Italy battery registration for non-EU sellers (Registro pile)

A business outside Italy that sells batteries, loose or built into a product, straight to buyers in Italy is the producer there, and Italian law makes it appoint a representative in Italy by written mandate (art. 25(4) D.Lgs. 29/2026). The representative registers you at the chamber of commerce for its own seat (Allegato I, Part A). The register’s own pages still cite D.Lgs. 188/2008. D.Lgs. 29/2026 took its place on 7 March 2026 and repealed it, but the register articles of the old law apply until the new register is fully implemented (art. 37(1)(d)). This page lists only what Italy adds to the EU Battery Regulation, which says when you are the producer and what the rest of the Regulation requires. The other Italian rules are in selling to Italy as a non-EU seller.

The register moved to a new law

D.Lgs. 29/2026 was published in the Gazzetta Ufficiale of 6 March 2026 and entered into force the next day (GU n. 54, art. 39). It carries out Regulation (EU) 2023/1542Regulation (EU) 2023/1542, Batteries RegulationThe whole regulationClick opens the law on the EU Publications Office. in Italy (art. 1) and repeals D.Lgs. 188/2008, except its art. 29, keeping its register articles (14, 15(2)-(3), 27(4)-(5) and Annex III) until the new register is fully implemented (art. 37(1)). It creates the Registro dei produttori di batterie, a sector register inside the national register of producers (RENAP), and says it replaces the register of the old law (art. 20(1)).

The old register stays active until the new one is fully implemented (art. 35(4)). RENAP’s notice of 13 March 2026 says the opening will be announced on RENAP and on the ministry’s site, and that every producer, those already registered included, then files within 60 days (RENAP, art. 20(10)). The RENAP news list, read on 6 October 2026 with its newest item dated 2 October, holds no such announcement (RENAP news). Its battery page still offers the old desk for a new registration, a change or a cancellation (RENAP, Registro Pile e Accumulatori). The home page of registropile.it and the ministry’s page, last updated 17 May 2025, still describe the 2008 law (MASE).

Who is the producer, and who represents you

Italy applies the definitions of the Regulation (art. 2(1)). A business that sells batteries, built-in ones included, by distance contract directly to end users in Italy, households or not, while established in another EU country or outside the EU, is a producer (Art. 3(47)(d)). Italy then states the consequence in its own text: that producer must designate an authorised representative for extended producer responsibility, by written mandate (art. 25(4), Art. 56(3)). The representative is established in Italy (Art. 3(48)).

The representative files for you at the chamber of commerce for its own seat (Allegato I, Part A, point 1). A representative that acts for several producers gives each producer’s name and contact details separately (art. 20(12)). The two representative roles of the Regulation, and the EU rules on the role, are in the EPR authorised representative.

What a seller outside Italy does

1. Today: register on the old desk. RENAP’s battery page still offers the old desk, the RENAP scrivania, for a new registration, a change or a cancellation (RENAP, Registro Pile e Accumulatori). The representative files the foreign producer’s application there with its digital signature (manual, chapter 8), with the data of Annex III of D.Lgs. 188/2008: the producer’s name and addresses, the battery types, whether it complies individually or collectively, and its tax or identification code (manual, section 2.6.4). The desk asks for the VAT number of a company in an EU state and for another identification code for a company in any other country (manual, section 8.1). Once the opening of registration in the new register is announced, you file again within 60 days (art. 20(10)); steps 4 and 6 below are that new-register procedure.
2. Sign a mandate with a representative in Italy. Written, one for the extended producer responsibility role (art. 25(4)).
3. Join a collective system. Portable batteries and batteries for light means of transport cannot be handled by an individual system (art. 26(1)). The Centro di Coordinamento Batterie lists 13 collective systems and one individual system among its members: APIRAEE, COBAT RIPA, CONSIBAT, ECOEM, ECOPED, ECO POWER, European Recycling Platform, Consorzio RLG, ECOLIGHT, ECO-PV BATTERY, ERION ENERGY, PV CYCLE ITALIA and SINAB, and NGK Italy as the individual system (CDC Batterie). Its page does not say which battery categories each system takes.
4. New register: have the representative apply. The application is electronic and carries a digital signature of the representative (Allegato I, Part A, point 2). It states the data of Art. 55(3) of the Regulation and whether you meet the producer duties individually or collectively (art. 20(6)). A foreign producer gives its national identification code in place of an Italian tax code (DM 144/2024 art. 4(5)(a)).
5. Name the collective system in the application. The register accepts a registration that names a collective system only once the membership is confirmed (art. 20(9)). The system can do the registration for you if you delegate it (art. 20(11)).
6. Place no battery on the Italian market before you are registered (art. 20(9)). New register: the authority authorises the registration within 60 days of the moment all the information is supplied, and the register gives the number within 15 days of that (art. 20(7)). The Regulation caps the whole wait at 12 weeks (Art. 55(9)(b)).
7. Use the number. It goes on all transport documents and commercial invoices within 30 days of its issue (art. 20(7)). A distance seller also shows it on its website and gives it to the platform it sells through (art. 20(7), DM 144/2024 art. 4(9)).
8. Report the quantities each 31 March. The batteries placed on the market in the previous calendar year, by category and chemistry (art. 21(3), Allegato I, Part C).
9. Notify changes within one month. A change in the registered data, or the end of the activity (Allegato I, Part A, point 4).

A producer registered under the old law files again. When the opening of the new register is announced, it presents its application within 60 days (art. 20(10)). Subjects of an EPR regime set up before 7 March 2026 had 180 days from that date to conform to the EPR rules of the decree, which ended on 3 September 2026 (art. 35(6)).

The guarantee

A producer gives a financial guarantee when it places a battery on the market. The individual producer gives it, or the collective system the producer belongs to. It covers the waste-management costs if the producer fails its duties, stops its activity or becomes insolvent (art. 29(1)-(3)). A decree was due by 7 September 2026 to set how the guarantee works (art. 29(2)); whether it was adopted is not checked. No amount is stated in the law.

What it costs

The old-register amounts come from the register’s producers manual, version 4.1 of January 2020, and its FAQ, both written under the 2008 law (registropile.it FAQ). They are the amounts for a registration made on the old desk. For the new register the law leaves the tariff to the chambers, to be updated every three years (DM 144/2024 art. 6(5)).

Selling through a marketplace

A producer that places batteries on the Italian market through an online platform may use the services the platform operator must offer under agreements with the schemes: membership, data collection and the contribution (art. 178-quater(1), (3) D.Lgs. 152/2006). The battery decree lets you use that route where it has been activated (art. 20(5)). No text read shows an agreement in force for batteries, so the registration stays yours.

The platform must obtain your register details and number, and your self-certification that you meet the producer duties (Art. 62(6)); the EU guide sets out that duty. Italy fines a platform that allows a sale in breach of it EUR 650 to 2,500, where the platform falls within Chapter III, section 4 of Regulation (EU) 2022/2065, the rules for platforms that let consumers conclude distance contracts with traders; micro and small enterprises are outside it (DSA Art. 29, art. 34(7)). Where the register is not public, the competent authority gives platforms access to it by interoperability and an operating agreement with the operator of the national register system (art. 20(20)).

Equipment with a battery inside

A battery built into equipment is a battery you place on the market, and the registration duty covers it (art. 20(4)). The equipment itself is registered in a separate sector register, and the battery register is another one. Both sit inside RENAP (DM 144/2024 art. 3). The equipment side is in WEEE in Italy.

What happens if you do nothing

You may not place batteries on the Italian market (art. 20(9)), and a marketplace must obtain your registration number before you offer batteries to consumers (Art. 62(6)). The fines are in art. 34. They apply where the act is not a crime.

The register’s FAQ still shows EUR 30,000 to 100,000 for not registering and EUR 2,000 to 20,000 for the annual communication (registropile.it FAQ). Those are the figures of art. 25 of D.Lgs. 188/2008, which art. 37 does not keep. Whether you count as a distributor, and what the take-back duty asks of a distance seller, is in the EU guide.

The fines of art. 34(3), (5), (6) and (8) are found and imposed under arts. 262 and 263 of D.Lgs. 152/2006 (art. 34(9)). Art. 262(1) gives the power to the province where the violation was committed. The fines of art. 34(1), (2) and (4) are imposed by the market-surveillance authority, the environment ministry, and by the customs agency and the Guardia di finanza at the border (art. 34(10), art. 3(2), (4)). A supervisory committee inspects producers at random, with ISPRA, and may use the Guardia di finanza and the Carabinieri forestry, environmental and agri-food command (art. 21(1)). Art. 34 names no authority for the platform fine in paragraph 7.

Language

No article on registration names a language for the application or the mandate. The register’s pages and its producers manual are in Italian, and registropile.it/en shows the same Italian page. The EU declaration of conformity of a battery supplied in Italy is translated into Italian (art. 13). The market-surveillance authority can ask the manufacturer’s authorised representative for a copy of its mandate, in Italian. That is the product role of Art. 40(3) of the Regulation, not the extended-producer-responsibility role above (art. 14(1)).