#BatteryRegulationSeminar: EUCOBAT Stands by Producers as the EU Decides on Battery Regulation Guidelines
Since Member States are at different stages of implementing the Regulation, Eucobat is advocating for transitional periods in the EU Battery Regulation. Eucobat is also concerned that the obligation to take back end-of-life batteries free of charge could bring back batteries placed on the market years ago, shifting costs to producers and distributors and putting pressure on the liquidity of European producer responsibility organisations.
Eucobat, the European association representing national collection schemes for batteries, is based in Brussels and acts as an advocate for producers at EU level. Secretary General Eric Ruyters presented current advocacy priorities at the Battery Regulation Seminar held at Heureka Science Centre in Vantaa in August 2025.
The EU Battery Regulation applies directly in all Member States, and one of its goals is to create a level playing field in the new battery market established by the Regulation.
– We genuinely believe that equal conditions across Member States will benefit us all, says Eucobat Secretary General Eric Ruyters on expectations for EU-level implementation.
Eucobat’s members consist of national producer responsibility organisations running collection schemes in different EU countries. In Finland, Recser Oy is a member of Eucobat.
Organizers of the Battery Regulation Seminar (From the left: Terhi Ilonen, Johanna Alakerttula, Liisa-Marie Stenbäck) and Eric Ruyters. Photo: Sus+Com Agency/Antti Partanen
Transitional Period Needed for Implementation
Because the previous Directive mainly set targets, national collection systems have developed into quite different structures and often cover only part of the battery categories defined in the Regulation. For this reason, and because implementation is still ongoing in many Member States, Eucobat is in discussions with the Commission on the need for a clear transition period into early next year.
– Most of our members have had well-organised systems for portable batteries, since they were already subject to clear collection requirements and targets, Ruyters said.
– With the new Regulation, most of our members are expanding the number of battery categories they cover and developing their organisational structures to include all types of batteries – just like in Finland, where producer organisations are now strengthening their cooperation to ensure that all categories are efficiently covered, he continued.
Ruyters also noted that diverging national practices in implementing the Regulation are causing confusion: Member States have different interpretations of definitions and targets as well as varying registration procedures.
– We certainly do not want to stop the process underway in Europe – we simply want a uniform start for all, he said.
Eric Ruyters. Photo: Sus+Com Agency/Antti Partanen
Addressing the Challenge of Historical Waste
A key requirement of the Regulation for the circular economy is the obligation to take back end-of-life batteries. According to Ruyters, Eucobat sees it as problematic if this obligation also applies to industrial and electric vehicle batteries placed on the market before 18 August 2025, when the new producer responsibility rules entered into force.
– Since in many Member States no take back and recycling fees were collected for these so-called historical batteries placed on the market before that date, it would be unreasonable to require producer responsibility organisations to accept them free of charge, Ruyters explained.
Under the Regulation, however, producers must accept all batteries in their category, regardless of chemistry, brand, or origin. Take-back must be free of charge and cannot be tied to a purchase obligation. The same duty applies to distributors.
– This is part of the broader discussion we are having with the Commission. They were surprised to hear what the free take-back obligation could mean in terms of historical waste. Of course, the Regulation must be followed, but it is important that the responsibility applies only to industrial and electric vehicle batteries placed on the market after the Regulation entered into force.
– Producers themselves remain responsible for batteries placed on the market before that date. They can organise collection and recycling individually or agree on it with a producer organisation, provided that it does not distort the collective system, Ruyters said.
In Finland, a collective collection and recycling system has already been established for all small batteries under 25 kilograms as well as for lead batteries. In addition, there is a functioning collection system for EV traction batteries, operated by Suomen Autokierrätys. The change in Finland therefore mainly concerns large industrial batteries.
Producer Registers and Enforcement
The Regulation requires each Member State to have a mandatory producer register. Registration in the national register is a prerequisite for placing batteries on the market in that country.
– There is no single European producer register – instead, producers must register separately in every Member State where they place batteries on the market, Ruyters clarified.
In addition, distance sellers must appoint an authorised representative. Member States must designate a competent authority responsible for maintaining the register and supervising compliance with producer responsibility. From 18 August 2025 onwards, producer organisations can only fulfil the obligations of the Regulation on behalf of those producers with whom they have a contract.
– Free-riding must not be allowed. Authorities must ensure that free riders are obliged to register, join an approved organisation, and pay their share, Ruyters stressed.
When the EU and its Member States succeed in creating equal conditions and eliminating free-riding, we can together ensure that the objectives of the Battery Regulation are achieved – and that Europe takes a genuine leadership role in the circular economy of batteries.
See the speaker’s presentation:
Read more:
Eucobat’s recommendations for the Commission and the Member States
Photos: Sus+Com Agency/Antti Partanen
Read our previous articles:
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.
Sorry, the comment form is closed at this time.