EU Battery Regulation: what you must do to sell batteries, or products with batteries, in the EU

A Bluetooth speaker, an electric toothbrush and a phone case with a power bank all put you under the Batteries Regulation (Art. 1(3)Regulation (EU) 2023/1542, Batteries RegulationArticle 1, paragraph 3Click opens the article on EUR-Lex.). The part that reaches online sellers first is registration, and a marketplace asks for its number.

What applies now, and what waits

The Regulation “shall apply from 18 February 2024”, except where it sets its own dates: Art. 11Regulation (EU) 2023/1542, Batteries RegulationArticle 11Click opens the article on EUR-Lex. from 18 February 2027, Art. 17Regulation (EU) 2023/1542, Batteries RegulationArticle 17Click opens the article on EUR-Lex. and Chapter VI (the duties of manufacturers, importers and distributors) from 18 August 2024, and Chapter VIII (registration, extended producer responsibility, collection) from 18 August 2025 (Art. 96(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 96, paragraph 2Click opens the article on EUR-Lex.). The due diligence date was 18 August 2025 in the original text; Regulation (EU) 2025/1561 replaced it with 18 August 2027. Regulation (EU) 2026/1738 rewrote Annex I, the list of restricted substances: the limits for portable batteries (mercury 0.0005%, cadmium 0.002%, lead 0.01% since 18 August 2024) stay as they were, and new limits were added for batteries in cars and vans.

Who the producer is when you sell at a distance

The producer carries registration, take-back and the fees. The Regulation names four cases, and each one covers batteries “including those incorporated in appliances, light means of transport or other vehicles” (Art. 3(47)Regulation (EU) 2023/1542, Batteries RegulationArticle 3, point 47Click opens the article on EUR-Lex.):

The last row is the online seller’s case. It covers a web shop and a marketplace listing alike, because the definition applies “irrespective of the selling technique used”. It covers business buyers too: the end users can be private households or not. A business outside the EU that ships straight to EU customers is the producer in every EU country it ships to. A business in Germany that ships to buyers in France is the producer in France. It is the producer in Germany as well only where one of the first three rows fits it there: it supplies batteries under its own name or trademark, or it is the first to supply them in Germany, on a professional basis, from another country (Art. 3(47)(a)Regulation (EU) 2023/1542, Batteries RegulationArticle 3, point 47, point (a)Click opens the article on EUR-Lex., Art. 3(47)(b)Regulation (EU) 2023/1542, Batteries RegulationArticle 3, point 47, point (b)Click opens the article on EUR-Lex., Art. 3(47)(c)Regulation (EU) 2023/1542, Batteries RegulationArticle 3, point 47, point (c)Click opens the article on EUR-Lex.).

Where you sell to a business in another EU country that resells, you are not the producer there: the buyer, which supplies the batteries there for the first time, is (Art. 3(47)(c)Regulation (EU) 2023/1542, Batteries RegulationArticle 3, point 47, point (c)Click opens the article on EUR-Lex.). Any distributor must confirm, before it sells a battery, that the producer is registered (Art. 42(2)(a)Regulation (EU) 2023/1542, Batteries RegulationArticle 42, paragraph 2, point (a)Click opens the article on EUR-Lex.), which is why business buyers ask for your number.

Where to register, and when you need a representative in each country

Each EU country keeps its own register of producers. You apply “in each Member State where they make a battery available on the market for the first time”, through that country’s electronic system, and a producer may make batteries available in a country only if it, or its authorised representative for extended producer responsibility, is registered there (Art. 55(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 55, paragraph 2Click opens the article on EUR-Lex.). The authority grants the registration and a number within 12 weeks of a complete application (Art. 55(9)Regulation (EU) 2023/1542, Batteries RegulationArticle 55, paragraph 9Click opens the article on EUR-Lex.), and it may charge a cost-based fee (Art. 55(10)Regulation (EU) 2023/1542, Batteries RegulationArticle 55, paragraph 10Click opens the article on EUR-Lex.).

If you are the producer because you sell at a distance into a country, the representative is not optional: you “shall appoint an authorised representative for extended producer responsibility in each Member State” in which you sell batteries, by written mandate (Art. 56(3)Regulation (EU) 2023/1542, Batteries RegulationArticle 56, paragraph 3Click opens the article on EUR-Lex.). That representative is established in the country where you sell, not in yours (Art. 3(48)Regulation (EU) 2023/1542, Batteries RegulationArticle 3, point 48Click opens the article on EUR-Lex.), and it carries out your duties under the waste chapter of the Regulation there. Registration, the fees and the reports to the authority run through it. How the fee is set, and whether a producer responsibility organisation is compulsory, each EU country decides (Art. 57(1)Regulation (EU) 2023/1542, Batteries RegulationArticle 57, paragraph 1Click opens the article on EUR-Lex.). The same registration model applies to packaging: PPWR sets it out for packaging producers, and EPR in the EU covers it across the four streams. In Germany the register is stiftung ear’s: BattG battery registration in Germany. In France the stream is run through ADEME’s SYDEREP: France battery EPR. In Italy the register is run through the chambers of commerce: Italy battery registration. In Spain the register is the Ministry of Industry’s RII-PYA: Spain battery registration for non-EU sellers. The United Kingdom, outside the EU, has its own rules: UK battery regulations.

What the battery must carry, and from when

Four markings apply today. The crossed-out wheeled bin has been required on every battery since 18 August 2025. Cd or Pb beneath it applies now too, where the battery holds cadmium or lead above the thresholds. Its sizes and thresholds are under battery labelling requirements below. The same bin on electrical equipment is set by the WEEE Directive; see the WEEE symbol guide.

The CE marking goes on the battery before it is placed on the market, or on the packaging and accompanying documents where the battery cannot take it (Art. 20(1)Regulation (EU) 2023/1542, Batteries RegulationArticle 20, paragraph 1Click opens the article on EUR-Lex., Art. 20(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 20, paragraph 2Click opens the article on EUR-Lex.). The manufacturer affixes it after the conformity assessment and the EU declaration of conformity, and has done since 18 August 2024 (Art. 38(3)Regulation (EU) 2023/1542, Batteries RegulationArticle 38, paragraph 3Click opens the article on EUR-Lex.). The manufacturer’s name, registered trade name or trade mark, postal address, and web and email address if it has them, go on the battery (Art. 38(7)Regulation (EU) 2023/1542, Batteries RegulationArticle 38, paragraph 7Click opens the article on EUR-Lex.), with a model identification and a batch or serial number (Art. 38(6)Regulation (EU) 2023/1542, Batteries RegulationArticle 38, paragraph 6Click opens the article on EUR-Lex.). An importer adds its own name and postal address (Art. 41(3)Regulation (EU) 2023/1542, Batteries RegulationArticle 41, paragraph 3Click opens the article on EUR-Lex.). Where the battery is too small, all of this goes on the packaging or a document with it.

From 18 February 2027 every battery also carries a QR code. What it opens, and the labels not yet due, are under battery labelling requirements below.

If you import, you do not draw up the declaration, but you check that it and the technical documentation exist and that the CE marking is on (Art. 41(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 41, paragraph 2Click opens the article on EUR-Lex.). A distributor also checks the producer’s registration (Art. 42(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 42, paragraph 2Click opens the article on EUR-Lex.). Who checks the label at each step of the chain is under battery labelling requirements below. The product the battery sits in has its own label duties under GPSR: GPSR labelling requirements.

Battery labelling requirements under Article 13 bind in three steps

Article 13Regulation (EU) 2023/1542, Batteries RegulationArticle 13Click opens the article on EUR-Lex. of the Batteries Regulation sets six battery labelling requirements, and they do not start together. The bin and the metal letters bind now, the QR code binds from 18 February 2027, and the three information labels wait for a Commission act that has not been adopted.

The bin and the metal letters. The bin is the symbol shown in Part B of Annex VI. It covers at least 3% of the area of the largest side of the battery, up to 5 × 5 cm. On a cylindrical cell it covers at least 1.5% of the surface area, also up to 5 × 5 cm. If the symbol would come out smaller than 0.47 × 0.47 cm, the battery goes without it and a symbol of at least 1 × 1 cm is printed on the packaging (Art. 13(4)Regulation (EU) 2023/1542, Batteries RegulationArticle 13, paragraph 4Click opens the article on EUR-Lex.). A battery above the cadmium or lead threshold carries the chemical symbol, Cd or Pb, beneath the bin, covering at least a quarter of the bin’s area (Art. 13(5)Regulation (EU) 2023/1542, Batteries RegulationArticle 13, paragraph 5Click opens the article on EUR-Lex.). The article names no symbol for mercury; mercury is limited to 0.0005% in Art. 6Regulation (EU) 2023/1542, Batteries RegulationArticle 6Click opens the article on EUR-Lex., Annex I. How the same bin is drawn and used on electrical equipment is on the WEEE symbol page.

Where the marks go. Labels and the QR code are printed or engraved “visibly, legibly and indelibly on the battery”. Where that is not possible or not warranted because of the nature and size of the battery, they go on the packaging and on the documents that come with it (Art. 13(7)Regulation (EU) 2023/1542, Batteries RegulationArticle 13, paragraph 7Click opens the article on EUR-Lex.).

The QR code from 18 February 2027. It must be in high contrast to its background and big enough for a common QR reader, such as a phone (Annex VI, Part C). What it opens depends on the battery (Art. 13(6)Regulation (EU) 2023/1542, Batteries RegulationArticle 13, paragraph 6Click opens the article on EUR-Lex.):

• E-bike and e-scooter (LMT) batteries, industrial batteries above 2 kWh and electric vehicle batteries: the battery passport.
• Other batteries, which includes portable batteries: the label information that applies by then, the EU declaration of conformity, the annual due diligence report where the maker is in scope of that duty, and the waste information producers owe end users, which includes what the labels and symbols mean (Art. 18Regulation (EU) 2023/1542, Batteries RegulationArticle 18Click opens the article on EUR-Lex., Art. 52(3)Regulation (EU) 2023/1542, Batteries RegulationArticle 52, paragraph 3Click opens the article on EUR-Lex., Art. 74(1)Regulation (EU) 2023/1542, Batteries RegulationArticle 74, paragraph 1Click opens the article on EUR-Lex.).
• SLI (starting, lighting, ignition) batteries: the above, plus the amounts of cobalt, lead, lithium and nickel recovered from waste and present in the active materials.

The information behind the code must be “complete, up-to-date and accurate”. The Commission may add other kinds of smart label, in place of or beside the QR code, by delegated act (Art. 13(8)Regulation (EU) 2023/1542, Batteries RegulationArticle 13, paragraph 8Click opens the article on EUR-Lex.).

The three information labels that wait. The date is “18 August 2026 or 18 months after the date of entry into force of the implementing act”, “whichever is the latest” (Art. 13(1)Regulation (EU) 2023/1542, Batteries RegulationArticle 13, paragraph 1Click opens the article on EUR-Lex.-Art. 13(3)Regulation (EU) 2023/1542, Batteries RegulationArticle 13, paragraph 3Click opens the article on EUR-Lex.). The first date has passed, so the second decides, and it has not started. The Commission had to adopt that implementing act, with harmonised specifications for the three labels, by 18 August 2025 (Art. 13(10)Regulation (EU) 2023/1542, Batteries RegulationArticle 13, paragraph 10Click opens the article on EUR-Lex.). It had not been adopted by 5 October 2026. The Commission’s own page shows a draft, “format and harmonised specifications for certain labelling requirements”, put out on 15 December 2025, with feedback closed on 26 January 2026, and the adoption stage still marked upcoming (Have Your Say). A draft is not law. When the act is in force, the general label must show the manufacturer, the category and identification of the battery, the place and the month and year of manufacture, the weight, the capacity, the chemistry, hazardous substances other than mercury, cadmium or lead, a usable extinguishing agent, and critical raw materials above 0.1% by weight (Annex VI, Part A). A Commission proposal of 10 December 2025 would change the hazardous-substances item to substances of very high concern at 0.1% or more; it is a proposal, not law. The gap this leaves for the capacity label is set out under What the law leaves open.

State of health is data, not a label. The labelling chapter also holds Article 14Regulation (EU) 2023/1542, Batteries RegulationArticle 14Click opens the article on EUR-Lex.. From 18 August 2024, the battery management system of a stationary battery energy storage system, an LMT battery or an electric vehicle battery must hold up-to-date data for the Annex VII parameters of state of health and expected lifetime (Art. 14(1)Regulation (EU) 2023/1542, Batteries RegulationArticle 14, paragraph 1Click opens the article on EUR-Lex.). For an electric vehicle battery that is the state of certified energy; for the other two it is, among others, the remaining capacity and the evolution of self-discharge rates (Annex VII, Part A). Whoever has legally bought the battery, including independent operators and waste management operators, and any third party acting for them, gets read-only access to that data on a non-discriminatory basis, to use the battery in energy storage, to estimate its residual value, or to prepare it for re-use, repurposing or remanufacturing. The system must also have a software reset function (Art. 14(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 14, paragraph 2Click opens the article on EUR-Lex., Art. 14(3)Regulation (EU) 2023/1542, Batteries RegulationArticle 14, paragraph 3Click opens the article on EUR-Lex.). The manufacturer carries this duty (Art. 38(1)Regulation (EU) 2023/1542, Batteries RegulationArticle 38, paragraph 1Click opens the article on EUR-Lex., Art. 38(8)Regulation (EU) 2023/1542, Batteries RegulationArticle 38, paragraph 8Click opens the article on EUR-Lex.). A portable battery in a speaker or a toothbrush is outside it.

Who must see that the label is there.

• The manufacturer ensures the battery is marked and labelled under Article 13Regulation (EU) 2023/1542, Batteries RegulationArticle 13Click opens the article on EUR-Lex. when it places it on the market, and puts on it a model identification, a batch or serial number or another element that identifies it, and its own name and postal address (Art. 38(1)Regulation (EU) 2023/1542, Batteries RegulationArticle 38, paragraph 1Click opens the article on EUR-Lex., Art. 38(6)Regulation (EU) 2023/1542, Batteries RegulationArticle 38, paragraph 6Click opens the article on EUR-Lex., Art. 38(7)Regulation (EU) 2023/1542, Batteries RegulationArticle 38, paragraph 7Click opens the article on EUR-Lex.).
• The importer may place on the market only a battery that complies with Article 13Regulation (EU) 2023/1542, Batteries RegulationArticle 13Click opens the article on EUR-Lex., and checks before it does that the battery is marked and labelled accordingly and the manufacturer has put on its name and address. If it has reason to believe the battery does not comply, it holds the battery back until it does (Art. 41(1)Regulation (EU) 2023/1542, Batteries RegulationArticle 41, paragraph 1Click opens the article on EUR-Lex., Art. 41(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 41, paragraph 2Click opens the article on EUR-Lex.).
• The distributor makes the same two checks before it makes a battery available, and does not sell one it believes is not labelled as required (Art. 42(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 42, paragraph 2Click opens the article on EUR-Lex., Art. 42(3)Regulation (EU) 2023/1542, Batteries RegulationArticle 42, paragraph 3Click opens the article on EUR-Lex.).
• An importer or distributor that sells a battery under its own name or trademark is treated as the manufacturer and carries the manufacturer’s duties, the label included (Art. 44Regulation (EU) 2023/1542, Batteries RegulationArticle 44Click opens the article on EUR-Lex.).
• Whoever refurbishes, repurposes or remanufactures a battery and places it on the market is the manufacturer, and the battery carries new labels or markings, with its change of status reachable through the QR code (Art. 13(9)Regulation (EU) 2023/1542, Batteries RegulationArticle 13, paragraph 9Click opens the article on EUR-Lex., Art. 38(11)Regulation (EU) 2023/1542, Batteries RegulationArticle 38, paragraph 11Click opens the article on EUR-Lex.).

When batteries must be removable and replaceable: 18 February 2027

From 18 February 2027, whoever places on the market a product with a portable battery inside must make sure the end user can remove and replace that battery “at any time during the lifetime of the product” (Art. 11(1)Regulation (EU) 2023/1542, Batteries RegulationArticle 11, paragraph 1Click opens the article on EUR-Lex., Art. 96(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 96, paragraph 2Click opens the article on EUR-Lex.). That is you if you make the product, have it made under your brand, or import it. In practice:

• Ordinary tools only. The battery counts as readily removable when commercially available tools do the job. A specialised tool is allowed only if it comes free with the product; proprietary tools, heat and solvents are not (Art. 11(1)Regulation (EU) 2023/1542, Batteries RegulationArticle 11, paragraph 1Click opens the article on EUR-Lex.).
• Instructions in the box and online. The product comes with instructions and safety information on using, removing and replacing the battery, and the same stays permanently on a public website (Art. 11(1)Regulation (EU) 2023/1542, Batteries RegulationArticle 11, paragraph 1Click opens the article on EUR-Lex.).
• Spare batteries for five years. The battery is sold as a spare part for at least five years after the last unit of the model is placed on the market, at a reasonable, non-discriminatory price (Art. 11(7)Regulation (EU) 2023/1542, Batteries RegulationArticle 11, paragraph 7Click opens the article on EUR-Lex.).
• No software lock. Software may not be used to block a compatible replacement battery (Art. 11(8)Regulation (EU) 2023/1542, Batteries RegulationArticle 11, paragraph 8Click opens the article on EUR-Lex.).

Two groups may instead have a battery that only an independent professional can replace: appliances built to work mainly in splashing water, water streams or immersion and meant to be washed or rinsed, where that is needed for the user’s safety; and certain professional medical imaging, radiotherapy and in vitro diagnostic devices (Art. 11(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 11, paragraph 2Click opens the article on EUR-Lex.). The duty also falls away where a permanent connection is needed for continuity of power and safety, or for data integrity in a product whose main function is collecting and supplying data (Art. 11(3)Regulation (EU) 2023/1542, Batteries RegulationArticle 11, paragraph 3Click opens the article on EUR-Lex.). An e-bike or e-scooter battery, an LMT battery, has a different rule: it and its cells must be removable and replaceable by an independent professional (Art. 11(5)Regulation (EU) 2023/1542, Batteries RegulationArticle 11, paragraph 5Click opens the article on EUR-Lex.).

The duty attaches to each unit when it is placed on the market, that is, first made available in the EU (Art. 3(16)Regulation (EU) 2023/1542, Batteries RegulationArticle 3, point 16Click opens the article on EUR-Lex.). A unit placed on the market before 18 February 2027 stays sellable after it; units first supplied after that date must comply. Until then the old Batteries Directive’s rule still runs: appliances designed so waste batteries can be readily removed, with instructions on removing them safely (Art. 95Regulation (EU) 2023/1542, Batteries RegulationArticle 95Click opens the article on EUR-Lex.; Art. 11Directive 2006/66/EC, Batteries Directive (repealed by Regulation (EU) 2023/1542)Article 11Click opens the article on EUR-Lex. of Directive 2006/66/EC).

The Commission’s guidelines, Notice C/2025/214, are not binding but say how it reads the article. They read “commercially available tools” as basic tools, or no tools, plus tools anyone can buy, taken from standard EN 45554:2020. They equate “splashing water” with an IPX4 rating, “water streams” with IPX5 and IPX6, and “water immersion” with IPX7, and name toothbrushes, shavers, hair clippers and epilators as examples of appliances that primarily work in such an environment. They call the IP rating an indicative guide that does not show whether a redesign is possible, and list as relevant evidence in the product documentation that end-user replacement would compromise safety and that no redesign avoids it; the next sentence, read as written, says “the IP rating alone is considered as sufficient”. The Regulation’s condition does not move: the derogation applies only where it is required for the safety of the user and the appliance (Art. 11(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 11, paragraph 2Click opens the article on EUR-Lex.). For smartphones and tablets, the stricter battery rules of Regulation (EU) 2023/1670 prevail.

What take-back means when you ship to the buyer

A seller that makes batteries available to end users, other than their manufacturer or importer, is a distributor (Art. 3(65)Regulation (EU) 2023/1542, Batteries RegulationArticle 3, point 65Click opens the article on EUR-Lex.), and a distributor takes back waste batteries from the end user free of charge, without requiring a new purchase, whatever their brand (Art. 62(1)Regulation (EU) 2023/1542, Batteries RegulationArticle 62, paragraph 1Click opens the article on EUR-Lex.). Selling at a distance does not take you out of it. You provide enough collection points across each country you sell to, taking account of population and of how easily buyers can reach them (Art. 62(4)Regulation (EU) 2023/1542, Batteries RegulationArticle 62, paragraph 4Click opens the article on EUR-Lex.). When you deliver, you offer to take back the waste battery free of charge at the delivery point or at a local collection point, and you tell the buyer about it when they order (Art. 62(5)Regulation (EU) 2023/1542, Batteries RegulationArticle 62, paragraph 5Click opens the article on EUR-Lex.).

The duty is limited to the categories of battery you sell or sold, and for portable batteries to the quantity a household normally throws away. It does not cover a waste product with a battery still inside (Art. 62(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 62, paragraph 2Click opens the article on EUR-Lex.): that product is electrical waste and goes through the WEEE take-back, covered in WEEE registration. What you collect goes to the producer, its organisation or a selected waste operator (Art. 62(3)Regulation (EU) 2023/1542, Batteries RegulationArticle 62, paragraph 3Click opens the article on EUR-Lex.). Collection points set up with distributors are part of the producers’ own collection system in each country (Art. 59(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 59, paragraph 2Click opens the article on EUR-Lex.), so the producer responsibility organisation you join as a producer is also where a distance seller finds its collection points.

You also give buyers the producer’s information on handling and returning waste batteries, and on how to return them free of charge, including when you sell through an online platform (Art. 74(4)Regulation (EU) 2023/1542, Batteries RegulationArticle 74, paragraph 4Click opens the article on EUR-Lex.).

What a marketplace asks for

A marketplace that lets consumers buy from you must obtain two things before you offer batteries, or products with batteries, to consumers in the EU: the register you are in and your registration number or numbers, and your self-certification that you only offer batteries whose extended producer responsibility duties are met (Art. 62(6)Regulation (EU) 2023/1542, Batteries RegulationArticle 62, paragraph 6Click opens the article on EUR-Lex.). Without them it may not let you offer those products to consumers in the EU, and if what you gave turns out wrong and you do not correct it, it must suspend you for those offers (Art. 30(1)Regulation (EU) 2022/2065, Digital Services ActArticle 30, paragraph 1Click opens the article on EUR-Lex., Art. 30(3)Regulation (EU) 2022/2065, Digital Services ActArticle 30, paragraph 3Click opens the article on EUR-Lex.). You need a registration number for each EU country you ship batteries to.

Who sets the penalties

Each EU country lays down its own penalties for breaking the Regulation, and they must be “effective, proportionate and dissuasive” (Art. 93Regulation (EU) 2023/1542, Batteries RegulationArticle 93Click opens the article on EUR-Lex.). The Regulation sets no figure. The consequence you meet first is not a fine: without a registration you may not make batteries available in that country at all (Art. 55(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 55, paragraph 2Click opens the article on EUR-Lex.), and a marketplace may not let you offer them to consumers (Art. 62(6)Regulation (EU) 2023/1542, Batteries RegulationArticle 62, paragraph 6Click opens the article on EUR-Lex., Art. 30(1)Regulation (EU) 2022/2065, Digital Services ActArticle 30, paragraph 1Click opens the article on EUR-Lex.).

What you can set aside for now

What the law leaves open

• No capacity label duty between 19 August 2026 and the new one. The old Directive’s rule that portable and automotive batteries show their capacity (Art. 21(2)Directive 2006/66/EC, Batteries Directive (repealed by Regulation (EU) 2023/1542)The whole regulationClick opens the law on the EU Publications Office. of Directive 2006/66/EC) was kept alive only “until 18 August 2026” (Art. 95Regulation (EU) 2023/1542, Batteries RegulationArticle 95Click opens the article on EUR-Lex.). Its replacement, Art. 13(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 13, paragraph 2Click opens the article on EUR-Lex., waits for an implementing act that has not been adopted. The text leaves a gap between the two. Meanwhile, keep the capacity on rechargeable portable batteries: it is already on most, and it will be required again.
• Whether take-back reaches a seller who sells batteries only inside products. Art. 62(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 62, paragraph 2Click opens the article on EUR-Lex. limits the duty to “the categories of waste batteries which the distributor has or had as batteries in its offer”, and Art. 74(4)Regulation (EU) 2023/1542, Batteries RegulationArticle 74, paragraph 4Click opens the article on EUR-Lex. speaks of batteries the distributor has “as new batteries in its offer”. Both read as loose batteries, but neither says whether a battery sold built into a product counts. Meanwhile, if you sell loose or spare batteries, the duty is plainly yours; if you sell only products with batteries inside, the producer registration and fees still apply in full.
• Who shows the extended producer responsibility cost at the point of sale, and how. “The costs covered by the producer under Article 56(4), points (a) to (d), shall be shown separately to the end-user at the point of sale of a new battery” (Art. 74(5)Regulation (EU) 2023/1542, Batteries RegulationArticle 74, paragraph 5Click opens the article on EUR-Lex.). The sentence names no one and sets no format. Each EU country fills this in through its own rules and its producer responsibility organisations.