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Webinar answers: How does the battery regulation change the obligations of manufacturers and importers? 

The focus of the second battery producer organisations’ battery regulation webinar was obligations imposed on battery manufacturers and importers by the new EU battery regulation. 

The EU’s battery regulation is part of a new type of EU regulation that covers the product’s entire life cycle from raw materials to recycling the product. The regulation strengthens the functioning of the EU’s internal market, promotes the circular economy and reduces the environmental and social impacts of batteries.

The theme of the second battery regulation webinar held by Akkukierrätys and Recser Oy on 21 May 2024 was chapters 4–8 of the regulation, which focus on the obligations of battery manufacturers and importers. With these webinars, we battery producer organisations want to provide our members with support in fulfilling the obligations.

The webinar was attended by 260 participants, of which nearly half were importers of either portable batteries or electrical and electronic equipment.

What does due diligence mean?

One of the obligations of the battery regulation is related to due diligence. Economic operators must fulfil the due diligence obligations and implement the related policies by August 2025. 

The aim of due diligence is, first and foremost, to prevent the occurrence of adverse effects on people, the environment and society. Companies must ensure that human rights and the environment are upheld and valued at every part of the production chain. The obligation also applies to subcontractors and subsidiaries. 

The principle of due diligence was further explained in the webinar by Senior Specialist Johanna Routio from the Ministry of the Environment. She reminded the participants that companies cannot yet be provided with a comprehensive list of the actions required to implement due diligence policies. The Commission is currently preparing due diligence guidelines that are due to be published in February 2025. In addition, the Commission has the power to adopt delegated acts. 

“It requires a lot of effort from companies to have all the required documents and operating methods ready by August 2025. After this, the implementation of policies is an on-going process,” said Routio. 

Battery conformity 

With the battery regulation, batteries must meet stricter requirements than before in order to be released to the EU market. The aim is to ensure people’s safety, health and property and to protect the environment. 

“According to the battery regulation, the manufacturer is responsible for the battery’s conformity,” said Senior Specialist Kati Suomalainen from the Ministry of the Environment in the webinar. 

The new requirements are related to the sustainability, safety, labelling and information requirements for batteries.

For example, manufacturers must ensure and demonstrate with tests that their batteries meet the requirements of the battery regulation. If a product is in conformity with the requirements, a declaration of conformity will be drawn up and a CE marking will be affixed to it. The product must have clear, understandable and readable instructions and safety information.

“The declaration of conformity must be updated as the new requirements of the battery regulation enter into force,” said Suomalainen. 

Find out whether your company is a manufacturer or an importer

Finnish Safety and Chemicals Agency’s Senior Adviser Tiia Salamäki emphasised in the webinar the obligation of all battery manufacturers and importers to ensure that only products that comply with the battery regulation will be available in the market in the future. 

However, the obligations are different for manufacturers and importers, and it is important to determine the role of each company. 

Although the roles are generally clear, importers might have to fulfil the obligations of manufacturers if they release batteries labelled with their own trade name to the market. Operators who prepare products for re-use, for example, are also considered manufacturers.

Salamäki answered the participants’ questions in the webinar. She explained, for example, that the product labels required by the battery regulation can be affixed to the product packaging if they are too large for small-sized products. Which labels need to be primarily affixed to the product is still unclear.  

Producer responsibility is also facing changes as a result of the battery regulation

Importers, manufacturers, remote sellers and distributors are responsible for the recycling and waste management of batteries. This is called producer responsibility and it ensures that recycling is free of charge to the end user. 

The Centre for Economic Development, Transport and the Environment of Pirkanmaa is the supervisory authority for producer responsibility in Finland. Senior Inspector Jaana Mäenpää explained in the webinar how the battery regulation is changing the producer responsibility requirements. 

The battery regulation affects the producer responsibility for batteries in many ways. Companies are not allowed to release products to the market in an EU country if the producer responsibility obligations are not fulfilled in the country in question. The obligation also applies to remote sellers, who are now required to appoint an authorised representative for producer responsibility separately for each country. 

The classification of batteries is also changing as a result of the battery regulation, as the batteries of electric means of transport and traction batteries of electric cars are separated into distinct categories. Different battery categories are subject to different obligations and targets, which should be studied carefully. 

The battery regulation also sets stricter collection, recycling efficiency and material recovery targets. 

The regulation encourages producer organisations to improve the efficiency of their operations. Joining a producer organisation is the easiest way to fulfil the producer responsibility obligations also when the new battery regulation enters into force.

The webinar series continues in the autumn—share your ideas with us

We will arrange at least two battery regulation webinars in the autumn. The dates and topics will be announced at a later date. 

If you want to suggest your ideas for the topics, please contact us by email. 

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.