The EU Batteries Regulation imposes new obligations on distributors, i.e., sellers of batteries and accumulators. These obligations include, among other things, ensuring the conformity of batteries, accepting end-of-life products, and providing information to customers.
A distributor is a company that sells a product manufactured in the EU or already placed on the EU market. Distributors include retail and wholesale sellers as well as traders of used goods, such as recycling centres and flea markets.
Below is a summary of the key requirements that every distributor must take into account.
Remember! A distributor selling products under their own brand is considered the manufacturer. In this case, the distributor is subject to manufacturer responsibilities. Always check whether your company is classified as a distributor or a manufacturer.
Distributor’s responsibilities and obligations
Check compliance
- Ensure that the battery or accumulator producer has fulfilled their producer responsibility and is registered in the producer register.
- Use the authorities’ Waste Management Compass (Jätehuoltokompassi) to verify companies that have fulfilled producer responsibility.
- Ensure the battery bears the CE marking. The CE mark indicates that the product complies with EU safety, health, and environmental requirements.
- Take note of the QR code. From 18 February 2027, all batteries and accumulators must carry a QR code containing essential product information.
- Check that the product comes with required documents, instructions, and information in clear Finnish and Swedish. These must include:
- Information on substance restrictions, carbon footprint, recycled content, performance, and durability.
- Information on safety and product lifespan.
If the manufacturer or importer has not translated instructions and safety information into Finnish and Swedish, translation is the distributor’s responsibility.
Product identification
- Check that the product includes:
- Model identification.
- Batch, serial, or product number, or another unique identifier.
- Manufacturer and importer names, registered trade name or trademark, postal address, and, if applicable, website and email address.
Storage and transport
- Ensure that storage and transport conditions do not compromise the conformity of the battery or accumulator.
Handling non-compliant products
- Do not place a battery or accumulator on the market if you suspect it does not comply with the Batteries Regulation.
- Take corrective actions, such as bringing the product into conformity, withdrawing it from the market, or organising a recall.
A checklist for distributors is also available on the TUKES website.
When a distributor is considered a manufacturer
A distributor is considered a manufacturer under the Batteries Regulation and is subject to manufacturer obligations if any of the following applies:
- The battery or accumulator is placed on the market or put into service under the distributor’s own name or trademark.
- The distributor modifies a battery or accumulator already on the market or in use in a way that could affect compliance with the Regulation.
- The distributor changes the intended use of a battery or accumulator already on the market or in use.
In such cases, the distributor must comply with the responsibilities and obligations set for manufacturers.
Extended take-back obligations for distributors
The new Batteries Regulation expands distributors’ obligations regarding the take-back of waste batteries and accumulators. Previously, distributors were only required to accept portable batteries and accumulators. From 18 August 2025, distributors must also accept other waste batteries and accumulators in their product range.
Distributors must accept waste batteries and accumulators from end-users free of charge, regardless of their chemical composition, brand, or origin.
- Portable waste batteries and accumulators: must be accepted at the point of sale or nearby.
- Batteries for light means of transport, vehicle batteries, industrial batteries, and electric vehicle traction batteries: must be accepted at the point of sale or nearby.
The take-back obligation only applies to the battery types you sell. For example, if you sell starter batteries, you must accept all starter batteries, regardless of chemistry. If you sell industrial batteries, the obligation applies to industrial batteries.
For portable waste batteries and accumulators, take-back is limited to the quantities normally discarded by private users.
You must also inform end-users about waste battery and accumulator return arrangements at the time of purchase. This obligation does not apply to waste products containing batteries, such as electrical appliance waste.
Returned waste batteries and accumulators must be delivered to producers, producer responsibility organisations, or their appointed waste management operators for processing. If your sales include delivery, you must offer the possibility to return batteries free of charge at the delivery location or a local collection point.