Here you can get quick answers to your questions.
If you want to dive deeper into a topic, you can also find answers on our dedicated producer responsibility theme page.
Remember! If you can’t find the answers to your questions, we are always ready to help by phone or email.
The regulation came into effect on August 18th, 2023, but many of the requirements are being gradually phased in towards 2028.
From August 18th, 2025, new rules for producer responsibility regarding batteries will apply, and at the same time, a new battery executive order will take effect. The Battery Regulation replaces the previous Battery Directive. Its purpose is to regulate the entire lifecycle of batteries – from design and production to use, waste management, and recycling.
The new aspect is that producers will have the financial and organizational responsibility for the collection and environmentally sound treatment of batteries.
The changes will enter into force on August 18th 2025. However, there will be a transition period, and the framework for the producer responsibility – including reporting and the collection of batteries, etc. – will continue as normal until December 31st 2025.
The new battery regulation is expected to come into force on August 18, 2025, together with the EU regulation (EU 2023/1542).
It is important to emphasize that although changes will occur from August 18, 2025, there will be a transition period, and the framework for producer responsibility—including collection and reporting of batteries, etc.—will continue as usual until December 31st, 2025.
The new aspect of producer responsibility in the EU battery regulation (EU 2023/1542) is that it is much more comprehensive, detailed, and harmonized than previous directives (such as the Battery Directive 2006/66/EC).
The goal is to ensure that producers take greater responsibility for the entire battery lifecycle – from design to waste management.
For the first time, it is the producer, not the member state, who is responsible for meeting the targets.
In Denmark, the producer responsibility for batteries has existed for many years. The battery regulation gives companies both more responsibility and more autonomy. The companies’ obligations are outlined in Chapter VIII of the battery regulation.
A significant change is that battery producers and importers (producers) will henceforth have both financial and organizational responsibility for collection and waste management.
Batteriretur, of course, assists our members in fulfilling this responsibility.
Yes.
The battery categories are increasing from three to five: portable, LMT (light means of transport), industrial, electric vehicle and starter batteries.
From August 18th, 2025, the battery categories expand from three to five:
There are separate requirements and responsibilities for each battery category.
A battery < 5 kg is registered as an industrial battery if it is specifically designed for industrial purposes (e.g. stationary energy storage – also in private homes).
If it is ≤ 5 kg, sealed, and not designed for industrial use – and also not an LMT, SLI, or EV battery – then it is considered a portable battery.
Definition (EU Regulation 2023/1542):
“Industrial battery” means a battery that is specifically designed for industrial uses, intended for industrial use after (re)purposing, or any other battery weighing more than 5 kg that is neither an EV, LMT, nor SLI battery.
(Note: a battery can still be classified as an industrial battery even if it weighs less than 5 kg, if its design/use is industrial.)
Guide – Example: When (< 5 kg) is it an industrial battery?
Is it an LMT, SLI, or EV battery?
– Yes → not an industrial battery.
– No → continue.
Is it specifically designed for industrial use (e.g. UPS/backup, stationary energy storage, industrial machines, telecom, etc.) – regardless of weight?
– Yes → industrial battery (even if < 5 kg).
If not for industrial use: Is it sealed and ≤ 5 kg?
– Yes → portable battery.
– No → (if > 5 kg and not LMT/SLI/EV) → industrial battery (weight fallback rule).
Example:
A 3.5 kg module that is part of a stationary battery cabinet for energy storage in a home → classified as an industrial battery (purpose is industrial/stationary), not a portable battery.
A sealed battery is constructed in such a way that it cannot be opened by the end-user without being destroyed or requiring special tools.
EPR stands for Extended Producer Responsibility.
Extended Producer Responsibility means that producers are responsible for the entire lifecycle of the products they put on the market.
This responsibility especially applies when the products become waste, where companies have the financial, legal, and practical obligation to organize the collection and treatment of their products – in this case, used batteries – once they become waste.
Batteriretur can help manage all these tasks and at the same time ensure economies of scale.
Companies that manufacture, import, and/or distribute batteries in Denmark – either as standalone batteries or as part of products – are subject to the producer responsibility for batteries.
This includes:
manufacturers
importers
distributors
online retailers and platform providers
professional users and producers of equipment containing batteries
These are collectively referred to as “producers.”
All manufacturers, importers, and distributors are subject to the producer responsibility for batteries and are referred to as “producers” in the regulation.
This means that both companies that manufacture the batteries themselves and companies that place batteries or products with built-in batteries on the Danish market have producer responsibility.
The responsibility also applies to sales via e-commerce and direct sales to Danish end users from abroad.
Yes.
Foreign companies that place batteries on the market are now also considered producers.
Batteriretur is a producer responsibility organisation (PRO). We are a private company, organised as an association, and we operate on a non-profit basis.
We manage the producer responsibility on behalf of our members – companies operating on the Danish market – and help handle the practical, legal, and financial obligations associated with producer responsibility for batteries.
Batteriretur is part of the Retur family. We are Denmark’s largest family of PROs, and we help manage producer responsibility for batteries, electronics, packaging, fishing gear, and, in the future, also textiles.
We have been helping companies manage producer responsibility since 2005 and are by far the PRO with the most experience in Denmark.
If your company places batteries in the categories of portable batteries and LMT batteries on the Danish market, it is mandatory to register your company with a producer responsibility organisation (PRO) like Batteriretur.
If you place industrial batteries, electric vehicle batteries, or starter batteries on the market, it is voluntary whether you wish to join a PRO.
You can become a member by filling out a registration form on our website.
In addition to handling the practical tasks related to producer responsibility, we offer free advice and support from our experienced team with relevant knowledge, webinars, tools, guides, newsletters, and more.
Membership in Batteriretur costs 1,500 DKK per year, regardless of the size of your company.
If you are already a member of one or more producer responsibility organisations (PROs) under Retur, you only pay a total of 1,500 DKK for all memberships.
You can sign up for Batteriretur by clicking here and following the instructions.
Note: These rules will soon change due to the new regulation. As soon as we know more about registration, Batteriretur will inform its members.
Once your company becomes a member of Batteriretur, you must also register with the authorities.
Producers and importers must register both with the Danish Environmental Protection Agency (DPA) and with the Danish Business Authority regarding reporting and payment obligations to the Danish Tax Agency for marketed portable batteries.
Batteriretur helps your company start the application process with the DPA if you are a member with us.
For portable batteries to be registered as an item in your business folder with the Danish Tax Agency, you must register with the Danish Business Authority.
This is done via virk.dk.
In Denmark, registration is done per battery category (portable, LMT, industrial, SLI, EV) – not as two separate “household/professional” registers. (as of August 2025!)
Note: These rules will soon change due to the new regulation. As soon as we know more about reporting, Batteriretur will inform its members.
Portable batteries must be reported to the Danish Tax Agency during the period from January 1 to February 15:
After the end of a calendar year, your company must report the quantity of batteries (in kg) sold in Denmark during that year.
Your company must submit the annual report of marketed quantities via your business folder under the menu: Excise Duties – Environment – Portable Batteries.
The Danish Tax Agency transfers your reported quantities to the Danish Environmental Protection Agency (DPA) around March 15.
For portable batteries to be set up as an item in your business folder with the Danish Tax Agency, you must register with the Danish Business Authority.
What options are there for installments, guidance, or reporting with the Danish Tax Agency?
This section describes the rules regarding the collection of payment for marketed quantities of portable batteries and accumulators.
The section includes:
Rules and legal basis (E.A.7.10.1).
Definitions: Batteries and accumulators (E.A.7.10.2).
Portable batteries and accumulators covered by the rules (E.A.7.10.3).
Companies covered by the rules (E.A.7.10.4).
Payment amounts and calculation (E.A.7.10.5).
Statements and settlements, etc. (E.A.7.10.6).
Note: These rules will soon change due to the new regulation. As soon as we know more about registration, Batteriretur will inform its members.
The Danish Tax Agency collects the annual fee rates for payments related to municipalities’ collection of portable batteries. The fee rates are published each year on the Danish Environmental Protection Agency’s website.
Here are the latest fee rates to the Danish Tax Agency:
Payment to the Danish Tax Agency 2024: 5.97 DKK per marketed kg
Payment to the Danish Tax Agency 2023: 5.72 DKK per marketed kg
Payment to the Danish Tax Agency 2022: 5.20 DKK per marketed kg
Payment to the Danish Tax Agency 2021: 5.44 DKK per marketed kg
Payment to the Danish Tax Agency 2020: 5.40 DKK per marketed kg
Foreign companies must have an authorised representative in the Member State where they place batteries on the market if the company itself is not established in the EU.
If the company markets batteries in multiple EU countries, it must have an authorised representative in each country where it markets batteries.
This representative is responsible for ensuring compliance with producer responsibility – including registration, reporting, and any necessary approvals.
If you are a member of Batteriretur, we will apply for approval on behalf of your company and can act as your authorised representative.
Contact: Write to retur@retur.dk to learn more.
If your company operates in several EU countries, we can also assist you through our international collaboration, Pronexa, and our Nordic collaboration, Nordic PRO Solutions.
Write to retur@retur.dk for more information about Pronexa.
Write to nordic@retur.dk for more information about Nordic PRO Solutions.
Example:
A company outside the EU must have an authorised representative in each Member State where they place batteries on the market.
Companies established in the EU, which do not have a physical establishment in Denmark but sell directly to end users in Denmark via distance selling (e.g., online sales), must appoint an authorised representative.
A company established in one EU country (e.g., Germany) may still need an authorised representative in other Member States depending on national implementation, but typically they can operate more freely.
Yes.
Foreign companies must appoint an authorised representative in the Member State where they place batteries on the market, if the company itself is not established in the EU.
If the company markets batteries in several EU countries, it must have an authorised representative in each country where it operates.
This representative is responsible for ensuring compliance with producer responsibility – including registration, reporting, and any necessary approvals.
If you are a member of Batteriretur, we will apply for approval on your company’s behalf and can act as your authorised representative.
Please contact retur@retur.dk for further information.
Companies that sell batteries directly to Danish consumers from another EU country (e.g., a webshop in Germany) are considered remote selling producers and have the same obligations as Danish producers.
They must:
Register in Denmark, typically via an authorised representative – see more under “How should foreign companies register?”
Report sold batteries to Denmark (weight, type, chemistry, etc.)
Ensure correct labeling and information to customers
Collect and report used batteries, if relevant
Participate in a producer responsibility organisation (PRO) or establish their own collection system
All batteries must be correctly labeled, regardless of where they are shipped from – e.g., with QR code, chemistry type, and sorting symbol.
Companies with producer responsibility for batteries must report information each year about the batteries they place on the Danish market.
If you are a member of Batteriretur, this is done via the Returportal.
Before you can report
Your company must be registered in the national producer responsibility register (DPA), which is managed by Dansk Producentansvar.
You must report annually:
Quantities (in kilograms)
Type (battery category and chemistry)
Sold batteries (marketed quantities) – this also includes online sales
Collected used batteries (returned/collected)
Recycled materials (for certain types, e.g., lithium, cobalt, nickel) – this task is handled by Batteriretur as your company’s producer responsibility organisation
Battery chemistry
From August 18th, 2025, companies will be able to register under the new battery categories.
Please note that we are still waiting for guidelines on how the registration should be done, and there is no deadline for registration from the Danish Environmental Protection Agency (DPA) yet. As soon as we know more, Batteriretur will inform its members.
January 1st, 2026:
Reporting: From this date, members must begin reporting quantities for the new categories. This includes both marketed quantities and collected quantities.
June 30th, 2026:
Annual reporting: Reporting of quantities and recycling rates for portable batteries and batteries for light means of transport (LMT) for the previous year.
Producer responsibility covers all batteries.
For registration and reporting purposes, batteries are categorized by types: vehicle batteries, portable batteries, and industrial batteries, and by substance groups: lead, cadmium, mercury, and others.
Companies are generally required to register and report batteries under the new producer responsibility regulations.
However, exemptions apply for batteries used in:
Equipment for Denmark’s defense and security — e.g., weapons and other military equipment.
Equipment designed for space launch.
A battery passport is a digital document containing key information about a battery, such as the manufacturer, capacity, chemical composition, recycled content, and CO₂ footprint.
The battery passport will become mandatory for certain battery types starting in 2027.
Batteries must be labeled with:
Users must be provided with information on correct disposal and recycling.
If the battery does not meet the criteria for the other categories (portable, LMT, SLI, EV), the weight is used as a fallback criterion.
Is it > 5 kg? → then it automatically falls into the industrial battery category, regardless of design/use.
Under the EU Battery Directive (2006/66/EC), batteries must be labeled with the manufacturer’s or importer’s name and address.
As an importer, you are responsible for ensuring that the batteries you import comply with all legal requirements, including labeling.
If batteries are not labeled correctly, this can lead to consequences such as product recalls, fines, or other legal sanctions. Therefore, it may be necessary to review documentation and contracts between the Chinese manufacturer and the importer—or ensure that labeling requirements are included in the contract.
It is the importer’s responsibility to ensure that products imported into a given market comply with legal and labeling requirements.
If in doubt, it may be advisable to seek legal advice to determine the necessary steps to ensure compliance with the law.
If the manufacturer, for example, is in China and the batteries are imported to Europe by a European importer, the labeling must still be done by the manufacturer.
However, the importer is responsible for ensuring that the batteries they import and sell comply with all relevant laws and standards, including the labeling requirements in the new battery regulation.
It is important to note that labeling requirements may vary depending on the specific battery type and applicable national and European rules.
Therefore, it is advisable to consult the relevant legislation and standards and, if needed, seek expert advice to ensure correct labeling of batteries sold as spare parts.
When a product containing a battery is imported into the EU, the European importer is generally responsible for ensuring that the product complies with applicable laws and regulations, including battery-related requirements.
This means the company or person importing the product into the EU is responsible for ensuring the product and its battery meet all relevant EU rules and standards, including the Battery Directive and other applicable environmental and safety regulations.
In some cases, the manufacturer in China may also be responsible for ensuring the product complies with EU rules, especially if there are specific agreements or contracts between the manufacturer and importer.
It is important for the importer to have clear agreements and documentation with the Chinese manufacturer to ensure products comply with all relevant EU regulations and standards, including battery-related rules, before import and marketing in Europe.
According to EU legislation, including the new Battery Regulation, it is the manufacturer’s responsibility to label batteries correctly. The manufacturer is the entity that manufactures or imports batteries or products containing batteries to the EU market.
Producer responsibility means that the party who manufactures or imports batteries is also responsible for those batteries when they become waste and need to be collected for environmental treatment and recycling.
This responsibility for collection and treatment can be managed either by the producer themselves or by using a Producer Responsibility Organisation (PRO) like Batteriretur.
In Denmark, used batteries are collected differently depending on the type.
Municipalities are responsible for collecting portable batteries from consumers. Besides collection at recycling centers, municipalities must establish collection schemes close to citizens, for example, at households or in collection bins.
Municipalities receive payment for their collection efforts, which is why the Danish Tax Agency (Skattestyrelsen) is involved in this part of the producer responsibility.
This means that, unlike other product groups covered by producer responsibility, battery registration must be done with the Danish Business Authority (Erhvervsstyrelsen), and the future annual reporting of marketed portable batteries must be submitted via the Tax Agency, which then transfers the marketed quantities to the Danish Producer Responsibility Administration (DPA).
The Danish Producer Responsibility Administration (DPA) no longer manages the allocation. Instead, Batteriretur handles negotiations regarding collection.
The Producer Responsibility Organisations (PROs), including Batteriretur, have participated in the Environmental Agency’s working group. Additionally, a negotiation group has been formed, including the Local Government Denmark (KL), Circular Denmark (Cirkulær), and the PROs.
Batteriretur manages about 90% of all portable batteries collected in Denmark.
We act as the project lead in developing the agreement on municipal collection. We have entered into a preliminary voluntary agreement and will continue negotiations for a permanent agreement in the fall.
The collection targets ensure that batteries containing environmentally harmful substances do not end up in regular waste, but are properly recycled.
The EU and Denmark have set a target to collect and recycle at least 65% of batteries by 2025 to protect the environment and promote reuse of valuable materials.
Portable batteries must therefore be delivered to separate collection points, such as recycling centers.
Collection targets:
Deadline for registration with new battery categories
Companies must update their registrations according to the new battery categories no later than the end of 2025. This is because the first reporting requirements for the calendar year 2025 will come into effect then.
Deadline for registration:
From 2024 until the end of 2025: Companies must update their battery registrations to include the new battery categories.
Deadline for reporting:
Q1 2025: Reporting of marketed quantities for 2024 must still be done via SKAT (Q1 2025).
Reporting:
Q1 2026: Reporting of marketed quantities for 2025 must take place (most likely via DPA, but this is not yet confirmed). Batteriretur is expected to handle the reporting and upload data to the relevant authority.
From 2027, built-in batteries must be able to be safely removed by the user or by independent repairers.
Integrated batteries must be reported as part of the products they are built into. However, battery data must still be provided separately.
Retur er en familie af non-profit kollektive ordninger, der håndterer producentansvaret på elektronik-, batterier-, emballage-, og tekstilprodukter for importører og producenter.
Som medlem i et eller flere af Retur-familiens kollektive ordninger drager I fordel af vores knap 20 års erfaring og omfattende viden indenfor håndtering af producentansvaret.
Vi hjælper jer ikke kun med at håndtere jeres producentansvar i Danmark. Gennem WEEE-Europe håndterer vi jeres producentansvar i EU, Norge, Schweiz og UK.
Returs kollektive ordninger er blandt de mest omkostningseffektive i EU, og gennem os er I garanteret legitime affaldsstrømme og pålidelig ESG-data.
Genanvendelse og genbrug er en integreret del af vores organisation og daglige arbejde.
Sammen med medlemmerne i vores kollektive ordninger, Elretur, Emballageretur, Batteriretur og Tekstilretur, arbejder Retur for at løfte så mange materialer som muligt ud af affaldsstrømmen gennem genbrug og genanvendelse.
Vores og medlemmernes indsats bidrager til flere af FN’s verdens mål – særligt nr. 11, 12 og 14.
Batteriretur/ Retur
Skagensgade 39, 2 sal
2630 Taastrup
Danmark
Tlf: +45 33 36 91 98
Mail: retur@retur.dk
CVR nr.: 4459 4404
Sign up for our newsletter and receive helpful guides and good advice to help you stay up to date on the producer responsibility.
Dansk 