrical products are registered in type and quantity included and will be automatically reported with the EEE.
We handle all the rest of reporting to PROs on your behalf and you will only need to pay the invoices that will be issued by the PROs based on your reports. You can fulfil your obligation in an efficient and effortless way, while we ensure that you keep full control of your reported data during the whole process.
Make your products and sales documentation compliant
As a producer who places EPR (Extended Producer Responsibility)-affected products on the market in the European Union, you have several obligations in providing transparent information to end-users. These obligations may include the following:
- Show eco-contribution fee (Visible Fee)
- Show registration number
- Labelling
- Instructions on proper disposal
PRONEXA proactively and comprehensively informs you about existing and upcoming new compliance topics in your countries of activity.
You require additional details?
Free consultation call
We offer you a free consultation call to give you an overview of your obligations and provide you with a non-binding offer for our services with full cost transparency to simplify your decision-making process.
We take care of the details and you benefit from our expertise
If you have battery obligations in one or more countries and don’t have a compliance team with the respective know-how on dealing with the subject or the capacity to work on your EPR compliance, we recommend to use the support of our compliance experts. We’ll take you by the hand and lead you to compliance.
Detailed Assessment
We provide you with an in-depth analysis of your organisational status and product scope on a country by country basis, so you perfectly understand your obligations and are able to take the necessary actions. In addition, you will receive an overview on both the fixed and variable costs to expect in each country. Based on the results of the assessment we will take you along to the next step of contractual arrangements with our PRO network.
360° Full Service
We offer a unique combination of many years of expertise and experience in international EPR compliance within our team in Munich and a network of handpicked partner PROs and their teams in Europe to achieve our goal in providing best-in-class services in all the countries you need.
One Single Point of Contact
New developments in any of your relevant countries, questions about the invoice you received from one of our partner PROs or simply managing your reporting obligations in the variety of countries relevant for you: we support you with one compliance specialist as your dedicated contact point for all your questions and with our centralised and harmonised reporting platform you are able to manage your PoM Reporting - simple and quick.
A Partner network for the extra mile
We take your obligations serious - and are willing to go beyond the standard: We help you closing the loop by facilitating innovative recycling projects for circular business models.