Answers from the webinar: what does the EU Battery Regulation require in practice from collection and distributors?
The implementation of the EU Battery Regulation became more concrete with the publication of the national implementation guidance in January. What does this guidance mean in practice for operators in the battery value chain? These questions were addressed at the seventh Batteries Regulation webinar organised by the battery and accumulator producer organisations.
The Batteries Regulation webinar was held on 23 April 2026 and it focused on the practical implications of the new regulation for battery collection, distributors’ take-back obligations and reporting. The webinar attracted more than 240 participants.
During the morning session, participants heard an overview of the national implementation guidance from the Finnish Supervisory Agency, perspectives from producer organisations on collection responsibilities, and practical observations from the Finnish Commerce Federation on the implementation of distributors’ collection.
The EU battery regulation places obligations on different actors across the battery value chain. This webinar focused in particular on distributors – i.e. companies selling batteries. The programme highlighted several themes that were new for many participants, including safety considerations, the use of battery-derived raw materials in fertilisers, the interpretation of the regulation through the national implementation guidance, and the retail sector’s perspective on regulatory responsibilities.
The national implementation guidance clarifies obligations under the EU battery regulation
Senior Officer Jaana Mäenpää from the Finnish Supervisory Agency presented the producer responsibility provisions of the EU Battery Regulation, which entered into force in August 2025. The regulation has introduced significant changes for battery producers and distributors alike.
the Finnish Supervisory Agency published Finland’s national implementation guidance on 30 January 2026. The guidance was updated on 2 March 2026 to correct a translation error in Article 61. Its purpose is to clarify how provisions related to the collection of waste batteries, distributors’ take-back obligations and reporting requirements are interpreted in Finland.
At the same time, the reform of the supervisory authority structure was outlined. As of 1 January 2026, supervision of producer responsibility matters was transferred to the Finnish Supervisory Agency and placed within the Environmental Department’s Circular Economy Unit. Mäenpää acts as the supervising authority for producer responsibility for batteries and accumulators.
The collection network must be comprehensive, accessible and free of charge
The national implementation guidance emphasises that producers or producer organisations must organise a collection network that ensures an adequate service level and accessibility nationwide. Collection points must accept all waste batteries and accumulators belonging to the contracted battery categories, regardless of their chemical composition, condition, brand or origin.
Collection must be free of charge and easy for the waste holder, and producers or producer organisations must provide collection and transport equipment to collection points free of charge.
Minimum requirements are also defined for the number of collection points by battery category. For portable batteries and accumulators, light means of transport batteries and vehicle batteries, each municipality must have, in addition to distributors’ take-back points, at least one regional collection point belonging to the producer responsibility collection network.
For industrial batteries, the requirements depend on battery weight. For waste batteries weighing less than 50 kg, collection must extend to every municipality. For batteries weighing more than 50 kg, the minimum requirement is one collection point per region. In all cases, the distance to a collection point must remain reasonable, and the collection network must be geographically balanced across Finland, taking population density into account.
For traction batteries, the same principle applies: collection must cover every municipality, and regional collection points must be located at a reasonable distance.
Distributors’ take-back obligations expand – flexibility is needed in practical implementation
The implementation guidance also provides clarification on distributors’ take-back obligations. As a general rule, distributors must take back waste batteries belonging to the battery categories that they sell. In certain situations, take-back may be organised at an alternative location, provided that it is at least equally accessible to the end user and otherwise compliant with the regulation.
The guidance also specifies practices related to distance selling within Finland.
- If a sale is concluded through a distance contract without delivery and the customer collects the product from the seller’s pick-up point, the distributor must at a minimum accept waste batteries of the battery categories it sells at its pick-up points.
- If the sale includes delivery to the end user in Finland, the distributor must at least inform the customer at the time of ordering where the regional collection points are located.
From the retail perspective, safety and clear communication are essential
In her commentary, Chief Policy Adviser Marja Ola from the Finnish Commerce Federation emphasised the importance of practical-level solutions. When implementing distributors’ take-back, safety must be ensured and operating models must be built on a documented risk assessment.
Take-back arrangements may vary depending on store premises, warehouse spaces, outdoor areas or other facilities. Collection solutions must take into account battery chemistry, appropriate collection containers and their correct placement.
Clear communication plays a key role. Customers must be clearly informed which waste batteries are accepted, where they can be returned and how the return process works. If a particular battery category cannot be accepted at a store for a justified reason, the customer must be given unambiguous instructions on the nearest collection point. This is essential both for customer service and for safety, to prevent batteries from ending up abandoned in car parks, streets or mixed waste.
Ola also highlighted the need for staff training. Handling and take-back of waste batteries must be properly managed in stores, and sufficient battery-related competence is also required from partner personnel such as cleaners and security staff. In addition, instructions, communication materials and collection equipment must be updated to reflect the new requirements.
The message from the Finnish Commerce Federation was clear: cost-efficient and safe battery collection is a shared interest across the entire value chain, and recycling targets can only be achieved through cooperation.
Roles of the three producer organisations – a shared objective of efficient battery circulation
During the webinar, the producer organisations Suomen Autokierrätys Oy, Recser Oy and Akkukierrätys Pb Oy presented their respective roles in implementing the EU Battery Regulation. While legislation defines the obligations, practical implementation is built on producer organisations’ infrastructure, cooperation and operational solutions.
Suomen Autokierrätys Oy is responsible for the collection and recycling of traction batteries from electric vehicles. The traction battery collection network consists of distributors such as vehicle repair shops and authorised reception points for end-of-life vehicles. Traction batteries are delivered to Stena Recycling for treatment. The DELV system supports the collection process, including arranging collections of traction batteries.
Akkukierrätys Pb Oy is responsible for the collection and recycling of vehicle and industrial lead-acid batteries. Its collection network covers all municipalities, with regional collection points including municipal waste stations, battery retailers, vehicle service centres and waste management operators’ facilities. Akkukierrätys Pb cooperates with ten waste management companies handling collection, logistics and treatment. The collection rate for lead-acid batteries is 100 %, enabling the efficient return of lead to the production of new batteries.
Recser Oy is responsible for the collection and recycling of portable batteries and accumulators, light means of transport batteries, vehicle batteries (excluding lead-acid batteries) and industrial batteries (excluding lead-acid batteries). Recser’s collection network consists of approximately 7,000 retail collection points and 500 regional collection points. Following the changes introduced by the EU Battery Regulation, the return network will expand to all battery sales points, and a dedicated collection network will be established for industrial batteries. Collection equipment will be updated, and communication and guidance will be strengthened.
Producer organisations’ websites provide information on collection networks, instructions and materials that can be used, for example, in distributors’ staff training and consumer guidance.
Producer organisations are responsible for collection networks
The core task of producer organisations is to organise functional, nationwide and compliant collection networks for their respective battery categories. This includes planning and maintaining the collection network, ensuring sufficient coverage and accessibility, providing collection and transport solutions to collection points, and cooperating with distributors to organise take-back in stores or alternative locations.
Producer organisations also ensure that collected waste batteries are directed to appropriate treatment and recycling and that producer responsibility systems comply with legislative requirements.
A shared message: successful implementation is built on cooperation
The obligations of the EU Battery Regulation have become clearer, but their practical implementation requires more detailed planning, communication and cooperation from producer organisations, distributors and other stakeholders.
The national implementation guidance provides important interpretative support. Ultimately, success depends on how effectively the obligations are embedded into day-to-day processes, collection network implementation, safety arrangements and reporting.
Producer organisations play a central role as system builders and coordinators, ensuring that the objectives of the EU Battery Regulation are implemented in practice across Finland.
Producer organisations’ websites
- Suomen Autokierrätys Oy: Recycling of electric vehicle traction batteries
- Akkukierrätys Pb Oy: Recycling of lead-acid batteries
- Recser Oy: Organising battery and accumulator recycling
Further information
- Licensing and Supervisory Authority: Producer responsibility legislation and guidelines, including the national implementation guidance for the EU Battery Regulation.
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.
Sorry, the comment form is closed at this time.