1 What producers must implement on registration, take-back, and reporting
The EU Batteries Regulation has moved battery compliance from a fragmented directive approach to a directly applicable regulation with phased requirements and higher enforcement expectations. For most companies, the operational pressure point in 2026–2027 is execution.
Key requirements to operationalise
– Correct producer registration in each Member State where you first place batteries on the market
– A functioning take-back model that is free to end-users and auditable
– Defensible annual reporting for placed on market, collection, treatment, and exports
– Alignment with the 2027 digital layer, including QR code and battery passport for relevant batteries
2 Why 2026–2027 is a compliance crunch
From 18 August 2025, the waste-battery management chapter applies and the old Batteries Directive is repealed, so competent authorities expect operational compliance, not just plans.
In 2026–2027, three things typically converge
– Member State registers and PRO controls mature and audits increase
– Companies must industrialise placed on market data and evidence trails to avoid corrections and back-payments
– 18 February 2027 QR code and battery passport obligations add a second compliance track that must be aligned with EPR reporting and product masters
3 Step zero – Confirm producer status and country scope
You are typically a producer if you are the first entity to make a battery available on a Member State market for the first time, including via import and distance selling. Practically
– Producer status is determined per Member State
– You can be a producer in multiple Member States due to import and first-placement patterns
– Your producer status can differ by battery category
For cross-border B2C into a Member State where you are not established, the regulation framework allows and, in certain cases, requires an authorised representative for distance selling setups.
4 2026–2027 compliance roadmap for producers
4.1 Registration in each Member State of first placement
Member States must operate a producer register, and producers must register in each Member State where they first make batteries available on the market.
Execution points
– Register before selling
– Register per battery category and chemistry, not only “batteries”
– Keep registration data continuously updated
A core control is that producers may only place batteries on a Member State market if they or their authorised representative are registered there. Distributors must verify registration before making batteries available, which increases delisting risk if registrations are missing or inconsistent.
4.2 Choose an operating model – PRO versus individual compliance
Producers can comply
– Collectively via a producer responsibility organisation (PRO)
– Individually, if the Member State authorises it and conditions are met
Practical guidance
– PRO-based compliance is usually the only scalable model for multi-country exposure
– Individual compliance is typically realistic only for narrow industrial closed-loop contexts with strong internal capability
4.3 Build a defensible take-back and collection setup
Obligations differ by category, but the producer pays and organises logic is consistent.
Portable batteries
– Producers must ensure separate collection and a take-back system, with collection free of charge to connected collection points and arrangements for transport and handling
LMT batteries
– Producers must ensure take-back and collection systems with appropriate collection points and logistics, with free discard for end-users
SLI, industrial, and EV batteries
– Specialised channels are typical, but you still need contracts, handover routes, and auditable evidence
Distributor take-back is part of your ecosystem
– Distributors must take back waste batteries from end-users free of charge without requiring a purchase, which impacts how producers structure collection networks and PRO contracts
4.4 Budget correctly – what producers must finance
Producer financial contributions must cover at minimum
– Separate collection, transport, and treatment, net of certain revenues from reuse, repurposing, or recovered secondary raw materials
– Compositional survey costs where applicable
– Information obligations and awareness campaigns
– Data gathering and reporting
4.5 Put reporting on rails – data model, evidence, and calendar
For portable and LMT batteries, reporting includes
– Quantities first made available on the market in the Member State, excluding quantities that left the territory before sale to end-users
– Quantities collected, collection rates
– Quantities delivered to treatment or preparation for reuse/repurposing
– Exports for treatment or reuse/repurposing
For SLI, industrial, and EV batteries, reporting includes
– Quantities first made available on the market in the Member State
– Quantities collected and delivered to treatment
– Exports to third countries for preparation for reuse/repurposing or treatment
Timing
– Producers, PROs, and relevant operators must report within six months of the end of the reporting year, with the first reporting period tied to the EU reporting-format implementing act timeline
4.6 Prepare for 2027 digital compliance that overlaps with EPR
From 18 February 2027
– All batteries must carry a QR code as specified in the regulation labelling framework
– For LMT, EV, and industrial batteries above 2 kWh, the QR code must provide access to the battery passport
– The electronic battery passport becomes mandatory for these categories
4.7 Track due diligence separately from EPR execution
EU legislation in 2025 postponed the battery due diligence application date by two years relative to its original schedule. Do not delay EPR readiness because due diligence has moved.
5 Common failure points in 2026–2027 programmes
– Registering only in the HQ Member State instead of every Member State of first placement
– Misclassifying batteries incorporated in products and under-reporting
– Reporting sales instead of first placement and missing the required exclusion for quantities leaving the territory before sale to end-users
– Take-back in theory but no contracts, no collection mapping, and no evidence of free take-back
– Inconsistent brand lists across registrations, PRO contracts, and distributor/marketplace documentation
6 2026–2027 readiness checklist
– Producer status decision per Member State, per category, per channel
– Registration route confirmed in each Member State and proof of registration numbers
– PRO contracts or individual authorisation in place, including financial guarantee where required
– Take-back system mapped and documented, including distributor interfaces
– Reporting data model implemented with audit trail and evidence pack
– Reporting calendar and sign-off workflow aligned to the six-month deadline
– 2027 QR code and battery passport workstream launched for in-scope batteries
7 How RegSurance can help
RegSurance supports manufacturers, importers, and online sellers with an end-to-end Battery EPR programme designed for auditability and multi-country scale.
7.1 Registration strategy and producer status determination
– Producer status determination per Member State and battery category, including distance selling and authorised representative coordination where required
7.2 Registration execution and register maintenance
– Country-by-country registrations, register updates, brand portfolio alignment, and documentation readiness
7.3 PRO identification and contracting
– PRO shortlisting, contracting support, operational onboarding, and governance over cost drivers and role split between producer and PRO
7.4 Reporting framework and placed on market logic
– Placed on market calculation rules, category mapping, exclusion handling, evidence packs, and submission workflows
7.5 Take-back system validation
– Take-back flow design and validation across categories and channels, including distributor and marketplace documentation packs
7.6 Cloud platform for multi-country data management
– Standardised data capture, audit trail, corrections control, and centralised records across submissions and fee calculations
7.7 Multi-stream coordination
– Alignment where batteries sit inside broader compliance exposure, including WEEE and packaging EPR, to reduce double counting and fragmented reporting
8 FAQs
8.1 What is the single most important EPR obligation to get right before 2027
– Correct registration in every Member State where you first place batteries on the market, because it is a prerequisite to legally sell and a distributor control point
8.2 Do we need a PRO in every country
– Often yes in practice, and sometimes because Member States can make PRO participation mandatory; at minimum you need an approved compliance route in each Member State and the ability to meet take-back and reporting obligations
8.3 How do we report placed on market correctly
– Report batteries first made available on the market in a Member State, excluding those that left the territory before sale to end-users; build logic around first placement, not invoicing
8.4 Are batteries inside products included
– Yes; reporting information must include batteries incorporated into vehicles and appliances and waste batteries removed from them
8.5 Are distributors responsible for take-back or are we
– Both; distributors must take back waste batteries free of charge, while producers must organise and finance the overall collection and treatment system, typically via PRO networks and contracts
8.6 When does the battery passport become mandatory
– From 18 February 2027 for LMT batteries, industrial batteries above 2 kWh, and EV batteries placed on the market or put into service
8.7 Did the due diligence obligations move to 2027
– EU legislation in 2025 postponed the due diligence application date by two years relative to its original schedule
Disclaimer
This blog is for general information only, not legal advice, and because EU rules can vary by Member State and change over time, you should seek professional advice for your specific products, supply chain, and country footprint before taking action