Innovation for batteries and accumulators:
New categories and obligated parties.
Table of contents
From 18.08.2025, the obligations arising from the EU Battery Regulation (EU 2023/1542) will also apply to foreign distributors not based in Denmark who serve this market. In this newsletter you will find all relevant information.
Background & legal situation
The EU Battery Regulation (EU 2023/1542) replaces the previous Directive 2006/66/EC and creates a uniform legal framework for batteries and waste batteries in the EU – including Denmark. It will be fully transposed into Danish law by August 18, 2025, the date on which the old directive officially expires.
Who is affected?
All manufacturers and importers of batteries who place products on the market in Denmark – even without a Danish branch – will in future be subject to extended producer responsibility (EPR). Foreign companies must appoint an authorized representative in Denmark.
What exactly do companies need to do?
The following obligations will apply from August 18, 2025:
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Registration in the Danish producer register, including volume planning for 2025 and 2026 and information on battery composition.
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Organization of take-back and recycling of all battery types.
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Annual reporting on quantities placed on the market and recycled – including transparency and inspection obligations.
New battery categories according to the regulation:
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Portable batteries (≤ 5 kg)
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Batteries for light vehicles (LMT, ≤ 25 kg)
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Industrial batteries (IND1, IND2)
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Batteries for electric vehicles (> 25 kg)
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Starter, light and ignition batteries (SLI)
Take-back systems & organizations
For portable and LMT batteries, membership of a recognized producer organization (e.g. Batteriretur) is mandatory.
For industrial batteries, EV batteries and SLI batteries, participation is voluntary, but take-back and reporting obligations must also be fulfilled here.
Important deadlines
The regulation has officially been in force since February 18, 2024. National implementation is underway and the first obligations already apply – for example regarding registration and responsibility for take-back systems.
The regulation will come into full application on August 18, 2025. From this date, companies must fully comply with the new requirements, including registration in new battery categories and compliance with stricter environmental requirements
The registration phase in the Danish producer register will also begin on August 18, 2025. Companies must provide estimated quantities for the years 2025 and 2026 and correctly categorize their battery products.
What are the consequences of non-compliance?
Companies that fail to meet their obligations run a risk:
- high fines (prescribed by law),
- Sales bans,
- or forced inclusion in expensive take-back systems.
To summarize:
- All battery types are subject to the EPR in Denmark.
- Foreign companies must also register and appoint representatives if necessary.
- Obligations: Registration, take-back, recycling, reporting, system participation if applicable.
- Start date: August 18, 2025
