#BatteryRegulation: producer responsibility for industrial batteries changes in August 2025 – what does collective responsibility mean?

The EU’s new battery regulation introduces significant changes to the producer responsibility for industrial batteries starting from 18 August 2025. The key change is the expansion of responsibility: producers will be responsible not only for the waste management of their own batteries but also for similar batteries from other producers. This marks a shift from individual contract-based models to a shared, collective system.

From individual responsibility to a shared system

Currently, producers have legally been able to agree on recycling costs with the end user only when the battery reaches end-of-life. This has enabled an individual, retrospective responsibility without an obligation to participate in a shared collection network.

Under the new regulation, producers are required to accept end-of-life batteries free of charge – regardless of the battery’s origin, brand, or chemical composition. According to Article 61, the responsibility also includes so-called orphan batteries, whose origin cannot be traced. This necessitates the establishment of a nationwide collection system for industrial batteries as well.

The role of producer organisations becomes more important

Collective responsibility will in practice be implemented through producer organisations. In Finland, legislation has already steered towards a collective operating model, and the battery regulation reinforces this direction. In practice, joining a producer organisation will become essential.

The regulation requires that recycling fees within producer organisations must be based at least on battery type and chemistry. In addition, factors such as battery durability, recyclability, hazardous substances, carbon footprint, and potential for reuse or remanufacturing must be considered. Potential revenues from recovered raw materials or preparation for reuse can also be taken into account when adjusting fees.

Diverging interpretations on retroactive responsibility – EUCOBAT’s stance is clear

There has been debate about whether collective responsibility also applies to batteries placed on the market before 18 August 2025. EUCOBAT, the European association of battery and accumulator producer organisations, has requested clarification from the Commission regarding the application of Article 61.

EUCOBAT emphasises that the regulation must be applied uniformly across all Member States. National differences could cause market distortions and lead to a situation where compliant producers end up covering the costs of others.

EUCOBAT’s implementation recommendations

1. Time limitation of responsibility
   Batteries placed on the market before 18 August 2025 remain the responsibility of the original producer or must be addressed separately through an agreement with the producer organisation. For new batteries, recycling costs are typically covered in advance through fees paid to producer organisations.
2. Preventing free-riding
   Distance sellers must be required to appoint an authorised representative in the destination country. Authorities must have effective tools and the right to access information in order to monitor compliance with producer responsibility.

What does the change mean in practice for producers?

• Responsibility for recycling costs is no longer limited to a producer’s own products – producers must contribute a fair share to the recycling of similar “orphan” batteries
• Recycling fees are generally paid when the product is placed on the market
• Belonging to a producer organisation is a prerequisite for market access
• Waste management costs can no longer be transferred to the end user

Registration and producer organisations in Finland

Anyone who places batteries on the Finnish market or for their own use must register as a producer before beginning import or sales. Distributors must ensure that the producer belongs to an approved producer organisation.

Lead batteries: Akkukierrätys Pb Oy
Other industrial batteries: Recser Oy

Read more:

Solution for producer responsibility of large industrial batteries – Four companies expanding Recser – Paristokierrätys

Information on Extended Producer Responsibility – Tuottajavastuu – ELY keskus

Home | Eucobat

Read our previous articles:

#BatteryRegulation: the EU battery regulation demands more efficient recycling – Finland prepares for new targets – Paristokierrätys

#BatteryRegulation: answers from the webinar – proper due diligence in the battery supply chain – Paristokierrätys

#BatteryRegulation: Commission guidelines on the removability and replaceability of portable batteries and light means of transport (LMT) batteries – Paristokierrätys

#BatteryRegulation: An Intense Year of Battery Regulation Behind – and a New One Ahead – Paristokierrätys

#BatteryRegulation: The battery passport is real and full of potential – Test the battery passport using the QR code in the article! – Paristokierrätys

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.