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This page is based on provisions set out in the EU Battery Regulation 2023. The rules on Extended Producer Responsibility can be found in Regulation (EU) 2023/1542, Chapter VIII ‘Management of waste batteries’.
In particular, this includes Article 55 (Register of producers), Article 56 (Extended Producer Responsibility), Article 57 (Producer Responsibility Organisation), Article 58 (Authorisation on fulfilment of extended producer responsibility), and Articles 60–61 (collection obligations for waste batteries).
What is Extended Producer Responsibility?
Extended Producer Responsibility (EPR) is the principle that producers remain responsible for their products when those products reach the waste stage. Within European waste legislation, this principle applies to a range of different product categories.
For batteries, producer responsibility is specifically regulated under the EU Battery Regulation. Article 56 states that producers have Extended Producer Responsibility for batteries they make available on the market for the first time within the territory of a Member State.
This responsibility extends beyond recycling alone. Producers are required, among other things, to register, organise and finance the collection and treatment of waste batteries, and comply with information and reporting obligations.
How is Extended Producer Responsibility organised in practice?
EPR is one specific part of the EU Battery Regulation, focusing primarily on the obligations of producers once batteries become waste.
The obligations set out in the Regulation can broadly be grouped into four areas:
Producers are responsible for financing the separate collection, transport and treatment of waste batteries. Where these obligations are fulfilled collectively, the costs are covered through financial contributions to a Producer Responsibility Organisation (PRO).
Responsible for lithium-ion batteries in Europe?
Are you a producer, importer or other organisation responsible for lithium-ion batteries placed on the European market? Discover how Heskon can support your organisation with professional battery service and aftersales.
- Heskon supports manufacturers, OEMs and other organisations supplying batteries to the European market.
- We can manage part or all of your battery service and aftersales process.
Who does Extended Producer Responsibility apply to?
Under the EU Battery Regulation, EPR obligations apply to the party that qualifies as the battery producer. This is not necessarily the company that manufactured the battery. Depending on how a battery enters the market, an importer, distributor or another economic operator may also qualify as the producer.
A key factor is who makes the battery available on the market for the first time in a particular EU Member State. Producer responsibility is therefore determined on a country-by-country basis. Companies supplying batteries in several European countries must assess their producer status separately in each Member State and determine which national implementation requirements apply.
Producer ≠ manufacturer
A manufacturer is the company that manufactures a battery, or has it manufactured, and markets it under its own name or trademark. For EPR purposes, however, producer is a separate legal role determined by how and where a battery is first made available on the market in a Member State.
This distinction also applies to batteries incorporated into other products. For example, a Dutch importer bringing e-bikes with integrated LMT batteries into the EU and making them available on the Dutch market for the first time may qualify as the producer of those batteries.
Under the EU Battery Regulation, you may qualify as a producer if you:
- make batteries available on the market for the first time in a Member State under your own name or trademark;
- bring batteries into a Member State from another EU country or from outside the EU and make them available there for the first time;
- make batteries available on the market again after they have been prepared for reuse, repurposed for a new application, or remanufactured;
- sell batteries directly to end users in a Member State from another country, for example through a webshop or another distance contract.
What does producer responsibility mean for waste batteries?
Once batteries become waste, producers are responsible for ensuring that they are collected separately and treated appropriately. For waste LMT batteries (Light Means of Transport batteries), the EU Battery Regulation sets out specific requirements for separate collection and treatment.
Producers must ensure that an accessible collection network is available where end users can return waste LMT batteries free of charge. In practice, these responsibilities are often fulfilled collectively.
In practice, producers often fulfil these obligations collectively through a Producer Responsibility Organisation (PRO). They report the volume of batteries placed on the market, while the PRO organises and finances the collection, transport and treatment of waste batteries through producer contributions.
What do repair and remanufacturing mean for producer responsibility?
Battery repair or rebuild work carried out on behalf of the owner does not automatically make a service provider the producer. If the battery is returned to the same owner after the work has been completed, it is not made available on the market again. The work itself therefore does not create a new producer for EPR purposes.
The relevant point is what happens to the battery afterwards. An economic operator that makes a battery available on the market for the first time in a Member State after preparation for reuse, preparation for repurposing, repurposing or remanufacturing is considered the producer of that battery for EPR purposes.
What matters is therefore not who carries out the technical work, but who first makes the battery available on the market in that Member State afterwards.
From EPR to sustainable battery management
Extended Producer Responsibility primarily focuses on what happens to batteries once they become waste.
Sustainable battery management begins long before a battery reaches the end of its life. Through professional diagnostics, repair and, where appropriate, rebuilding, defective batteries can often remain in service for longer instead of being replaced prematurely.
Heskon helps producers build a structured and sustainable approach to lithium-ion battery aftersales. When repair or further use is no longer a responsible option, batteries can move into a controlled end-of-life process for further treatment and recycling.
- Diagnosis before disposal: assess whether a battery can still be safely repaired or returned to use.
- Controlled end-of-life handling: safely dismantle batteries that cannot be restored, separate materials and transfer them to specialised recycling partners.
- Registration and reporting: record the outcome for each battery, such as repair, rebuild, return to use or end-of-life disposal, providing useful data for internal monitoring and, where relevant, EPR reporting.
Discuss your battery project
Tell us about your project using the form below. We will contact you within 3–5 business days to discuss your requirements and the available options.