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Legal amendments brought together producers of large industrial batteries: “In the morning, I didn’t yet realise we needed to establish a new producer organisation”

Producers of large industrial batteries came together for a joint seminar at the beginning of April. The topic of the seminar was the EU’s new Battery Regulation and the responsibilities it imposes on producers. In the future, producers of industrial batteries must assume shared and comprehensive responsibility for the collection and recycling of decommissioned batteries. The seminar’s follow-up discussions involved taking the first steps towards establishing a producer organisation.

“The new more stringent producer responsibility requirements mean changes for all producers and producer responsibility systems. The producers of large industrial batteries that do not yet have a collective producer responsibility system are facing the most substantial change. These producers will be required to cooperate in the same way as the producers in current producer organisations,” said Chair of Recser’s Board of Directors Seppo Tokola at the start of the event, shedding light on the reasons for organising it.

The seminar organised by Recser Oy was held on 9 April 2024 at Technopolis in the Ruoholahti district of Helsinki. It brought together a total of 36 participants from various organisations.

Before noon, the programme included a presentation on the legislative changes and current producer organisations. The afternoon discussion event involved considering the practical measures required to make the collective responsibility a reality and deciding on the first joint steps that the producers need to take to further the matter.

Producer of industrial batteries, you cannot handle your new responsibilities alone!

There are currently four producer responsibility organisations in Finland, which maintain the statutory collection systems for portable batteries and accumulators, lead-acid batteries, industrial batteries lighter than 25 kg, vehicle batteries and EV traction batteries. A producer that joins a producer organisation outsources the collective producer responsibility obligations to the organisation.

There is plenty of cooperation between the producer organisations, but each have their own delineated responsibilities.

With the exception of lead-based batteries, the systems managed by the organisations exclude all large industrial batteries weighing more than 25 kg, such as battery energy storage systems and traction batteries other than those used for road transport. There is currently no existing organised collection system that would enable the producers to observe the new legal obligations.

“Us producers are facing shared challenges: we need to organise nationwide collection and accept all batteries in our categories. This also entails informing the customer base and organising recycling one way or another… Will we perhaps need a separate industrial facility for dismantling and batteries or modules, or how should we organise the operations? This issue is now specifically a problem shared by producers instead of Recser or the authorities for example,” emphasised Anders Blomqvist, managing Director of Celltech Oy.

The requirement on the transparency of the chain shifts the corporate responsibility to all operators: “Pioneers benefit in this context”

The EU’s Battery Regulation introduces a great deal of new requirements for producers of industrial batteries.

“In the big picture, the change may also open up business opportunities. Pioneers benefit in this context,” said Liisa-Marie Stenbäck, managing director of Recser Oy.

Producer responsibility is part of the transition to the circular economy and corporate responsibility. When a company is able to communicate about responsibility in the right way, this generates business value. Companies should explore the financial opportunities of corporate responsibility and the business models that align with the circular economy simultaneously with planning the measures required by the stricter legislation.

In his talk, Juha Kenraali, managing director of Suomen Autokierrätys Oy, highlighted that the general responsibility reporting requirements concerning large companies are about to be tightened.

“In any case, ESG (corporate responsibility) issues will flood in to affect all operators through many different channels. At first, the reporting will only apply to large operators, but they must keep the entire subcontracting chain transparent, which means that the smaller operators will receive the requirements from the larger ones,” Kenraali said.

The international speaker of the seminar was Secretary General Eric Ruyters of the European association of national collection schemes for batteries EUCOBAT. He emphasised the significance of understanding the new repurposing approach and the operating model.

“It is important to realise how the market dynamics will change as the reuse of waste batteries increases,” Ruyters said.

There are also challenges ahead, because the market has demand for some battery materials but not for others. Senior Inspector Jaana Mäenpää, who is responsible for producer responsibility control at the ELY Centre for Pirkanmaa reminded attendees that the EU’s Battery Regulation also includes the ‘blending obligation.’

“This obligation means that minimum amounts have been determined for the use of recycled materials in new batteries. This will most likely shape the raw material markets,” Mäenpää said in summary.

The new producer organisation is needed: “This communality feels good”

The discussion event held at the end of the seminar found the establishment of the new producer organisation a necessity. The current organisations – Recser Oy, ERP Finland ry, Akkukierrätys Pb Oy and Suomen Autokierrätys Oy – collaborate closely. The new producer organisation for large industrial batteries would be a natural part of this network.

Avant Power Oy’s Samuli Saarela says that he is pleased that the seminar helped to clear up some of the mystery around the waste management requirements of the new Battery Regulation.

“The conversations with authorities were valuable. We certainly have a great deal of new information to take home with us!” Saarela says, summarising the day with satisfaction.

Merus Power Oy’s Teemu Paakunainen also says that the seminar provided clarity.

“Upon arriving for the seminar in the morning, I didn’t yet realise we needed to establish a new producer organisation, but now it seems entirely clear. This communality feels good,” Paakkunainen says.

Recser’s Liisa-Marie Stenbäck, who was responsible for organising the event is also pleased with the yields of the seminar.

“Companies now widely understand and accept their environmental responsibility in terms of the direct effects of their own operations, but not everyone knows that the responsibility extends to the end of the life cycle of all launched products. What is entirely new is that the responsibility at the end of the life cycle will now become collective for industrial batteries, meaning that, in the future, companies with producer responsibility must work together to handle the collection and recycling of decommissioned batteries.”

“This is why it was great that we got a variety of companies at todays’ event to hear and talk about the topic and, most importantly, to take steps to build a producer responsibility system of the future, Stenbäck says.

Recser Oy has promised to support the start-up phase of the producer organisation for industrial batteries by conducting a preliminary analysis of the volumes and producers of large industrial batteries. A small group consisting of producers who participated in the afternoon talks has decided to organise a follow-up discussion event on the topic before the summer holiday season of 2024.  An invitation to the follow-up discussions will be sent to all seminar participants and producers of large industrial batteries that report to Recser.

If you do not receive an invitation and would like to participate in the follow-up discussions, please contact:  Anders Blomqvist, anders.blomqvist(a)

Definitions changed: Is your company now a producer or industrial batteries?

The new legislation defines industrial batteries more specifically than before. They are in particular batteries and accumulators that have been designed for industrial purposes and batteries and accumulators that will enter industrial use after their application is changed.

Examples of industrial batteries are traction batteries used in railway, water and aerial vehicles. Industrial batteries also include the traction batteries of mobile work machines as well as batteries used in communications networks, agricultural operations or the production and distribution of electricity.

Moreover, all batteries and accumulators weighing more than 5 kg are defined as industrial batteries if they are not traction, starting, lighting or ignition batteries (i.e. SLIs) of electric vehicles or LMTs. Therefore, industrial batteries also include consumer products, such as batteries used for storing electricity in households.

The new regulation expands the definition of producers. In addition to importers, manufacturers and distance sellers, the producer responsibility may also apply to distributors. Producers of industrial batteries are regarded to be those who “make the batteries in question available on the Finnish market for the first time.” In the future, remote sellers must appoint an authorised representative to handle producer responsibility in the EU countries where they make batteries and accumulators available on the market by selling them directly to end users.

Responsibilities have changed: Producers, you will now need to handle all of this

The collection and recycling of decommissioned batteries must be handled by their producers. The EU’s Battery Regulation makes the extended producer responsibility more of a shared effort as regards industrial batteries, and batteries may not be made available on the markets without taking care of the responsibility. In Finland, this means joining a producer organisation established by producers.

The producer organisation ensures, on behalf of the producers, that end users can return any waste batteries and accumulators that are regarded as industrial batteries easily and without any additional charges or the obligation to purchase a new product. In simple terms, this means that industrial batteries must be accepted regardless of their origin, brand, condition, nature or chemical composition. The challenge is increased by the fact that industrial batteries launched before the legislative change may also be returned to the collection points.

As such, the receipt must be handled be means a nationwide collection network, collection infrastructure that meets the safety requirements and transport to authorised processing plants. In addition to responding to the tighter recycling efficiency requirements, the recycling processes must be able to recover increasing quantities of the most important raw materials from batteries, such as cobalt, lithium, copper and nickel. After the transition periods, new batteries must use at least the minimum required amounts of recycled raw materials.

See the Ministry of the Environment’s and ELY Centre for Pirkanmaa’s presentations (in Finnish). See the pre-seminar questions and answers.

The EU’s Battery Regulation: Regulation – 2023/1542 – EN – EUR-Lex (

Read more about the EU’s Battery Regulation, pertinent articles from Recser and Akkukierrätys Pb, and summaries of prior events:

#BatteryRegulation: The application of the EU Battery Regulation begins on 18 February 2024 – preparations in Finland (

#BatteryRegulation: The webinar gave additional information about the requirements of the battery regulation (