France battery EPR for non-EU sellers (filière BAT)

Since 18 August 2025, France runs batteries as one EPR stream (filière BAT) for all five battery categories. A seller outside France that sells batteries, loose or built into a product, to buyers in France is the producer. It names a representative established in France by written mandate, joins an approved eco-organisme or runs an approved individual system, and holds an IDU for the batteries scheme. This page lists only what France adds to the EU Battery Regulation, which says when you are the producer and what the rest of the Regulation requires. The other French rules are on the France page.

Two names in older material are gone. Corepile merged into ecosystem on 31 July 2025, and Screlec is now called Batribox (ecosystem and ADEME).

France adds a representative, a scheme and an IDU to the EU registration

The EU rule makes a seller that ships to end users in a country where it is not established the producer there, and has it appoint an authorised representative for extended producer responsibility in each country by written mandate (Regulation 2023/1542, Art. 3(47)(d) and Art. 56(3)). France’s Code de l’environnement R. 543-124 takes that definition of producer as its own and adds any economic operator that is first to make available in France a battery that was prepared for re-use or repurposing, repurposed or remanufactured. ADEME describes the producers concerned as everyone placing batteries on the market in France, in a shop or online, and the batteries concerned as every type, built-in ones included (ADEME). Batteries for military and space equipment are outside.

What France sets on top:

• a representative established in France, by written mandate, for every producer not established in France (L. 541-10-9-1);
• membership of an approved eco-organisme, or an approved individual system (Ministry);
• an IDU for the batteries scheme, issued by ADEME (ADEME).

Joining an eco-organisme for electrical equipment does not cover batteries, and Batribox says so in terms (Batribox). Each stream has its own IDU, and a battery inside a phone can put you in the batteries stream, the electrical equipment stream and the packaging stream at once (ADEME FAQ).

Do this, in this order

1. Sort each battery into a category. The five are portable (sealed, 5 kg or less), light means of transport (LMT, sealed, 25 kg or less, for the traction of wheeled vehicles), starting-lighting-ignition (SLI), industrial, and electric vehicle. The Ministry publishes a classification note with examples, which it says is not legally binding (Ministry, ADEME).
2. Name your representative in France, by written mandate, unless an operator established in France that is named in L. 541-10-9, such as a marketplace, already meets your producer duties for the product (Sénat). The EU side of the role is in EPR authorised representative. ecosystem requires it of any foreign company that joins, and publishes a list of firms that offer the service for batteries (ecosystem).
3. Join an approved eco-organisme for every category you sell, using the table below, or run an approved individual system. The contract, the scale and the first declaration come from the eco-organisme.
4. Declare what you place on the market. The eco-organisme registers you in SYDEREP and ADEME issues the IDU. What to type with no SIRET, and who asks for the IDU, is on EPR registration number in France.
5. Show the IDU and the costs. The IDU goes in your general conditions of sale and on your website (ADEME). The costs you cover under Article 56(4) of the Regulation are shown at the point of sale of a new battery, without the amount of the modulation (R. 543-126). ecosystem reads this as a duty to display its scale: a printed poster in a shop, and a web link on each product page online (ecosystem).
6. Offer take-back when you deliver to France. See the section below.

Who can take your membership

Source: Ministry for the Ecological Transition, page updated 2 September 2026. ADEME lists the same three organisations and the same dates. The Ministry says a producer must meet the duty either by joining and paying an approved eco-organisme or by setting up an approved individual system. A producer that does neither gets no IDU, so the EUR 30,000 row of the fines table applies, on top of the per-unit fine (L. 541-9-5).

What it costs

The scales are the eco-organismes’ own documents. ecosystem’s scales page labels its batteries scale “Version septembre 2026 rétroactive au 1er janvier 2026” (ecosystem); Batribox’s applies from 1 January 2026. The fee is raised or lowered by environmental criteria: in the 2025 scheme, cylindrical rechargeable NiMH batteries that replace disposable ones get a bonus of 50% of the alkaline fee, and zinc-carbon batteries a penalty of 100% of it (ADEME). No volume is exempt from the IDU (Code de l’environnement L. 541-10-13), so the flat rate and the minimum are how small volumes are priced.

Deadlines

The text of L. 541-10-9-1 is in article 5 of loi no. 2026-602 of 8 July 2026, published in the Journal officiel of 9 July 2026 (Sénat). The time to sign a contract and be registered is the eco-organisme’s own. Join before your first sale in France, because the EU rule bars you from making a battery available in a country before you or your representative is registered there (Regulation 2023/1542, Art. 55(2)).

Taking back waste batteries when you deliver to France

France’s take-back rule defines the distributor as anyone who supplies the product to the end user commercially, by any technique, distance communication included (R. 541-158). For batteries it applies with no sales-area or turnover threshold (R. 541-160 i). It is limited to the type and quantity of product sold, or to the products it replaces (L. 541-10-8).

For a sale with delivery, R. 541-161 I gives these ways to meet the duty (R. 541-161):

• take the waste battery back at the delivery point;
• a local collection point the distributor finances and organises, only for waste products that can be carried without equipment;
• a free return solution for the holder, such as a postal service, only when the characteristics of the waste product allow it;
• the holder sends the waste battery straight to a waste operator that has a contract with an approved eco-organisme for that category, only when the eco-organisme offers this.

The buyer is told how, visibly and legibly, before the sale is concluded (R. 541-163). The producers or their eco-organisme supply containers free of charge (R. 541-165). The EU version of the duty for distance sellers is Article 62(4) and (5). The articles apply to a distributor “y compris en cas de vente à distance” (R. 541-166), and they set no exception for a seller that ships from abroad.

A marketplace becomes the producer if you hold no IDU

A marketplace that facilitates distance sales for a third party must provide for or contribute to the management of the waste, unless it holds proof that the third party has already met its obligations. An IDU issued for the products counts as that proof (L. 541-10-9). ADEME puts it this way: the marketplace is the producer for the quantities it places on the market for third parties, unless those parties hold an IDU for the scheme (ADEME). So the marketplace asks you for the IDU of the batteries scheme. The law does not let a marketplace file for you. By contract it can: a marketplace may offer an EPR intermediary service, taking over your EPR duties and reporting for you to the eco-organismes, on terms it sets itself (draft Ministry FAQ). The EU rule that has a platform collect your registration number and a self-certification is in the EU guide.

Labels and product information France sets

The crossed-out wheeled bin is an EU duty on every battery, covered in the EU guide. On top, a product subject to EPR and sold to households carries a sign that tells the consumer it has sorting rules, and the sign comes with information on how to sort it (L. 541-9-3). The sign is the Triman logo or other common signage that EU or member-state law makes compulsory (Service-Public). The EU makes the crossed-out bin compulsory on a battery (Regulation 2023/1542, Art. 13(4)), so the bin can replace the Triman logo. The sorting instruction is still required. ecosystem’s Info-tri carries it, and its Info-tri includes either the bin or the Triman logo (ecosystem). The Triman rule is on Triman logo in France.

A producer, importer or other business putting products on the market that declares more than EUR 10 million of turnover across all the products listed in R. 541-228 and puts at least 10,000 units of those products a year on the French market also states on batteries their recycled content, their recyclability and any hazardous substance above 0.1% (Service-Public). The turnover and unit thresholds are in R. 541-227 and the product list in R. 541-228 (copy in Ineris AIDA; décret no. 2022-748 numbered them R. 541-220 and R. 541-221). The general duty to inform consumers of a product’s environmental qualities is in L. 541-9-1, and missing that information costs up to EUR 3,000 for an individual and EUR 15,000 for a company (L. 541-9-4-1).

If you do nothing

The minister notifies you of the facts and the penalty you face, you have one month to answer in writing or orally, and the minister then decides (L. 541-9-5). How the penalty is set for an unregistered producer, and what a missing IDU costs in general, is on the IDU page.

Where the breach is failing the EPR duty itself, the per-unit and per-tonne amount is worked out from the average annual quantity you are estimated to place on the market, set against how long the breach lasted and the highest unit contribution of the approved eco-organismes of the stream (L. 541-9-5). The same fifth class covers a manufacturer, cell or module supplier, importer, distributor, authorised representative, fulfilment service provider or second-life operator that breaks the product duties of Articles 38 to 45 of the Regulation (R. 543-129). If you do nothing, a marketplace that holds no proof of your IDU is the producer for your quantities.

What does not apply

• There is no single French EPR number. The batteries scheme has its own IDU.
• You do not register in SYDEREP yourself when you join an eco-organisme. The eco-organisme does it.
• No volume is exempt from the IDU. Low volumes pay the minimum of the eco-organisme, or its flat rate where it has one.
• A battery seller with only a WEEE membership is not covered for batteries.
• Corepile and Screlec are no longer approved under those names.