EPR for Batteries in the EU: Why You Need an Authorised Representative and How to Comply
If you make, import, or sell products with batteries in the EU, your Extended Producer Responsibility (EPR) obligations have changed. The new EU Batteries Regulation (EU 2023/1542), often called BATT2, introduces stricter rules for how battery producers are managed across Europe.
One of the most important changes is the requirement to appoint an Authorised Representative (AR) for EPR in each EU country where distance sellers established elsewhere sell batteries directly to end-users.
In this guide, we’ll break down what EPR for batteries means for you and how to stay compliant. You’ll learn who needs an AR, what they actually do, how to handle compliance in different EU countries, the key deadlines and penalties, what this means for Amazon and other online sellers, and practical tips to make the whole process easier.
Why EPR Matters for Batteries: The EU’s New Battery Compliance Rules
As battery demand soars, so does the volume of battery waste. To tackle the environmental impact, the EU has introduced stricter rules through Extended Producer Responsibility (EPR). EPR means producers are responsible for their products throughout their entire lifecycle, including proper collection and recycling at the end of use.
For batteries, this shifts the responsibility onto the companies placing them on the market to finance and manage safe disposal and recycling. This is critical, since batteries often contain hazardous materials like heavy metals that can cause serious pollution if not handled correctly.
The new EU Batteries Regulation (EU 2023/1542), also referred to as BATT2, replaces the older Battery Directive and significantly strengthens these obligations. With global battery demand expected to grow around 14-fold by 2030, according to a 2021 European Parliament briefing, and the EU set to be a major market, the new rules are designed to prevent a surge in waste and ensure producers play their part in recycling and circular economy goals.
So what does this mean for you? If you’re considered a “producer” of batteries (we’ll explain what that means shortly), new responsibilities have applied since August 18, 2025. Key EPR requirements, including registration, reporting, and the appointment of local representatives where required, apply across all EU member states.
One of the biggest changes is the obligation for some companies to appoint an Authorised Representative (AR) in every EU country where they sell batteries or products containing them. This ensures there is a local point of accountability in each market and closes long-standing compliance gaps.
In the next sections, we’ll break down exactly who needs an AR, why this rule exists, and how it works in practice.
Who Needs an Authorised Representative for Batteries (and Why)?
Not every business will need an Authorised Representative. Under Article 56(3) of the Batteries Regulation, a producer that sells batteries (including those built into products) by distance contract directly to end-users in an EU country, and is established in another EU country or outside the EU, must appoint an authorised representative for EPR in each country where it sells. Producers established in the country concerned, such as importers there, carry their own EPR obligations.
Here are some common scenarios where an AR is required:
- Non-EU companies selling into the EU: If your business is based outside the EU – for example, in the U.S. or UK – and you sell batteries or products containing batteries directly to end-users in an EU country, you’re considered a “producer” there and must appoint an authorised representative for EPR in that country. If you supply through an importer or distributor established in that country, that business is the producer, so check who carries the EPR obligations.
- EU companies selling to other EU countries (distance selling):If your business is based in one EU country but sells batteries or battery-containing products to another EU country where you don’t have a local office, you’re considered a producer there. For example, a German company selling directly to consumers in France or Italy would need an Authorised Representative in each country to handle EPR compliance.
- Online marketplace sellers: If you sell through platforms like Amazon or eBay and ship products to customers in other EU countries, the same rule applies. Distance sellers must have an Authorised Representative in the buyer’s country unless they have a local business entity. This ensures there’s a responsible party to handle regulatory obligations.
The EU introduced the Authorised Representative requirement to prevent “free-riders” and ensure accountability. If you sell batteries (or products containing them) directly to end-users in an EU country by distance contract and you are established elsewhere, you must appoint an authorised representative for EPR in that country. The AR is responsible for ensuring your batteries are properly registered and contributing to recycling programs.
How do Authorised Representative Handle EPR Obligations?
An Authorised Representative (AR) in the context of battery EPR is a person or entity in the EU country where you sell, appointed to handle your EPR obligations. Think of them as your local compliance agent, ensuring all legal responsibilities of a battery “producer” are met, even if your business is based elsewhere.
Here are the key roles and tasks an Authorised Representative typically handles:
- Registration with authorities: The AR registers your company in the national battery producer or EPR registry for each country, as required by law. Every EU member state has its own registry. For example, Germany uses the Stiftung EAR database, and France uses ADEME’s register. The AR submits the necessary information so your company is officially recognised as a battery producer and receives the local EPR registration number, or “battery ID.”
- Ongoing reporting and record-keeping: Once registered, producers must regularly report the quantities of batteries or battery-containing products they place on the market. Your AR usually handles these reports, making sure they’re accurate and submitted on time, while keeping records of sales data, battery types, weights, and any other information required by authorities or recycling organisations.
- Arranging collection and recycling (via PROs): Under EPR, producers are financially responsible for collecting and recycling waste batteries. This is usually done by joining a Producer Responsibility Organisation (PRO) or battery compliance scheme. An AR helps enroll your company in an approved PRO or take-back program. The PRO handles collection and recycling to meet national targets, while you pay the fees. The AR ensures you’re signed up with a compliant scheme (or sets up individual arrangements if needed) and may also manage recycling fee payments on your behalf.
- Acting as the local contact point: The Authorised Representative serves as your company’s face with regulators in that country. If authorities have questions, audits, or enforcement actions, they contact the AR, who must provide proof of compliance—registration, reporting, fee payments, and more. Essentially, the AR handles all battery EPR matters locally, making communication easier and preventing issues from falling through the cracks due to time zones or language barriers.
- Taking over producer obligations: In many cases, an AR can handle almost all of a producer’s obligations under the law. For example, German law allows an AR to take on nearly all duties under the Battery Act. Once appointed and given the necessary information, the AR manages registration, enrollment in recycling schemes, and filing of annual reports. You still provide sales data, but the AR carries the main compliance burden and keeps you updated on regulatory changes to ensure ongoing compliance.
In short, think of the authorised representative as an expert local team member who keeps you on the right side of the law. Next, we’ll cover how to comply with these requirements across multiple EU countries.
How to Comply with Battery EPR Requirements Across the EU
Managing battery EPR compliance means addressing each EU country where you sell. While the Batteries Regulation (BATT2) creates a common EU-wide framework, every member state implements it with local systems, which means registration, reporting, and AR requirements can vary.
1. Know Your Markets
Start by identifying all EU countries where you place batteries on the market, either directly or through shipments. If you sell in multiple countries, you will probably need to register in each one separately.
2. Understand the Registration Process
Every country has its own registration system. For instance:
- Germany uses Stiftung EAR
- France uses SYDEREP
- Italy uses Registro Pile e Accumulatori
- Poland uses BDO
- Spain and Sweden have their own portals too
Registration typically involves submitting company details, battery types, and brand names. Once approved, you’ll receive a national battery registration number (EPR ID).
3. Appoint an Authorised Representative (AR)
If you sell directly to end-users in a country where you are not established, you must appoint an authorised representative for EPR there (Article 56(3)). Some countries require foreign sellers to register through a local authorised representative, for example Germany and Sweden. Check the rules in each country where you sell.
4. Join a PRO (Producer Responsibility Organisation)
You’ll need to join a national PRO or recycling scheme to meet your obligations for waste collection and recycling. In many countries, registration and PRO enrollment are linked. Your AR can coordinate this for you and manage annual payments.
5. Stay Compliant Post-Registration
Once registered, your responsibilities don’t end. You’ll need to:
- Report battery sales annually (by weight, type, etc.)
- Pay recycling fees to PROs or authorities
- Display required markings (e.g., the crossed-out wheeled bin)
- Ensure your products carry a CE mark and have a designated EU “responsible person” for safety (a separate role from the AR)
Since August 2025, registrations must also align with the new battery categories under BATT2.
In the next sections, we’ll cover the timeline for these requirements, what happens if you don’t comply, and how major marketplaces are enforcing these rules (which is especially important for e-commerce sellers).
Key Deadlines, Penalties, and Legal Obligations to Know
Key date: August 18, 2025. From that date, the Batteries Regulation EPR requirements, including the need for an authorised representative where required, apply across the EU. Here’s what you need to know about deadlines and consequences:
- August 18, 2025 – “Go Live” Date: Since this date, battery producers must be registered and compliant with the new rules. This includes having an EPR registration number in each relevant country and appointing an AR where required. You must also follow the new battery categories and other regulation requirements. The old Batteries Directive (2006/66/EC) is repealed, so there’s no grace period—August 18, 2025, marks the full launch of “Extended Producer Responsibility 2.0” for batteries.
- Transitional arrangements: Some requirements, like certain battery substance restrictions and CE marking, began in 2024, mainly related to product design and safety. EPR obligations had a transition period while member states set up systems. If you haven’t started registration, start now: the competent authority has up to 12 weeks to grant a registration number once all required information is provided (Article 55).
- Penalties for non-compliance: Each EU country enforces the Batteries Regulation through national laws, with penalties for breaches. Failing to register as a producer or appoint an AR can lead to significant fines (in Germany, up to €100,000 for failing to register) and other sanctions. Regulators may also stop sales. In Germany, foreign producers without an authorised representative had their registrations revoked from 18 August 2025. In short, being unregistered can prevent your products from being sold legally.
- Marketplace enforcement (the “immediate penalty”): Even before regulators issue fines, online marketplaces can block your listings. Platforms like Amazon and eBay will deactivate or hide battery product listings if you lack the required EPR registration. Amazon has said that from August 18, 2025, it will be required to deactivate non-compliant offers or comply on your behalf, depending on the country. eBay warns that sellers without registration IDs may have listings hidden and could face sanctions from local authorities.
- Other ongoing obligations: Compliance isn’t just a one-time task. Producers must report battery sales annually and fund recycling programs. Countries may set collection targets. For example, the EU aims to collect 63% of portable batteries by 2027, rising to 73% by 2030. While you don’t collect batteries yourself, you must participate in a system that does, and regulators may increase pressure or costs if targets aren’t met. Large producers (over €40 million turnover) will also face due diligence obligations from August 2027 to ensure responsible sourcing of raw materials. Battery compliance is an ongoing responsibility that will continue to evolve.
Beyond avoiding penalties, EPR compliance is part of being a responsible business and protecting the environment. Next, we’ll look at how these rules affect Amazon sellers and other e-commerce vendors, who often face extra platform compliance checks.
Implications for Amazon Sellers and Other Online Retailers
Since August 18, 2025, the EU Batteries Regulation has applied to all sellers of batteries and battery-containing products on Amazon, eBay, and other marketplaces. Under EU law, sellers are treated as “producers” and must register in each country where they sell, obtain national battery IDs, appoint an Authorised Representative where required, report sales, and pay recycling fees through PROs. Marketplaces are now enforcing these rules because they can be held accountable for non-compliance.
Amazon
Amazon requires sellers to upload their national battery registration numbers in the Compliance Portal in Seller Central. This applies whether you fulfill orders yourself or use FBA. Failure to comply may result in listings being removed or Amazon stepping in to manage compliance at your expense. Early registration is recommended, especially in key markets such as France, Germany, Italy, Poland, Spain, and Sweden.
eBay
eBay asks producers to provide their battery IDs in their eBay account. Listings may be hidden until you add the necessary battery IDs, and you may be subject to sanctions from local authorities. eBay also advises sellers without a local presence in a country to appoint an authorised representative there.
Key takeaway
EPR compliance is separate from CE marking and product safety requirements, but all are now actively enforced. If you sell directly to end-users in a country where you are established elsewhere, appointing an authorised representative for EPR is mandatory. Acting early will help you avoid disruptions, fines, or loss of sales.
Next Steps for Your Business
The new EPR rule requiring an Authorised Representative for batteries in the EU is a big shift that manufacturers, importers, and e-commerce sellers can’t afford to ignore. It reflects the EU’s push to hold producers accountable for environmental impact, and while the rules may feel complex, they create a fairer system and encourage sustainable business practices.
If you are unsure how battery EPR applies to your products, contact Euverify to discuss your obligations.
Now is the time to act. Don’t risk fines or disrupted sales. Reach out to Euverify to discuss your situation.
Take charge of your EPR obligations today with Euverify. We’ll help you stay powered up in Europe’s new battery economy — sustainably, legally, and with peace of mind.
Sources:
- EU Batteries Regulation (EU 2023/1542) – Key provisions and EPR obligations
- Reverse Logistics Group – EU Battery Regulation implementation and updates (overview of new rules and AR requirement)
- eBay Seller Center – EU Batteries and Waste Batteries Regulation (producer obligations and AR for sellers)
- Amazon Seller Forums – Upcoming EU Batteries Regulation requirements for EPR (Amazon’s compliance deadline and requirements for sellers)
