THE EXTENDED PRODUCER RESPONSIBILITY FOR BATTERIES

If your company manufactures, imports, or sells batteries, you have a producer responsibility.

This means that your company is responsible for ensuring that your batteries are collected and treated in the most environmentally responsible way possible and that as much as possible is recycled when the batteries can no longer be used.

The Extended Producer Responsibility for Batteries is based on the principle that the polluter pays and bears the responsibility for the waste generated by their products. This means that, as a company, you have a legal, financial, and operational responsibility for managing your batteries once they reach the waste phase.

Currently, there is a producer responsibility for electronics, batteries, packaging, fishing gear, and vehicles. Work is also underway to introduce producer responsibility for textiles in a few years.

In addition to the responsibility for managing your company’s battery waste, producer responsibility also includes obligations for collection, treatment, reporting, and submission of data to the authorities.

Batteriretur assists you with all these tasks.

By shifting the financial and practical burden of waste management onto producers, importers, and distributors, there’s a strong incentive to design and market batteries, and battery-containing products that are more environmentally friendly — for example, easier to recycle, dismantle, or with a longer lifespan.

The goals are to:

• reduce the environmental impact of battery waste
• increase the amount of batteries that are properly collected and treated
• promote a circular economy and efficient use of resources
• ensure responsible handling of hazardous substances in batteries

With producer responsibility, environmental considerations and product accountability become part of the business model.

The new EU Battery Regulation sets a new standard for how batteries must be produced, used, and handled as waste.

Its purpose is to ensure more sustainable batteries with a lower carbon footprint, fewer hazardous substances, and increased and improved recycling. The regulation covers all types of batteries – from ordinary portable batteries for remote controls and mobile phones to batteries for electric vehicles – and introduces requirements such as due diligence, labelling, digital battery passport, and CE marking.

The revised regulation also supports the EU’s goal of climate neutrality and strengthens supply security by promoting a circular economy and reducing dependence on raw materials from third countries.

The regulation came into force in February 2024 and will be implemented gradually over the coming years.

It replaces the previous Battery Directive and now applies as a regulation, meaning the rules are directly binding in all EU member states without the need for national implementation.

The regulation covers all types of batteries, from portable batteries in electronic devices to batteries in electric vehicles, and introduces requirements including:

• Due diligence in sourcing raw materials
• Labelling and information on capacity, service life, and content
• A digital battery passport for increased traceability
• CE marking as proof of compliance with requirements
• Requirements for performance, durability, recycled content, and removability/replacement of batteries

Changes in Producer Responsibility

The regulation also brings changes to the producer responsibility as we know it in Denmark.

Previously, municipalities were responsible for collecting used batteries from households and received compensation through DUT funds. Under the new regulation, producers themselves must organise and finance producer responsibility, including take-back schemes and environmentally sound treatment of used batteries.

Batteriretur operates as a producer responsibility organisation (PRO), handling the organisational and financial responsibility for collection and environmentally sound treatment of batteries on behalf of its members – companies operating on the Danish market.

New Obligations for Actors in the Battery Value Chain

In addition to producers, the regulation also imposes requirements on importers, distributors, authorised representatives, and recyclers, who now have new obligations regarding documentation, labelling, and responsibility for sustainability.

Here are the key changes:

New battery categories:
The number of battery categories is expanding from three to five: Portable, LMT (Light Means of Transport), industrial, electric vehicle, and starter batteries.

Climate and environmental requirements:
The carbon footprint of certain battery types must be documented and reduced. There will also be requirements for minimum levels of recycled raw materials (including lithium, cobalt, and nickel).

Higher recycling targets:
Ambitious targets are being set for both collection rates and efficient material recovery, with increasing percentages towards 2036.

Product design and labelling:
Batteries must be replaceable and labelled with both the CE marking and a QR code. Users must be able to easily identify and understand key battery characteristics.

Digital battery passport:
From 2027, certain batteries will be required to have a digital passport, enabling traceability of materials and usage throughout the battery’s entire life cycle.

Due diligence and accountability:
Larger companies will be required to ensure responsible sourcing – including for raw material extraction in third countries. Companies can also expect their due diligence policies to be subject to third-party verification and regular audits to ensure compliance with the regulation’s requirements.

Who is affected?
All actors in the battery life cycle – producers, importers, distributors, and treatment operators – will have to comply with the new requirements.

This means that the producer responsibility applies both to companies that manufacture the batteries themselves and to companies that place batteries or products with built-in batteries on the Danish market.

This applies to all types of batteries, whether loose or integrated – for example, in power tools, toys, portable electronics, or household appliances.

Batteries used in space technology and/or military equipment are exempt.

The reason the responsibility is placed on the producer, importer, or distributor is that these companies introduce the batteries to the market and therefore have the greatest ability to influence their design and choice of components – including how the batteries can later be collected and treated.

Generally, companies with producer responsibility for batteries can be divided into three main categories:

Producer: For example, a company that manufactures electrical devices with built-in batteries and sells them under its own name or brand.

Importer: For example, a company that imports batteries or products containing batteries from abroad and sells them in Denmark.

Distributor: For example, a company that resells batteries or battery-powered products under its own name, thereby being regarded as a producer.

Regarding online sales and/or remote selling

The producer responsibility applies regardless of sales channels – meaning it also applies if your company sells via e-commerce or directly to end-users in Denmark from abroad.

COLLECTION, TREATMENT, AND RECYCLING

As a producer, importer, or distributor, your company is responsible for ensuring that the batteries you place on the Danish market are properly collected and treated when they reach end-of-life.

This means, among other things, that you must:

• Cover the costs of collection and treatment.
• Ensure that batteries are handled in accordance with EU requirements for recycling and recovery.
• Comply with specific targets for collection and material recovery – these targets increase through 2031 and 2036.

By being a member of Batteriretur, you can be confident that these requirements are met both administratively and practically.

REGISTRATION

All companies marketing batteries in Denmark are subject to the producer responsibility. This means your company must be registered with Dansk Producentansvar (DPA).

Registration requires your company to report on your activities and the types of batteries you place on the market.

Batteriretur assists you with this process.

Please note: Foreign companies selling directly to Danish customers must either register themselves or appoint an authorised representative in Denmark.

Batteriretur helps with registration and ensures your company is properly listed in the official mandatory registers.

REPORTING

Producers, importers, and distributors subject to the Extended Producer Responsibility for Batteries must regularly report the quantities of batteries they place on the market.

The Extended Producer Responsibility for Batteries applies to all batteries:

• Portable batteries
• Batteries for light means of transport (LMT)
• Batteries in electric vehicles (EV)
• Industrial batteries (IND1, IND2)
• Starter, lighting, and ignition batteries (SLI)

Here’s an overview:

Portable batteries

Small, sealed batteries under 5 kg that are not designed for industrial purposes, and which are neither starter batteries, LMT batteries, nor electric vehicle batteries.

Examples:

• AAA/AA batteries
• Batteries for power tools, cameras, and laptops
• Power banks and portable power stations under 5 kg
• Batteries for toys and hobbies

Batteries for light means of transport (LMT)

Batteries under 25 kg that provide power for propulsion in vehicles that can operate on an electric motor (alone or combined with muscle power) and that do not fall under the electric vehicle category.

Examples:

• Batteries for e-bikes, e-scooters, e-scooters (kick scooters), and mono-wheels

Starter batteries

Batteries specifically designed to start engines, power lights, or ignition systems, which can also serve as backup in vehicles and machinery.

Examples:

• Batteries for cars, motorcycles, mopeds
• Tractor and garden tractor batteries

Industrial batteries

Batteries over 5 kg that are designed for or used in industrial applications, or that do not fit into the other categories.

Examples:

• Stationary energy storage systems
• Commercial batteries and large battery packs
• Batteries over 5 kg in power stations, electric boats, electric trains, and electric garden tractors

Electric vehicle batteries

Batteries for hybrid or electric vehicles in vehicle categories L, M, N, and O — specifically designed to provide propulsion and weighing more than 25 kg.

Examples:

• Batteries for electric cars and hybrid cars
• Larger batteries for electric vehicles in class L (e.g. electric motorcycles or electric dirt bikes)

Note: It’s important to distinguish between battery types, as different requirements and reporting obligations apply depending on the category. The producer responsibility applies whether you manufacture, import, or sell batteries – physically or online.

Batteries falling under multiple categories

In some cases, batteries may fall under several categories. In such instances, the battery is subject to the category with the strictest requirements.

Exemptions

In general, the regulation’s broad scope covers almost all batteries placed on the market or put into use within the EU, with only a few exemptions where batteries are not covered.
Batteries used in military equipment and space applications are not included.

These requirements apply across the battery’s entire lifecycle and have major consequences for how batteries and battery-powered products must be designed in the future.

WHY ARE STRICTER PRODUCT REQUIREMENTS BEING INTRODUCED?

The new rules aim to:

• Protect the environment: Reducing hazardous substances such as mercury, lead, and cadmium.

• Promote recycling: More critical raw materials must be recovered, e.g. lithium and cobalt.

• Increase transparency: Digital passports will make it possible to trace the battery’s origin and environmental footprint.

• Improve durability and performance: Especially in portable products.

• Boost innovation and competition: Common EU standards are intended to promote technological development and secure supply chains.

KEY REQUIREMENTS FOR DESIGN AND CONTENT

CO₂ footprint

From 2025, rechargeable industrial batteries >2 kWh, LMT batteries, and EV batteries must be accompanied by a CO₂ declaration indicating the battery’s climate footprint per kWh over its lifetime. Limit values for allowable CO₂ footprints will be set later.

RESTRICTION OF HAZARDOUS SUBSTANCES

• Mercury: banned in all battery types.

• Cadmium and lead: banned in portable batteries from August 2024 (exception: zinc-air button cells until August 2028).

DESIGN REQUIREMENTS – EASY BATTERY REPLACEMENT

From 2027, portable batteries must be removable and replaceable by the user — without the use of special tools.

LMT batteries must be replaceable by professionals.

RECYCLING AND RECOVERY

Recycling efficiency – by 2025:

• 75% for lead-acid batteries

• 65% for lithium-based batteries

• 80% for nickel-cadmium batteries

• 50% for other batteries

By 2030:

• 80% for lead-acid batteries

• 70% for lithium batteries

RECOVERY OF MATERIALS

Lithium:

• 50% by 2027

• 80% by 2031

Cobalt, copper, lead, and nickel:

• 90% by 2027

• 95% by 2031

MINIMUM REQUIREMENTS FOR RECYCLED CONTENT IN NEW BATTERIES

From 2031 (for industrial, EV, LMT, and starter batteries):

• 16% cobalt

• 85% lead

• 6% lithium

• 6% nickel

From 2036:

• 26% cobalt

• 85% lead

• 12% lithium

• 15% nickel

LABELLING AND TRACEABILITY

General labelling – from 2026 batteries must be labbeled with:

• Manufacturer, date, origin

• Chemistry, weight, and capacity

• Hazards and critical raw materials

From 2027, labelling will be via QR codes.

DIGITAL BATTERY PASSPORT – FROM 2027, REQUIRED FOR:

• LMT batteries

• Industrial batteries >2 kWh

• EV batteries

The battery passport will contain key information and must be accessible via the QR code.

SAFETY

• Companies must identify and manage social and environmental risks related to raw materials such as lithium, cobalt, nickel, and natural graphite.

• Restrictions on hazardous substances such as mercury, cadmium, and lead apply, and batteries must be accompanied by information about their ecological footprint.

• From 2026/2027, labelling with information about battery components and recycled content will be mandatory via QR codes and digital “battery passports” for larger battery types.

CE MARKING AND COMPLIANCE

Before placing a battery on the market:

• The battery must be CE-marked.

• The company must have an EU Declaration of Conformity ready (which must be kept for 10 years).

MONITORING OF BATTERY LIFE AND CONDITION

Already from 2024, certain battery types (LMT, EV, and industrial batteries) must be equipped with a battery management system that monitors:

• State of health

• Expected remaining lifetime

• Suitability for reuse or recycling

FUTURE CHANGES

The EU Commission will continuously evaluate and may introduce further requirements:

• 2025: Possible harmonisation of universal chargers

• 2027: Assessment of a potential deposit return scheme

• 2030: Consideration of phasing out non-rechargeable batteries

The design of both batteries and the products they are built into must support easy replacement, increased durability, and traceability of materials.

This includes requirements that certain batteries must be removable and replaceable either by the end user or a professional, and that information about battery content and origin must be easily accessible via labelling and QR codes.

For manufacturers and designers, this means circular principles must be considered already during the development phase — from material selection to construction and disassembly.

The following provides an overview of the specific requirements, deadlines, and implications for the various battery types.

PORTABLE BATTERIES

The EU Regulation introduces new requirements and deadlines for portable batteries, focusing on sustainability and the circular economy.

Definition:
A portable battery is a sealed battery weighing no more than 5 kg, not designed for industrial use, and not used for electric vehicles, light means of transport (LMT), or as a starter battery.

Key requirements and deadlines:

• Removal and replacement: From February 18th, 2027, portable batteries in electronic devices must be removable and replaceable by the end user without the use of specialist tools. In other words, it must be possible to use commonly available tools such as a screwdriver.

• Exceptions: The requirement does not apply to devices designed for regular exposure to water, professional medical imaging and radiology equipment, and in vitro diagnostic medical devices.

• Spare parts: Manufacturers and importers must ensure that batteries can be purchased as spare parts for at least five years after the last sale of the product model. Replacement must be possible at a reasonable and non-discriminatory cost for both consumers and professionals.

• Collection targets: The collection rate for portable batteries must reach 63% by the end of 2027 and 73% by the end of 2030.

• Labelling: From 2026, batteries must be labelled with information on components and recycled content. From 2027, they must also feature a QR code providing access to further information.

These measures support the EU’s strategy for reducing environmental impact, limiting harmful substances, and promoting increased reuse.

BATTERIES FOR LIGHT MEANS OF TRANSPORT (LMT)

The EU Regulation introduces specific requirements and deadlines for batteries used in light means of transport (LMT batteries), such as those found in e-bikes, e-mopeds, and e-scooters.

Definition:
LMT batteries are batteries specifically designed to provide electric propulsion for light means of transport, such as electric bicycles (e-bikes), electric scooters, electric skateboards, and similar small vehicles intended for one or two people.

Requirements for LMT batteries:

• Performance and durability: Batteries must meet established standards for safety and efficiency.

• Replaceability: From 2027, batteries must be replaceable by qualified professionals without damaging the vehicle.

• Labelling: From 2026, batteries must carry a QR code providing detailed information about the battery’s specifications and proper handling.

Deadlines:

• Replaceability requirement: The requirement for LMT batteries to be replaceable by a qualified professional comes into force in 2027.

• Labelling requirement: From 2026, batteries must be labelled with the necessary information, including a QR code.

• Collection targets: Collection targets for end-of-life LMT batteries are set at 51% by the end of 2028 and 61% by the end of 2031.

• Recycling requirements: From 2028, there will be minimum percentages of recycled materials required in new batteries, promoting the circular economy.

INDUSTRIAL BATTERIES (IND1, IND2)

The EU regulation introduces a series of requirements and deadlines for industrial batteries with the aim of promoting sustainability and safety in the battery sector.

Definition:
An industrial battery is specifically designed for industrial use, to power vehicles in non-road mobile machinery, or for electricity supply in electrical or emergency power systems, energy storage, or use in railway or aviation applications, ships, offshore installations, and other industrial uses.

Performance and durability:
The main requirements and their deadlines are:

• From August 18th, 2024: Rechargeable industrial batteries with a capacity over 2 kWh must be accompanied by documentation specifying values for electrochemical performance and durability parameters as set out in Annex IV, Part A of the regulation.

• From August 18th, 2027, or 18 months after the entry into force of a delegated act (whichever is later): These batteries must meet minimum performance and durability values specified in the delegated act.

Labelling and information:

• From 2026: Industrial batteries must have specific labelling, including a QR code that provides access to detailed information about the battery.

• From 2027: A digital “battery passport” must be available for industrial batteries, containing information about the battery’s composition and characteristics.

Sustainability requirements:

• From February 18th, 2025: Producers must disclose the CO₂ footprint of batteries.

• From December 31st, 2030: The Commission will assess the feasibility of phasing out non-rechargeable portable batteries to minimize environmental impact.

Recycled material content:

• From August 18th, 2031: Industrial batteries must contain minimum recycled material levels: 16% cobalt, 85% lead, 6% lithium, and 6% nickel.

Due diligence:

• From 2025: Companies must implement due diligence processes to identify, prevent, and address social and environmental risks related to the sourcing, processing, and trade of raw materials such as lithium, cobalt, nickel, and natural graphite used in their batteries.

Transitional provisions:

• The previous Battery Directive (Directive 2006/66/EC) remains in effect until August 18th, 2025. The Ministry of Environment has announced that municipal battery collection will continue until 1 January 2026 to ensure a smooth transition to the new rules.

These requirements and deadlines are designed to ensure that industrial batteries are produced, used, and disposed of in an environmentally responsible way and in line with the EU’s sustainability goals.

START, LIGHTING, AND IGNITION BATTERIES (SLI BATTERIES)

EU Regulation introduces a series of requirements and deadlines for start, lighting, and ignition batteries (SLI batteries), primarily used in vehicles and machinery.

Definition:
“SLI battery” means a battery specifically designed to provide power for starting engines, lighting, and ignition systems (passenger cars, trucks, motorcycles, boats, and other combustion-engine vehicles).

Key requirements for SLI batteries:

• Minimum recycled material content: From 18 August 2031, SLI batteries must contain at least 16% recycled cobalt, 85% lead, 6% lithium, and 6% nickel.

• Labelling and information: From 2026, batteries must be labelled with information about their components and recycled content. From 2027, batteries must also include a QR code providing access to additional information.

• Due diligence: Companies marketing SLI batteries must implement due diligence policies to address social and environmental risks in their supply chains.

Deadlines:

• August 18th, 2025: Due diligence policies become mandatory.

• August 18th, 2028: Minimum recycled material content requirement takes effect.

• 2026: Labelling requirements take effect.

• 2027: Requirement for QR codes on batteries takes effect.

By complying with these requirements and deadlines, manufacturers and importers of SLI batteries contribute to a more sustainable battery industry within the EU.

ELECTRIC VEHICLES (EV BATTERIES)
EU Regulation introduces comprehensive requirements and deadlines for batteries, including those for electric vehicles (EV batteries). The regulation, which came into force on August 17, 2023, aims to regulate the entire lifecycle of batteries to promote sustainability and circularity.

Definition:
“Battery for electric vehicles (EV battery)” means a battery specifically designed to provide propulsion to hybrid-electric or fully electric vehicles covered by Regulation (EU) 2018/858 (passenger cars and light commercial vehicles) or Regulation (EU) 167/2013 (tractors) and 168/2013 (two- and three-wheeled vehicles).

Requirements and Deadlines for EV Batteries:

• Labeling and Information Obligations: From 2026, EV batteries must be equipped with a digital battery passport containing detailed information about the battery’s composition and origin.

• CO₂ Footprint: From 2025, manufacturers must provide the CO₂ footprint for EV batteries, which aims to help reduce the environmental impact of battery production.

• Recycled Material Content: From 2028, EV batteries must contain minimum percentages of recycled materials to promote a circular economy and reduce the need for new raw materials.

• Collection Targets: The regulation sets targets for collecting used batteries to ensure proper recycling and waste management.

• Recycling Efficiency: Targets have been set for the efficiency of recycling materials such as cobalt, copper, lead, and nickel from used batteries.

• Restriction of Hazardous Substances: From February 18th, 2024, restrictions on the use of certain hazardous substances in batteries have been introduced to protect the environment and human health.

• Safety, Performance, and Durability Requirements: From August 18th, 2024, EV batteries must meet specific safety, performance, and durability requirements to ensure reliability and long service life.

• CE Marking and Declaration of Conformity: From August 18th, 2024, EV batteries must be CE marked, and manufacturers must issue an EU declaration of conformity confirming that the products comply with applicable requirements.

These requirements and deadlines are part of the EU’s efforts to ensure sustainable and responsible battery production and management throughout the battery’s lifecycle.

Reporting is crucial to ensure the effective management and recycling of batteries.

The purpose is to ensure proper organization and financing of the collection and recycling of spent batteries.

Before your company can report its marketed quantities, you must be registered in the national producer responsibility register. This registration is managed by Dansk Producentansvar (DPA).

Reporting is crucial to ensure the effective management and recycling of batteries.

The purpose is to ensure proper organization and financing of the collection and recycling of spent batteries.

Before your company can report its marketed quantities, you must be registered in the national producer responsibility register. This registration is managed by Dansk Producentansvar (DPA).

Once your company is registered with DPA, you must annually report the quantity of batteries your company has placed on the Danish market.

The reporting must be specified according to battery types and categories as defined in the regulation.

These categories include, among others:

• Portable batteries: Batteries under 5 kg that are not industrial batteries.
• Batteries for light means of transport (LMT): Batteries that power vehicles such as e-bikes and electric scooters.
• Industrial batteries: Batteries designed for industrial purposes or those that do not fall under other categories.
• Starter batteries: Batteries used to start combustion engines in vehicles.
• Electric vehicle batteries: Batteries that provide propulsion for electric vehicles, such as hybrid and electric cars.

Producers, importers, and distributors subject to producer responsibility for batteries must continuously report:

• Quantities (in kilograms)
• Type (battery category and chemistry)
• Batteries placed on the market (sold quantities) – this also includes online sales.
• Collected used batteries (returned/collected)
• Recycled materials (for some types, e.g., lithium, cobalt, nickel) – this task is managed by Batteriretur as your company’s collective scheme.

Additionally, batteries must be categorized according to their dominant battery chemistry:

• Lead-acid
• Nickel-cadmium
• Nickel-metal hydride
• Alkaline and zinc-carbon
• Lithium
• Others

Reporting is done through Batteriretur’s systems, which guides you through the process step by step.

If a battery does not have a clearly dominant battery chemistry, it is categorised in the chemistry category with the most relevant design criteria.

This is done through a series of financial obligations:

Financing of Waste Management

Producers must cover all costs associated with:

• Collection of spent batteries from end-users and collection points
• Transport, treatment, and recycling
• Environmentally sound disposal of non-recyclable parts

This applies to portable, industrial, SLI, and electric vehicle batteries alike.

Administration Fees

Fees may be charged for:

• Producer responsibility organisations or return systems that companies choose to join.

The rationale behind eco-modulated fees is that the more environmentally friendly a battery is, the lower the fees can be. The idea is to create an economic incentive for those who can influence the battery’s design.

The purpose is to promote the design and production of more sustainable batteries and support the principles of extended producer responsibility.

Eco-modulated fees must be set and managed by the producer responsibility schemes and may vary from country to country depending on the national implementation of EU regulations.

The eco-modulated fees (expected to be adopted by August 2025 via regulation) are based on:

• Recycled content
• Rechargeability
• Remanufacturing

Recycled Content
The design requirement for recycled content applies to the metals cobalt, lithium, and nickel. The share is calculated as a percentage of the active material in the battery. The recycled material can come either from production waste or consumer waste.

For lead, the requirement applies as a percentage of the total lead content in the battery, recycled from waste.

If a battery does not contain cobalt, lithium, or nickel as part of the active material, the recycled content requirement does not apply. The same applies to lead—if the battery does not contain lead, there is no requirement for recycled lead.

Minimum criteria for recycled content:

Rechargeability
A rechargeable battery is a battery designed to be charged with electricity. The battery is evaluated according to the criteria set for its grading category.

Remanufactured
A battery is considered remanufactured if it undergoes technical processes including disassembly and assessment of all its cells and modules.

In this process, a combination of new, used, or recovered cells and components is used to restore the battery’s capacity to at least 90% of the original nominal capacity.

At the same time, the capacity difference between individual cells must not exceed 3%. The remanufactured battery must be used for the same purpose as it was originally designed for.

Note: If a design criterion cannot be documented, the battery does not meet that criterion.

Below is an overview of the key dates and implementation steps.

Timelines and deadlines

Deadline for Registration with New Battery Categories
Companies must update their registrations to include the new battery categories by the end of 2025. This is because the first reporting requirements for the calendar year 2025 come into effect then.

Registration deadline:
2024 – until the end of 2025: Companies must update their battery registrations to include the new battery categories.

Reporting deadline:
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 be submitted (likely via DPA, though this is not yet finalized). Batteriretur is expected to handle the reporting and upload the data to the relevant authority.

The EU has had a common regulatory framework for batteries since 2006, when the Battery Directive (2006/66/EC) was adopted with the aim of ensuring proper collection and management of used batteries.

The directive established producer responsibility, requiring companies that place batteries on the market also to finance and organize the collection and treatment of batteries once they become waste.

Denmark implemented the Battery Directive into national legislation and introduced producer responsibility for batteries in 2009. This was anchored in the Environmental Protection Act and is currently administered through the national producer register managed by Dansk Producentansvar (DPA).

From 2009, it was Elretur, a sister organization to Batteriretur, that handled producer responsibility for batteries.

However, this changed when the old Battery Directive was replaced by a new, directly applicable EU regulation, Regulation (EU) 2023/1542, which imposes significantly stricter requirements on producers and importers of batteries throughout the EU as of 2023.

The regulation is part of the EU’s ambitions for a European green transition and aims to strengthen the circular economy, reduce the carbon footprint, and ensure responsible resource use throughout the entire battery lifecycle.

The new regulation will enter into force gradually and introduces new requirements regarding documentation, collection, recycling, labelling, the use of recycled materials, and due diligence in supply chains.

At the same time, new battery categories are being introduced along with an expanded producer responsibility that also includes digital battery passports and more detailed reporting obligations.

Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 concerning batteries and waste batteries

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1542

Further legislation (in Danish)

Executive Orders pursuant to the Environmental Protection Act (Bek. LBK 48 af 12/01/2024)

https://www.retsinformation.dk/eli/lta/2024/48

The Battery Executive Order. Executive Order on batteries and accumulators and waste batteries and accumulators (BEK nr 1453 af 07/12/2015)

https://www.retsinformation.dk/eli/lta/2015/1453

Executive Orders on the import and sale of batteries and accumulators (Bek nr 870 af 08/07/2015)

https://www.retsinformation.dk/eli/lta/2015/870

The eco-badge demonstrates that your company takes responsibility and supports sustainable management of batteries in line with EU regulations and the principles of the circular economy.

The label can be used in your company’s communication towards customers, partners, and employees.

The battery label becomes available once your company transitions to full membership, including both reporting and payment according to the new regulations.

The digital label is supported by Retur’s partner, BeCause.

The Extended Producer Responsibility for batteries follows the battery waste.

This means that if your batteries are marketed in other countries and contain batteries that end up as waste there, you also have producer responsibility in the respective country.

You must therefore comply with the national rules on producer responsibility for batteries in every country in which you operate.

Although producer responsibility is based on EU legislation, the requirements and systems for collection and reporting can vary significantly from country to country — including deadlines, fee structures, and registration criteria.

As part of our international network and in collaboration with Pronexa, Nordic PRO Solutions, and other collective schemes worldwide, we can assist you further and connect you with the right international partners.

Write to retur@retur.dk for more information about Pronexa.
Write to nordic@retur.dk for more information about Nordic PRO Solutions.

As a PRO, we act on behalf of our members – companies operating on the Danish market – and the primary tasks we typically perform at Batteriretur are:

COLLECTION AND HANDLING OF WASTE

As a PRO, Batteriretur organizes and finances the collection of batteries covered by producer responsibility when they reach the end of their lifecycle, on behalf of the companies that are members with us.

Specifically, we collect batteries from recycling centers, businesses, and take over waste sorted by Danish households.

As part of this task, we purchase and install collection equipment throughout Denmark.

We also negotiate and enter into agreements with municipalities and private waste management companies regarding the collection and handling of used batteries.

RECYCLING AND ENVIRONMENTALLY SOUND DISPOSAL

As a PRO, we ensure that batteries are treated in an environmentally responsible manner.

This includes collection, sorting, recycling of materials, and proper disposal of hazardous substances. The goal is to maximize recycling and minimize environmental impact as much as possible.

REPORTING AND DOCUMENTATION

PROs must maintain detailed records of quantities of collected, recycled, and disposed waste.

It is our responsibility to quality-assure and report this data to authorities to document legal compliance and ensure transparency.

Furthermore, we monitor waste streams, ensure that treatment processes are transparent, and that member companies fulfill their obligations under producer responsibility legislation. This may include inspections and audits at treatment facilities with our partners.

We also provide our members with data on collected and treated quantities as well as CO₂ figures, and we develop IT systems to help ease the reporting burden for our members.

FINANCING

When a company is subject to producer responsibility, it is obliged to pay the costs that municipalities may incur to collect, transport, treat, and manage the company’s products once they become waste.

Fees are typically based on the quantity and type of products each producer markets.

As a PRO, we collect fees from our member companies, provide guarantees, and ensure payments to actors and partners.

Batteriretur’s PROs operate on a non-profit basis.

INFORMATION AND COMMUNICATION

An important part of the producer responsibility is to inform both producers and consumers about their roles and responsibilities.

As a PRO, we conduct awareness campaigns, provide information on correct disposal methods, and collaborate with other stakeholders to promote proper waste management.

We can also provide data to our members. See more under Reporting and Documentation.

ADVICE AND GUIDANCE

New laws and updates to existing producer responsibility laws are being introduced continuously.

As a PRO, we ensure that our members stay up to date on the latest rules and developments.

We also represent our members in negotiation committees and by submitting consultations to authorities.

INNOVATION AND DEVELOPMENT

We also see great value in contributing to the circular economy.

As a PRO, we work to promote innovation in waste management and recycling.

This can include research into new technologies and methods to improve recycling rates and reduce environmental impact.

For example, Batteriretur’s sister organisation, Elretur, has recently established electronic recycling facilities in Denmark that will significantly increase the volume of recycled electronics in the coming years.

WHY CHOOSE A PRODUCER RESPONSIBILITY ORGANISATION?

Producer responsibility involves many practical, legal, and financial tasks.

Collection and handling of waste, sorting, reuse, recycling, environmentally sound disposal, reporting, monitoring, awareness-raising, and innovation are all elements that are time-consuming and costly for a single company to manage alone.

By handling these tasks collectively for our member companies, we relieve a significant administrative burden from your shoulders, create economies of scale, and as one of the most cost-effective and experienced PROs in Europe, we also ensure you get the most value and impact for your money.

RETUR HELPS YOUR COMPANY MANAGE MULTIPLE PRODUCER RESPONSIBILITIES IN ONE PLACE

Retur is Denmark’s largest family of PROs, with the oldest having operated producer responsibility organisations for nearly 20 years.

We help Danish businesses fulfill their producer responsibility for batteries, electronics, packaging, fishing gear, and in the future also textiles.

Whether you have one or several producer responsibilities, your company can have them all managed in one place – with us at Retur – as your partner in producer responsibility.

Batteriretur is owned by our members – companies operating on the Danish market.

We are built on member democracy, influence, and co-determination.

Naturally, we place great value on the engagement and participation of our members, and we work closely with member representatives through our sector management groups.

These sector management groups play a central role in developing our shared initiatives.

They ensure that important decisions are made in close dialogue with the industry and that our systems and processes are optimised to meet future requirements.

In addition to our sector management groups, Batteriretur also has a board of directors that oversees the strategic development of Batteriretur and collaborates on the overall development of Retur.

End-of-life batteries contain both valuable raw materials and substances that require careful handling.

For this reason, the new EU Battery Regulation and the Danish implementing legislation introduce stricter requirements for how consumers and businesses prevent waste and handle batteries safely and responsibly.

Below are the key points you need to know.

The Consumer’s (End User’s) Role: How to Prevent Waste and Ensure Proper Collection

As an end user, you play a crucial role in ensuring that used batteries are collected and recycled.

Small everyday actions make a big difference. Here are three simple tips for better battery use:

1. Use batteries for longer: Choose rechargeable batteries whenever possible and use batteries fully before replacing them.
2. Do not mix batteries with other waste: Batteries must never be placed in residual waste, plastic, cardboard, or other household containers. They must always be taken to a collection system specifically designed for batteries.
3. Hand in batteries regularly: Avoid allowing batteries to accumulate at home or in the workplace. Deliver them regularly to minimise fire risks, ensure correct recycling, and return valuable resources to the circular economy as quickly as possible.

Collection and Recycling Schemes

In Denmark, it is straightforward to dispose of batteries safely and correctly:

• Recycling centres: All types of batteries can be delivered here – from small household batteries to larger lithium batteries.
• Kerbside or municipal waste services: In many municipalities, small batteries can be placed in designated containers such as boxes, battery stands, hazardous waste cabinets, or special bags collected alongside household waste (but never in the residual waste bin).
• Businesses: Must use approved collectors and treatment operators, often arranged through their producer responsibility organisation, such as Batteriretur.
• Check your local authority’s arrangements: Schemes differ between municipalities. Visit your local authority’s website to see how battery collection is handled in your area.

Safe Handling of Used Batteries

All batteries can pose a fire risk if damaged or handled incorrectly, and lithium batteries in particular require extra care.

Follow these guidelines:

• Cover the terminals: Place tape over exposed metal terminals.
• Deliver damaged batteries immediately: If a battery is swollen, leaking, hot to the touch, or has a chemical smell, take it to the recycling centre straight away and notify the staff.
• Store in a cool, dry place: Avoid storing batteries in direct sunlight or near heat sources.
• Keep batteries separate: Do not store loose batteries together with metal objects, as this can lead to short-circuiting and potentially cause a fire.
• Do not crush or break batteries: Never attempt to open, puncture, or otherwise damage a battery.

The Importance of Labelling and Symbols

Labelling is a key part of the new regulation, both for safety and to ensure that batteries can be sorted and recycled correctly.

• The crossed-out wheeled bin symbol: Indicates that the battery must not be disposed of with household waste.
• Chemical symbols (e.g., Pb, Hg, Cd): Show whether the battery contains substances requiring special treatment.
• QR codes: New EU requirements mean that more batteries will include QR codes with information about composition, capacity, and safety instructions.
• Producer identification: Enables producer responsibility organisations to identify the manufacturer and allocate responsibility correctly.
• Product-specific information: If you require information about a particular battery, visit the manufacturer’s website. You can find a list of Batteriretur’s member companies here.

Environmental and Health Impacts of Incorrect Disposal

Incorrect disposal of batteries can have serious consequences:

• Fire and explosion risks: Especially from lithium batteries placed in residual waste or waste collection vehicles.
• Pollution: Batteries contain metals such as lithium, cobalt, nickel, and lead. If disposed of incorrectly, they can contaminate soil and groundwater.
• Loss of valuable resources: Batteries contain materials that Europe largely imports. If batteries are not collected, these resources are lost, and the environmental footprint increases.
• Risks to health and safety: Waste workers may be put at risk if batteries are hidden in bags or containers not designed for them.

Summary: Return Your Used Batteries – A Small Action with a Big Impact

By sorting and delivering batteries correctly, you help to:

• reduce the risk of fires,
• protect the environment and groundwater,
• ensure that valuable materials can be recycled,
• support the circular economy in Denmark and across the EU.

It’s a small action, but the impact is considerable.