Mange spørsmål i EU om batterier – men noen forpliktelser forblir uendret

Ny batteriforordning 2025:
Artikkelen er skrevet av PRONEXA, for medlemsland i EU. PRONEXA er et europeisk produsentansvarselskap som Norsirk er en del av.

Why the regulatory landscape is becoming more complex

Since the new EU Battery Regulation came into force in Mid-August, the industry has been buzzing: Manufacturers, importers, and distributors across Europe are now facing a wave of new obligations, unclear definitions, and unanswered questions. From the upcoming EU Battery Passport to new rules on recycled content, carbon footprint declarations, and sustainability design – with the new Battery Regulation the regulatory landscape is becoming more complex than ever.  
 
However, some things remain unchanged: If your electrical or electronic products contain batteries, you still have EPR obligations under both WEEE and Battery legislation. Still, this rule continues to surprise many companies. 

WEEE and Battery means dual EPR responsibility 

We regularly receive inquiries from companies bringing Electrical and Electronic Equipment (EEE) onto the market in various EU countries, being uncertain on “Who is the producer?” They struggle with the differentiation of the “manufacturer” of the product and the role as “producers”, responsible under EPR legislation. While those companies often “only” ask for support on WEEE, we frequently find out during our intensive assessment that their WEEE products also contain batteries. Therefore – in addition to their WEEE EPR obligations – these companies are considered “producers” also for the batteries and are subject to the same obligations under Extended Producer Responsibility (EPR) rules  that the new regulation puts in place.

Here are some examples of electrical devices that you would not immediately suspect to contain batteries: 

• Computer motherboards:
  They contain a small button cell battery that supplies power to store settings (such as system time and configurations) even when the PC is turned off and
  disconnected from the power supply 

• Smart kitchen appliances with integrated rechargeable batteries 

• Electric toothbrushes or shavers with built-in power cells 

• IoT and smart home devices powered by button cells or small batteries 

• Cordless tools with lithium-ion packs 

• Children’s toys or gadgets with internal batteries 

Companies placing those products on the market must register both – as WEEE and a Battery producer. 

The Battery EPR obligation remains – even under the new Regulation 

While the new Battery Regulation introduces major changes – such as stricter sustainability criteria, collection targets and digital traceability – the core compliance duties remain fully intact: 

• Registration with the relevant authorities

• Reporting of batteries placed on the market 

• Take-back and recycling obligations 

• Labeling and documentation requirements

These foundational rules continue to apply, regardless of how the upcoming technical details on the Battery Passport or carbon footprint reporting evolve. 

Marketplaces are stepping up compliance checks 

Another important development: Online marketplaces such as Amazon, eBay or Otto are increasingly required to verify the EPR compliance of all sellers. In practice, this means: 

• Without a valid Battery registration number, sellers cannot list their products

• Marketplaces perform automated compliance checks before listings go live

• Missing registrations can lead to sales bans or delistings almost instantly

• For small and mid-sized producers, this can quickly result in disruptions to sales channels or even penalties
  
  

What Producers should do now 

If you’re a manufacturer or importer of electrical devices, take a moment to review your compliance setup: 

• Do your products contain batteries – even small or built-in ones? 

• Are you registered under the national Battery EPR scheme? 

• Are your volume reports and labeling up to date? 

• Can your products legally be sold via online marketplaces? 
  
  

Ta kontakt

Trenger du hjelp med produsentansvar i EU, sjekk ut www.pronexa.com eller snakk med noen av Norsirks selgere. Hvis Norden er det geografiske området du trenger hjelp til, har Nordic PRO også en god løsning. Send en e-post til adm@norsirk.no for mer informasjon om produsentansvar på batterier og hvordan vi kan hjelpe deg.