The changes in waste management and extended producer responsibility under the EU Battery Regulation entered into force on 18 August 2025. Batteries may no longer be placed on the market without fulfilling producer responsibility obligations and meeting the requirements of the Regulation. In Finland, these obligations are fulfilled by joining a producer responsibility organisation (PRO). The Battery Regulation applies directly in all EU countries, and its requirements must be followed even if national implementation is delayed.
Authorities responsible for legislative preparation and enforcement, the Ministry of the Environment and the ELY Centres, presented the changes at the Battery Regulation Seminar held at Heureka Science Centre in Vantaa in August 2025.
Johanna Routio, Government Secretary at the Ministry of the Environment, explained the nature of the Battery Regulation through a life-cycle approach covering batteries. Jaana Mäenpää, Senior Officer at the Pirkanmaa ELY Centre, emphasised that the Battery Regulation is built around producer responsibility.
In addition, Sinikka Koikkalainen, Head of Supervision at the Häme ELY Centre, outlined the impacts of changes in the European Waste Catalogue on waste reporting and the possible need to amend environmental permits.
The goal is a circular economy: Regulation covers the entire life cycle
According to Government Secretary Johanna Routio, the purpose of the Regulation is to promote the circular economy by covering the entire life cycle of batteries. A key objective is to increase the recovery and reuse of valuable materials contained in batteries.
The background to the Regulation is the rapidly growing demand for batteries, which is expected to increase fourteenfold by 2030.
“The term ‘life-cycle regulation’ may not fully describe it – it is really a ‘circular life regulation,’” Routio said.
Manufacturers, for example, must consider the reusability of products already at the design stage.
“There are obligations for all actors in the value chain, and everyone must do their part,” Routio emphasised.
The chapter of the Battery Regulation concerning producer responsibility entered into force on 18 August 2025. National implementation in Finland has been delayed (as of August 2025), with the goal of bringing the remaining regulatory changes into force by 1 January 2026.
“The current regulatory amendments mainly concern the chapter on producer responsibility and waste management. Preparation of the complementary national legislation is slightly behind schedule. Ideally, national legislation would have entered into force simultaneously with the Regulation’s chapter,” Routio noted.
Guidance is currently being prepared for reporting obligations and distributors’ take-back obligations by battery category. Instructions are also being drafted for producers’ collection network requirements, which will vary depending on the type of industrial battery.
Despite delays at national level, the Regulation must still be complied with. Most of its provisions are directly applicable in all Member States, and their content may not be repeated or interpreted in national legislation.
Producer responsibility is at the core of the Battery Regulation
With the entry into force of the changes regarding waste management and producer responsibility, batteries can no longer be placed on the market without fulfilling producer obligations. Producer responsibility refers to the obligation of producers to organise the sustainable and safe recycling and other waste management of their products at their own expense.
“In Finland, producer responsibility is primarily managed by joining a producer responsibility organisation,” explained Jaana Mäenpää of the Pirkanmaa ELY Centre.
The Regulation has expanded producer responsibility obligations, making it extremely challenging for individual companies to meet them alone. Producers must, for example, receive waste batteries of their own category free of charge through a nationwide collection network. This is a significant change, particularly for industrial battery producers, who will need to transition from individual contractual models to a common collective system.
Producer responsibility organisations are non-profit organisations founded by producers themselves, to which producers outsource the collection, transport, treatment, and recycling of their end-of-life products. PROs also handle tasks such as regulatory reporting and communications on behalf of producers.
Broader definition of “producer”
“In the case of batteries, the producer is the economic operator who places the product on the Finnish market for the first time. This includes importers, manufacturers, distributors established in Finland, and foreign distance sellers,” Mäenpää clarified.
Importers, in this context, are those bringing products into Finland from within the EU or from outside the EU.
“Producers also include those selling batteries under their own brand or embedded in other products,” Mäenpää continued.
According to the definitions in the Battery Regulation, more actors now fall under the scope of producer responsibility.
“Newly included are economic operators who, through treatment activities such as preparation for reuse or repurposing, place waste batteries back on the market as products,” Mäenpää said.
Distance sellers, in turn, must appoint an authorised representative in Finland to take responsibility for their producer obligations if they sell batteries directly to end-users.
Number of battery categories rises from three to five – PROs support producers in meeting the new requirements
The Regulation increased the number of battery categories from three to five. Portable batteries and automotive batteries remain as their own categories.
“In addition, propulsion batteries for electric and hybrid vehicles and batteries for light means of transport have been separated from industrial batteries into their own categories. Different categories and chemistries are subject to different obligations and targets,” Mäenpää explained.
The classification is important because, for example, new collection requirements under the Regulation are determined based on it. Furthermore, distributors’ take-back obligations specifically apply to the categories of batteries that they sell.
Battery Regulation and changes in the waste catalogue affect waste reporting and environmental permits
In addition to the Battery Regulation, waste operators must prepare for changes in the European Waste Catalogue, which will affect the classification of battery fractions in waste reporting and environmental permits. Batteries, their manufacturing waste, and intermediate fractions from treatment will generally be classified as hazardous waste in the future.
“The change to the Waste Catalogue will apply from 9 November 2026, according to the Commission’s decision. In Finland, the plan is that the current waste codes will still be used for 2026 reporting. Companies should prepare by ensuring that, in their bookkeeping for 2027, wastes are classified under the new codes, with reporting based on them the following year,” said Sinikka Koikkalainen, Head of Supervision at the Häme ELY Centre.
“Operators should already contact their supervisory authority to assess whether their permits will need to be amended before the Waste Catalogue changes take effect,” Koikkalainen added.
View presentations from the webinar speakers (in Finnish):
Johanna Routio, Ympäristöministeriö: EU:n akkuasetus – kohti akku- ja paristoalan kiertotaloutta (PDF)
Jaana Mäenpää, Pirkanmaan ELY-keskus: Tuottajavastuu akkuasetuksessa – velvoitteet, valvonta ja muutokset (PDF)
Sinikka Koikkalainen, Hämeen ELY-keskus: Akkuasetuksen vaikutus ympäristölupiin ja jäteraportointiin – jäteluettelon muutos (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.