FAQBatteries RegulationEU

EU Batteries Regulation Waste collection and recycling reporting FAQ

Under Regulation (EU) 2023/1542, waste battery collection and recycling reporting is an workflow: register in each relevant Member State, finance and operate collection or take-back routes, send collected batteries to permitted treatment, and report the required data.

This FAQ focuses on portable and LMT battery collection targets, free take-back, treatment and recycling evidence, and the records needed for competent-authority reporting.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

Waste battery obligations under the EU Batteries Regulation span producers, producer responsibility organisations, distributors, waste operators, and recyclers. Each actor holds part of the evidence chain for Member State registration, collection-rate monitoring, treatment, , material recovery, and Article 75 reporting.

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6 of 6 questions
Question 1

What should producers do first for waste battery collection and reporting?

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 and collection obligations. For portable and LMT batteries, the record should also explain the system used to keep reported data reliable. Chapter VIII, which contains these waste-management duties, applies from 18 August 2025; national registers, competent authorities, and filing mechanics still have to be checked in each Member State.

  • Map each battery category: portable, light means of transport (LMT), starting, lighting and ignition (SLI), industrial, and electric vehicle batteries.
  • Register in every Member State where batteries are first made available on the market.
  • Record whether obligations are fulfilled individually, through an authorised representative, or through a .
  • Keep written evidence of collection measures, data reliability controls, and any mandate.
Recommended next step

Turn waste battery reporting into a verifiable evidence file

Use the FAQ to map Member State registrations, collection systems, take-back routes, treatment records, recycling calculations, and Article 75 reports before reporting cycles close.

Question 2

Who pays for collection, take-back, treatment, and reporting?

The Batteries Regulation uses . 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 can carry out obligations on behalf of producers.

  • Budget collection, transport, and treatment costs by Member State and battery category.
  • Include reporting and data gathering in the EPR cost model, not only logistics invoices.
  • For repurposed or remanufactured batteries placed on the market, check whether the operator becomes the producer for EPR purposes.
  • Confirm national registration fees, filing procedures, and producer-responsibility arrangements with the competent authority in each Member State of first supply.
Question 3

How must free collection and take-back work for portable and LMT batteries?

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.

  • Portable battery collection points can involve distributors, public authorities, voluntary points, end-of-life vehicle treatment facilities, and waste electrical and electronic equipment (WEEE) treatment facilities.
  • LMT battery systems use the same types of cooperation points, with suitable infrastructure for the volume and hazardous nature of LMT waste batteries.
  • Distributors must take back waste batteries from end-users free of charge, limited to categories they have or had in their offer and, for portable batteries, normal non-professional quantities.
  • Distance sellers must provide collection points across the Member State and tell end-users the take-back arrangements when a battery is ordered.
Question 4

Which collection targets matter for portable and LMT batteries?

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 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.

  • Track placed-on-market weights by Member State, category, and chemistry.
  • Exclude batteries that left that Member State before sale to end-users when reporting placed-on-market amounts.
  • Keep collection-point data connected to the producer or collection system.
  • Prepare corrective-action evidence if a competent authority finds collection measures are not consistent with achieving the targets.
Question 5

What has to happen after waste batteries are collected?

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 and material recovery targets, calculated under the delegated methodology and documentation format for recycling efficiency and recovery rates.

  • Maintain handover records from distributors, public collection points, voluntary points, WEEE facilities, and end-of-life vehicle facilities.
  • Show that collected batteries were delivered to permitted treatment, preparation for re-use, preparation for repurposing, or recycling facilities.
  • For exported waste batteries, retain documentary evidence approved by the destination competent authority when counting treatment toward EU obligations.
  • For recycling evidence, preserve data for each individual recycling step and output fraction.
Question 6

What should the Article 75 reporting evidence file contain?

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, including the separate amount for portable batteries of general use, 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.

Article 75 ties the first reporting period to the reporting-format implementing act. Commission Implementing Regulation (EU) 2025/2289 entered into force on 11 December 2025, so the first full reporting year is calendar year 2026. Article 75 requires the covered reporting parties to report within six months after that year ends, making 30 June 2027 the EU-level deadline for 2026 data. The competent authority still controls the electronic submission system, format, and any additional information needed to check reliability.

  • Placed-on-market data: first making available in the Member State, excluding batteries that left before sale to end-users, with portable batteries of general use reported separately.
  • Collection data: collected waste portable and LMT batteries, by category and chemistry, plus the achieved .
  • Treatment data: amounts delivered to permitted treatment, preparation for re-use, preparation for repurposing, or recycling facilities.
  • Export data: amounts exported for treatment, preparation for re-use, or preparation for repurposing, with supporting destination evidence where needed.
  • Recycler data: , material recovery, destination, and yield of final output fractions, covering all recycling steps.
  • Submission control: prepare calendar-year 2026 data for submission by 30 June 2027 through the relevant competent authority's electronic system.
Primary sources

References and citations

eur-lex.europa.eu7 citations
Referenced sections
  • Primary legal source for producer registration, extended producer responsibility, free collection and take-back, collection targets, treatment, recycling, shipment evidence, and Article 75 reporting.
  • Article 55 supports the Member State producer registration requirement and the registration evidence needed for battery categories, chemistries, EPR measures, and data reliability controls.
  • Article 56 supports the producer responsibility rule and the cost categories for separate collection, treatment, information, data gathering, and reporting.
Show 4 more
  • Articles 59, 60, and 62 support the free collection and take-back requirements for portable and LMT batteries, including distributor and distance-sale obligations.
  • Articles 59, 60, and 69, together with Annex XI, support the detailed target dates, collection-rate calculation approach, Member State monitoring, and corrective-action process.
  • Articles 70 to 72 support the treatment route, recycling obligation, export evidence rule, and requirement to cover all recycling steps and output fractions.
  • Article 75 supports the annual reporting fields for producers, producer responsibility organisations, waste management operators, recyclers, exporters, and treatment operators.
"concerning batteries and waste batteries"
More quoted passages
"Producers shall register in the register"
"Producers shall have extended producer responsibility"
"shall not be charged"
"calculate the collection rate"
"shall not be disposed of"
"report to the competent authority"
data.europa.eu2 citations
Referenced sections
  • Official delegated methodology and documentation-format source for calculating and verifying recycling efficiency and recovery rates from waste batteries.
  • This delegated regulation is the official methodology and documentation-format source for calculating and verifying recycling efficiency and recovery rates for waste batteries.
"recycling efficiency and recovery rates"
More quoted passages
"calculation and verification"
eur-lex.europa.eu2 citations
Referenced sections
  • Binding reporting-format act used to determine the first Article 75 reporting period and the category, chemistry, and quality-control reporting structure.
  • The reporting-format act was published on 21 November 2025 and entered into force 20 days later. Together with Article 75(7), that makes calendar year 2026 the first reporting period and 30 June 2027 the reporting deadline.
"format for the reporting of data"
More quoted passages
"The data shall be reported separately for each of the battery categories"
eur-lex.europa.eu2 citations
Referenced sections
  • Plain-language EUR-Lex summary supporting the battery categories, portable and LMT collection targets, recycling efficiency targets, and material recovery targets.
  • The EUR-Lex summary gives the headline portable and LMT collection targets and provides a concise source for search visitors checking the target percentages.
"collected, reused and recycled"
More quoted passages
"waste collection targets for producers"
environment.ec.europa.eu2 citations
Referenced sections
  • Commission explanation of the delegated recycling rules, including calculation guidance for recyclers and harmonised documentation for Member State authorities.
  • The Commission news page explains that the delegated rules create consistent calculation guidelines for recyclers and a harmonised documentation format for Member State authorities.
"recycling efficiency of recyclers"
More quoted passages
"harmonised format for documentation"
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