The EU Battery Regulation significantly reforms producer responsibility systems for batteries. At the Battery Regulation Seminar held in August 2025 at Heureka Science Center in Vantaa, participants learned about the regulation’s impacts on the operations of producer organisations: distributors’ obligation to take back batteries as well as stricter efficiency and recovery requirements will change future collection and recycling. Recser Oy is building an entirely new collection system for large industrial batteries in cooperation with Akkukierrätys Pb Oy. Meanwhile, Suomen Autokierrätys Oy is preparing both for these changes and for the growing number of electric vehicles.
“The Battery Regulation changes the way we all work, our objectives, but at the same time, there are many elements that will remain much the same,” says Johanna Alakerttula, Managing Director of Akkukierrätys Pb Oy.
Producer organisations for batteries help their members understand the changes the regulation brings to producer responsibility and fulfill their new, up-to-date obligations.
“A single producer cannot realistically – and frankly should not – handle the obligations alone,” says Liisa-Marie Stenbäck, Managing Director of Recser Oy.
With the Battery Regulation, more and more companies are regarded as producers in the eyes of the law.
“The Battery Regulation has now broadened the definition of a producer to mean anyone who ‘places a product on the market in Finland for the first time.’ Therefore, distributors of products may also be regarded as producers and thus subject to producer responsibility,” Stenbäck explains.
Distributors’ take-back obligation and stricter requirements reform producer organisations
The take-back obligation for distributors is one of the changes introduced by the Battery Regulation, and it affects all three producer organisations.
“In the future, all distributors must take back the types of batteries they sell – which means the collection system will gain a large number of new points,” says Recser’s Stenbäck.
Producer organisations’ collection networks will therefore grow.
“If you sell electric cars, you are also obliged to take them back. Our collection network is already quite broad, and we are now considering what it will look like in a practical sense. We are planning a new system and digitalising it,” says Juha Kenraali, Managing Director of Suomen Autokierrätys Oy.
According to Akkukierrätys Pb’s Alakerttula, many lead battery distributors have in practice already been taking back batteries for a long time. However, the expanded take-back obligation will particularly change practices for smaller companies.
More detailed guidance on the take-back obligation will be provided later by the Ministry of the Environment.
Lithium-ion batteries as Europe’s challenge: stricter recycling efficiency and recovery requirements call for action
The Battery Regulation strengthens recycling through efficiency requirements and material recovery targets, which will gradually increase until 2031. These changes affect all three producer organisations, albeit in slightly different ways.
“Alkaline batteries and high-cobalt lithium-ion batteries in smart devices are already recycled quite efficiently,” says Stenbäck.
But not all battery types yet have established recycling processes in Europe.
“For light electric vehicle batteries and other low-cobalt lithium-ion batteries, efficient recycling channels have not yet emerged, as waste streams remain small due to long lifetimes. The biggest challenges relate to batteries with varying chemistries and raw material contents that are not evident from their markings,” she continues.
Stricter requirements also apply to lead batteries, though the situation is different in their case.
“A significant share of the lead recovered from batteries in recycling facilities is already used again in lead battery manufacturing,” says Alakerttula.
“Lead battery circular economy is already a reality,” she adds.
Recser Oy: “We make producer responsibility manageable”
Recser Oy, founded in 2008, has operated as a producer organisation for portable batteries and other small batteries under 25 kilograms, excluding lead batteries. It is a producer-founded and producer-owned organisation with more than 1,200 members.
“We expect the number of foreign distance sellers to grow significantly in the coming years, though the majority of registered members are currently domestic importers,” says Managing Director Liisa-Marie Stenbäck.
Recser’s collection network is extensive relative to population: there are about 7,000 collection points. Last year, around 2,000 tonnes of batteries were collected through the network, about half of which were recycled as secondary raw materials.
“That met the current collection target of 45%, but requirements will tighten significantly in the future,” says Stenbäck.
Battery Regulation changes are already expanding Recser
The most significant change for Recser under the Battery Regulation is the expansion of its operations to also cover large industrial batteries over 25 kilograms.
“The biggest change relates to large industrial batteries. They will be subject to collective responsibility, meaning we must take back all batteries in this category, regardless of who placed them on the market or their chemistry,” Stenbäck explains.
To address this change, Recser and Akkukierrätys Pb will jointly build a new collective system for large industrial batteries. This nationwide network will receive all types of industrial batteries and forward them to recycling.
Akkukierrätys Pb Oy: lead batteries responsibly recycled
Founded in 2008, Akkukierrätys Pb Oy is a producer organisation for automotive and industrial lead batteries. Like other producer organisations, it was established by producers and is owned by four companies that import batteries.
“Lead batteries have been mainstream for a very long time. We have over 400 members, ranging from importers of lead batteries to those importing vehicles and machines containing them,” says Managing Director Johanna Alakerttula.
Akkukierrätys Pb’s nationwide lead battery collection network has more than 400 collection points, including waste facilities and auto service companies. For transport and recycling, Akkukierrätys cooperates with ten different operators.
“About 20,000 tonnes are collected annually. That’s a significant amount and has remained stable year after year,” Alakerttula says.
Suomen Autokierrätys Oy: “Our principle is to handle all producer responsibility obligations on behalf of producers and disturb them as little as possible”
Founded in 2001, Suomen Autokierrätys Oy was established by Autontuojat ry, the Finnish Car Importers’ Association, whose members are importers. Suomen Autokierrätys operates under one umbrella with separate producer organisations for end-of-life vehicles and for traction batteries in electric cars. Its nationwide collection network has about 700 collection points. The batteries recycled from electric cars are primarily lithium-ion batteries.
“There are not yet very many electric cars in traffic, so only a small number are currently reaching recycling. However, this will grow significantly in the future,” says Managing Director Juha Kenraali.
The annual collection volume is about 500 tonnes.
“In tonnes, that’s already a significant amount, but compared to the potential, it’s still small. That 500 tonnes will increase ten- to twenty-fold in the next 5–10 years,” Kenraali says.
Suomen Autokierrätys is already preparing for the introduction of battery passports under the Battery Regulation. These passports will include information on each recyclable battery, which will facilitate reporting on behalf of producers.
“We have prepared for the battery passport by creating an interface in our new system, which will be able to provide information for possible future passports. The plan is to have the system ready at the beginning of next year,” Kenraali explains.
Producer responsibility for batteries
Producer responsibility refers to a company’s legal obligation to arrange waste management and recycling for its products at the end of their lifecycle. This obligation applies to companies acting as producers – that is, as manufacturers, importers, distributors, or distance sellers.
In Finland, companies meet their producer responsibility obligations by joining a producer organisation for their product group. The producer organisations for batteries in Finland are Akkukierrätys Pb Oy, Recser Oy, Suomen Autokierrätys Oy, and ERP Finland ry.
The producer organisation assumes responsibility for the practical arrangements of collection, transport, and recycling of the products placed on the Finnish market once they become waste.
Photos: Sus+Com Agency/Antti Partanen
View presentations from the webinar speakers (in Finnish):
Liisa-Marie Stenbäck, Recser Oy (PDF)
Johanna Alakerttula, Akkukierrätys Pb Oy (PDF)
Juha Kenraali, Suomen Autokierrätys Oy (PDF)
Stay up to date with the progress and content of the Battery Regulation
As the producer organisations, it is important for us to remain up-to-date and share information on how the content of the EU’s Battery Regulation will affect the responsibility of producers of batteries and accumulators in particular.