EU Batteries Regulation Waste collection and recycling reporting FAQ

Start with the Member State where each battery category is made available on the market for the first time. Article 55 requires a producer register in each Member State, and producers may place batteries on that Member State market only if they, or their authorised representative where applicable, are registered there.

The registration file should identify the producer, battery categories and chemistries, and the measures used to meet extended producer responsibility and collection obligations. For portable and LMT batteries, the file should also explain the system used to keep reported data reliable.

The Batteries Regulation uses extended producer responsibility. Article 56 makes producers responsible for batteries they make available for the first time in a Member State, including batteries resulting from preparation for re-use, preparation for repurposing, repurposing, or remanufacturing.

Producer financial contributions cover separate collection, transport and treatment, compositional surveys where required, information on prevention and management of waste batteries, and data gathering and reporting to competent authorities. A producer responsibility organisation can carry out obligations on behalf of producers.

For portable batteries and LMT batteries, producers or their producer responsibility organisations must establish take-back and collection systems in the Member State where they make those batteries available for the first time. Those systems must cover the whole territory, taking account of population, expected waste battery volumes, accessibility, and proximity to end-users.

End-users must be able to discard waste portable batteries and waste LMT batteries at collection points without being charged, without having to buy a new battery, and without having to prove they bought the battery from the producer that set up the collection point.

For waste portable batteries, producers or producer responsibility organisations must attain and durably maintain collection targets of 45% by 31 December 2023, 63% by 31 December 2027, and 73% by 31 December 2030.

For waste LMT batteries, the targets are 51% by 31 December 2028 and 61% by 31 December 2031. The collection rate is calculated using the Annex XI methodology, which compares collected waste batteries with the average weight of relevant batteries made available on the market to end-users in the three preceding calendar years.

Collected waste batteries cannot be treated as disposal or energy-recovery material. Article 70 requires treatment in permitted facilities, with waste batteries removed from waste appliances, waste light means of transport, or end-of-life vehicles where applicable.

Article 71 requires permitted facilities to accept waste batteries made available to them and ensure preparation for re-use, preparation for repurposing, or recycling. Recyclers must meet Annex XII recycling efficiency and material recovery targets, calculated under the delegated methodology and documentation format for recycling efficiency and recovery rates.

Article 75 is the practical reporting checklist. Producers of portable and LMT batteries, or their producer responsibility organisations, must report annually by chemistry and battery category on placed-on-market amounts, collected waste batteries, collection rates, delivery to treatment, export for treatment or preparation, and delivery to preparation for re-use or repurposing.

Waste management operators, treatment operators, recyclers, and exporters also have reporting duties where they collect, treat, recycle, or export waste batteries. The evidence file should therefore connect sales data, collection data, treatment handovers, recycling calculations, and export records by Member State and battery category.