Since 18 August 2025, the EPR scheme for batteries has changed scale with the application of European regulation 2023/1542.

If you sell portable products containing batteries (smartphones, electric scooters, cordless tools, connected toys), you become a direct link in a scheme that is now heavily regulated: CE marking, eco-contributions, traceability, authorised representative for foreign sellers. The framework is becoming stricter and more complex.

The following explains clearly what is changing and how to turn this regulatory constraint into a managed process.

EPR Batteries: New obligations for sellers of portable products.

Reading time: ~11 min

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Understanding the EPR scheme for batteries under the new European framework

Extended producer responsibility (EPR) is based on a simple principle: whoever places a product on the market must finance and organise the management of its waste throughout its life cycle, from commissioning to collection and recycling.

With regulation 2023/1542, Europe no longer targets only small portable batteries. The scheme now covers all battery families and imposes common rules on safety, environmental performance and information.

Businesses concerned: manufacturers based in France; importers who buy outside France to resell on the French market; marketplace sellers and e-commerce brands who ship portable products to French customers; producers not established in France, who will be required to appoint an authorised representative from 12 August 2026.

In short, if you sell a product containing a battery, you are almost always considered a producer and therefore responsible under the EPR scheme for batteries.

Which battery categories are concerned

Main categories

• Portable batteries: smartphones, tablets, connected watches, toys, small household appliances, domestic tools (businesses: e-commerce sellers, D2C brands, general retailers).

• Light means of transport (LMT) batteries: scooters, electric bikes, gyropods, hoverboards (micro-mobility platforms, specialised marketplaces).

• Electric vehicle (EV) batteries: electric cars and light commercial vehicles (manufacturers, importers, car dealers).

• SLI batteries (starting, lighting, ignition): automotive batteries for combustion or hybrid engines (auto centre networks, spare parts sites).

• Industrial batteries: stationary storage, professional equipment, backup power systems (B2B suppliers, energy integrators).

Even if you only sell small portable items, the "portable batteries" and "LMT batteries" categories are already enough to make you subject to the EPR scheme.

New key obligations for sellers of portable products

CE marking and placing on the market

All batteries placed on the European market after 18 August 2025 must carry the CE marking. The seller must check the certification, keep the technical documentation and be able to present it in the event of an inspection. If you import products containing batteries from a non-EU country, you are responsible for this compliance.

Extended responsibility and eco-contributions

The producer finances the end of life of the products. Two options: join an approved producer responsibility organisation (PRO) (the most common case) or set up an individual system validated by the authorities. In practice, you need to register, obtain an EPR unique identification number (UIN), periodically declare quantities by category and pay the corresponding contributions. The multiplication of declarations (packaging, WEEE, textile, furniture, construction products…) can quickly become time-consuming.

Authorised representative for foreign sellers

Any producer or seller not established in France will need to appoint, from 12 August 2026, an authorised representative for France. This representative handles registrations, prepares declarations and pays the eco-contributions. CompliancR offers this service.

Removal and replacement of integrated batteries

Portable batteries must be easily removable by the end user, without any specific tool. For LMT, EV and industrial batteries, replacement must at least be possible by an independent professional. Sellers must check compliance with their suppliers, provide clear instructions and anticipate after-sales returns.

Labelling and user information

Each battery must state the chemistry used, the capacity, the estimated lifespan, collection/recycling instructions, the possible presence of hazardous substances and precautions for use. This information must also be available in open electronic databases.

Duty of care across the supply chain

Producers must implement a due diligence policy: risk mapping, supplier identification, prevention and remediation measures. Sellers of portable products must be able to trace the origin of the batteries.

Recycling targets and environmental performance

Minimum recycling efficiency thresholds come into force from 31 December 2027. Sellers will need to offer take-back solutions, inform consumers about collection points and source from manufacturers able to demonstrate good recycled content performance.

Risks and penalties for non-compliance

Authorities can restrict or ban placing products on the market, order the withdrawal or recall of entire batches and impose heavy financial penalties. Marketplaces now require proof of EPR registration; without a UIN, your listings can be blocked or removed.

How to simplify your EPR compliance for batteries

Two approaches: manage internally (regulatory monitoring, data management) or outsource to an authorised representative and a specialised platform. CompliancR automates catalogue analysis, application of fee scales, generation of declarations and multi-scheme tracking. Sellers not established in France can also entrust CompliancR with the role of authorised representative.

FAQ on the EPR scheme for batteries

Who is considered a producer?

Any business that, for the first time, places on the French market a battery or a product containing a battery: manufacturers, importers, marketplace sellers and D2C brands.

I only sell on a marketplace, does this concern me?

Yes. Marketplaces request your EPR unique identification number (UIN), which is your registration number in the EPR scheme managing your products, and can suspend your listings in the event of non-compliance.

Do I need to join several producer responsibility organisations if I sell different types of products?

In most cases, yes. Each EPR scheme (batteries, packaging, WEEE, textile, furniture, construction products…) often requires a separate membership, resulting in a heavy administrative burden.

What does my company risk if I do not comply in time?

Financial penalties, product withdrawals or recalls, restrictions on placing products on the market and account suspensions on platforms. The reputational impact can also be significant.