Webinar Provides Answers: Industrial Battery Producer Responsibility in Practice: What BESS Project Stakeholders Need to Know
The EU Batteries Regulation has significantly changed producer responsibility obligations for industrial batteries. A Batteries Regulation webinar organised by Recser Oy, Recser Industrial Oy, Akkukierrätys Pb Oy and Renewables Finland (Suomen uusiutuvat ry) focused on identifying who is considered a producer under the new legislation and how these obligations are fulfilled in practice in Finland.
The webinar brought together industrial battery producers, BESS project developers and owners, energy sector stakeholders, and public authorities to discuss the changes introduced by the Batteries Regulation. Particular attention was given to the definition of an industrial battery producer, collective producer responsibility, and practical solutions for battery collection and recycling.
Who Is an Industrial Battery Producer?
Jaana Mäenpää, Senior Officer at the Finnish Supervisory Agency, explained the legal definition of battery producers. Producers are economic operators that first place batteries on the Finnish market. A producer may be, for example, a manufacturer, importer, distance seller or distributor.
Producer responsibility may also arise when batteries are sold together with other products, resold under a private label, or placed on the market following reuse, repurposing or remanufacturing. In addition, the obligation may apply to batteries imported into Finland for a company’s own use.
“Batteries may not be made available on the market in an EU Member State unless the producer responsibility obligations have been fulfilled.”
Mäenpää also reviewed the definitions of industrial batteries and discussed how the Batteries Regulation is interpreted in battery energy storage system projects. As supply chains often involve multiple parties, determining producer responsibility may require case-by-case assessment.
Collective Producer Responsibility Changes the Operating Model
One of the most significant changes introduced by the Batteries Regulation is the transition of producer responsibility for large industrial batteries to a collective model. This means that producers jointly finance and organise the collection and waste management of end-of-life batteries within a battery category, regardless of which producer originally placed the batteries on the market.
Established in spring 2026, Recser Industrial Oy is a wholly owned subsidiary of Recser Oy and has been created to manage the collective producer responsibility obligations for industrial batteries other than lead-based batteries. The aim is to separate the responsibilities, costs and operations related to industrial batteries into their own dedicated system.
In the future, producer responsibility for industrial batteries will be managed through Recser Industrial Oy, while portable batteries, batteries for light means of transport, and vehicle batteries (SLI batteries excluding lead-based batteries) will remain within the scope of Recser Oy. Akkukierrätys Pb Oy, in turn, is responsible for fulfilling producer responsibility obligations for lead-based vehicle and industrial batteries.
Producer obligations include registration, reporting batteries placed on the market, and payment of recycling fees. The producer responsibility organisation is responsible for organising the collection network, logistics, recycling operations and regulatory reporting.
The service model has been designed to be fully digital. Producers register through an online portal, report batteries placed on the market electronically, and pay recycling fees based on their reported volumes. In addition, the producer responsibility organisation provides ongoing guidance, regulatory updates and an annual certificate confirming compliance with producer responsibility obligations.
Recycling Solutions for Growing Battery Volumes
Joni Korkola, Recycling Services Manager at Recser Oy, presented the collection, logistics and recycling chain for industrial batteries. The objective is to establish a nationwide collection network across Finland, complemented by direct collection services from large-scale energy storage sites when needed.
The webinar also examined how battery chemistry affects recycling costs. Particular interest was shown in lithium iron phosphate (LFP) batteries, as their recycling is currently more challenging than that of nickel manganese cobalt (NMC) batteries under existing recycling technologies.
“Recycling solutions for LFP batteries already exist, but the costs remain high because current recycling processes have primarily been built around NMC and NCA battery chemistries.”
Nevertheless, recycling technologies are expected to develop rapidly as the growing market share of LFP batteries creates strong incentives for new investments and innovation.
A Clear and Cost-Effective System for Producers
The producer perspective was presented by Veli-Erkki Ruotsalainen, Founder and COO of Cactos Oy, who explained how the company is preparing for the new obligations. According to Ruotsalainen, collective producer responsibility simplifies compliance for companies. Once registration, reporting and fee payments have been completed, the producer responsibility organisation manages the remaining obligations.
A key message from the webinar was that every company involved in the industrial battery supply chain should assess its own role and obligations well in advance. Proper compliance with producer responsibility requirements is a prerequisite for placing batteries on the market. Furthermore, responsibility extends throughout the battery life cycle, from market placement to end-of-life management and recycling.
The producer responsibility system will continue to be developed in cooperation with industry stakeholders and other battery producer responsibility organisations. Future development work will focus on enhancing services for industrial battery producers, supporting closed-loop battery material cycles, and exploring alternative financing and fee models that take into account the long service life of industrial batteries.
Watch the full webinar recording in Finnish with English subtitles here.
Battery Producer Responsibility Organisations
- Recser Oy: Recser.fi
- Akkukierrätys Pb Oy: Akkukierratyspb.fi
Further Information
The Finnish Licensing and Supervision Authority provides additional guidance and official interpretations related to producer responsibility legislation on its website: Legislation and Guidelines on Extended Producer Responsibility – Finnish Supervisory Agency
Read our previous articles:
Webinar Provides Answers: Durability, Safety, Labeling, and Information Requirements for Batteries
This article is a part of the joint communications of the battery producer organisations Recser Oy and Akkukierrätys Pb Oy concerning the EU Batteries Regulation. You can also subscribe to our newsletter to receive the latest news on the subject.
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