EU Batteries Regulation Producer responsibility reporting workflow

Start with the Member State where the battery is first made available, not with a generic EU-wide assumption. Article 55 requires a producer to apply for registration in each relevant Member State and states that batteries, including batteries incorporated in appliances, light means of transport or other vehicles, may only be made available there if the producer or authorised representative is registered.

The registration record should identify the producer, trade or tax identifiers, contact point, battery categories and chemistries, the EPR fulfilment route, and any appointed producer responsibility organisation or authorised representative.

Article 56 makes the producer responsible for batteries first made available in a Member State, including batteries resulting from preparation for re-use, preparation for repurposing, repurposing or remanufacturing. The workflow should therefore identify whether EPR is fulfilled individually, through a producer responsibility organisation, or through an authorised representative where required.

The operating record should also show which party covers separate collection, transport, treatment, compositional survey, waste-battery information, data gathering, and competent-authority reporting costs.

The reporting file needs evidence that collection and take-back systems actually cover the relevant Member State and category. Articles 59 and 60 require separate collection systems for portable and light means of transport (LMT) batteries; Article 61 requires take-back for starting, lighting and ignition (SLI), industrial and electric vehicle (EV) batteries; Article 62 adds distributor take-back duties.

Collection evidence must cover the full chain: connected collection points or take-back systems, a free end-user return route, container and safety arrangements, collection frequency, handover to the producer or PRO, and delivery to permitted treatment facilities. A single supplier certificate does not show that chain.

Article 75 sets minimum reporting content for competent authorities. For portable and LMT batteries, producers or PROs report market quantities, including the separate amount for portable batteries of general use, collected waste quantities, collection rates, deliveries to treatment, exports for treatment or preparation, and deliveries for preparation for re-use or repurposing. For SLI, industrial and EV batteries, producers or PROs report market quantities and the collected waste batteries delivered to preparation, treatment, or export routes.

The same reporting workflow must ingest data from waste management operators, treatment operators, recyclers, and certain exporters. Article 75 requires reporting within six months of the end of the reporting year through electronic systems and formats specified by competent authorities. Commission Implementing Regulation (EU) 2025/2289 entered into force in December 2025, so the first full reporting year is calendar year 2026 and the Article 75 deadline for that data is 30 June 2027.

Where the workflow includes treatment or recycling data, Article 75(5) and Delegated Regulation (EU) 2025/606 require more than a high-level collection total. Waste management operators carrying out treatment and recyclers report waste batteries received, waste batteries beginning preparation for re-use, preparation for repurposing or recycling, recycling efficiency, material recovery, and the destination and yield of final output fractions.

Delegated Regulation (EU) 2025/606 makes the recycler data operational: data are broken down by Member State where the waste batteries were collected, cover all individual recycling steps and output fractions, and where recycling is split across more than one permitted facility, the first recycler collects and provides the required information.