Under the new EU Batteries Regulation (EU) 2023/1542, all businesses selling batteries or battery-containing products in the EU market must complete registration and fulfill full-lifecycle compliance obligations. The following is a summary of key information and an operational guide:

I. Core Registration Requirements and Legal Basis

  1. Regulatory Scope
    Covers all types of batteries (excluding special-purpose batteries for military, aerospace, etc.), including portable batteries, electric vehicle batteries, industrial batteries, and more. Effective August 18, 2024, batteries without CE marking are prohibited from sale. Enterprises must undergo testing at third-party laboratories for electrical safety, chemical substance restrictions (e.g., mercury ≤ 0.0005%, cadmium ≤ 0.002%), and obtain CE certification.
  2. Extended Producer Responsibility (EPR) Registration

    • Registration Entity: Enterprises meeting any of the following criteria must register:
      ✅ Established within the EU and selling own-brand batteries
      ✅ Supplying batteries directly to EU end-users via distance sales
      ✅ Importing batteries into the EU and distributing them under their own name

    • Country-Specific Independent Registration: A separate EPR number must be applied for in each country of sale. For example, Germany requires registration per brand (e.g., selling 3 brands requires 3 separate applications).

II. Registration Process and Timeline

  1. Phased Compliance Timeline

    • July 2024: Traction batteries and industrial batteries must declare carbon footprint, submitting data on raw material composition, total carbon footprint, etc..

    • August 18, 2025: All batteries and battery-containing products must complete EPR registration and submit their registration number. Non-compliant products will be forcibly delisted by platforms (e.g., Amazon, TikTok Shop).

    • 2027: Traction batteries must hold a "Battery Passport," documenting supply chain, carbon footprint, and other full-lifecycle information.

  2. Registration Steps and Document Preparation

    • Example: Germany:
      ① Appoint an Authorized Representative (AR) within Germany, and submit materials such as basic enterprise information and trademark registration certificates.
      ② Complete registration through the "Stiftung EAR" platform; the review period is approximately 2–3 months, and an annual fee is required to maintain qualification.

    • Common Documents:
      ✅ Battery specification sheet (capacity, voltage, composition table)
      ✅ UN38.3 test report (lithium batteries)
      ✅ Declaration of Conformity (DoC) and CE certification certificate.

III. Key Compliance Obligations and Risks

  1. Full-Lifecycle Management

    • Production Phase: Sign a 10-year Declaration of Conformity, report carbon footprint, and use recycled materials (e.g., by 2030, recycled cobalt content in lithium batteries must be ≥12%).

    • Collection and Recycling Phase: Assume responsibility for waste battery collection and recycling; portable battery collection rate must reach 73% by 2030, and recovery rates for critical metals such as lithium and cobalt must be ≥80%.

    • Information Disclosure: Batteries must bear the CE marking, WEEE recycling symbol, and a QR code; scanning the code provides access to the "Battery Passport".

  2. Consequences of Non-Compliance

    • Market Restrictions: Platforms such as Amazon and TikTok Shop will delist products, and Pan-European FBA eligibility may be revoked.

    • Financial Penalties: Germany imposes fines of up to EUR 100,000 and confiscation of profits; France, Italy, and other countries are tightening enforcement.

    • Supply Chain Traceability: Customs may detain products, and enterprises must bear traceability compliance costs (e.g., back-payment of environmental levies).

IV. Strategies for Chinese Enterprises

  1. Authorized Representative and Localized Services
    Non-EU enterprises must complete registration through an Authorized Representative (AR). For example, Germany requires that the EPR registration number be tied to an AR; otherwise, it becomes invalid after August 2025. It is recommended to engage professional compliance service providers (e.g., J&P) to assist with multilingual documentation, government communications, and other matters.
  2. Multi-Platform Coordinated Compliance

    • E-Commerce Platforms: Submit EPR registration numbers via the Amazon "Regulatory Compliance" portal or the TikTok Shop "Battery Compliance Center," ensuring that brand and model information matches the registration details.

    • Multi-Category Linkage: Simultaneously complete WEEE (Waste Electrical and Electronic Equipment) and Packaging Act registration to avoid cascading risks.

  3. Technical Tools and Data Management
    Use AI tools to automatically identify battery-category products, establish an EPR registration number ledger, and periodically update contracts (typically in Q4 each year) to maintain qualification validity.

V. Official Resources and Operational Guidance


Enterprises are advised to initiate the registration process immediately, prioritizing high-risk markets such as Germany and the Netherlands, and allow at least 3 months to accommodate review delays. Through systematic compliance management, market access risks can be avoided while seizing the long-term opportunities presented by the EU circular economy policy.