Producer responsibility for batteries

In which cases are you subject to producer responsibility for batteries?

As a company you are subject to producer responsibility for batteries the first time you make a battery available on the Danish market – whether you are the producer, importer, or distributor.
Making available means:

• Any supply of a battery for distribution or use in Denmark.
• This only applies when it involves a commercial activity.

If you resell batteries that have already been made available by another company – and you do not change the product or the marking – you are not subject to producer responsibility for batteries.

Which types of products are covered?

Generally, the rules apply to all types of batteries. The EU Battery Regulation divides batteries into five categories: (follows from article 1(3)):

• Portable batteries – weigh 5 kg or less and are not industrial batteries
• Starting batteries – used for vehicles’ combustion engines
• Light means of transport batteries (LMT) – motive power for, e.g., electric bicycles
• Electric vehicle batteries – power for traction in, e.g., hybrid or electric vehicles
• Industrial batteries – specifically designed for industrial uses or that do not belong to other categories

The producer responsibility also applies to batteries that are incorporated into or added to products such as electric bicycles, tools, toys, or electronics.

Precise definitions can be found in Article 3(1), points 9-14 1 of the Battery Regulation.

How to register in the producer register, and what information to use in the registration

When you register, you must log into the system through virk.dk and register the following information:

• Company information
• Information about contact person
• Battery categories
• Expected quantities for the calendar year, in which you apply for registration and for the subsequently calendar year
• Battery chemistry and choice of collective scheme
• Brands
• Distance selling

You can get help registering by following the instructions here

Are we required to be a member of a collective scheme or have an authorised representative?

If you are subject to producer responsibility you can find help for meeting your obligations by becoming a member of a collective scheme that can help you with the administrative and practical tasks associated with the producer responsibility.

• It is mandatory for you to be a member of a collective scheme if you are a producer of portable batteries and light means of transport batteries.
• It is voluntary to be a member of a collective scheme if you have producer responsibility for industrial batteries, starting batteries, and electric vehicle batteries.

You are free to choose whether your collective scheme is to assume the producer responsibility for all your categories or just the ones that are mandatory.

If you are established abroad and if you sell batteries for end-users in Denmark, you must designate an authorised representative to comply with your obligations relating to producer responsibility.

What are the costs associated with the producer responsibility?

A number of costs are associated with the producer responsibility. These are:

• registration fee for entry in the producer register
• annual fee for DPA
• membership of collective scheme, if relevant
• guarantee to Danish Environmental Protection Agency in connection with approval, if relevant.

You can read more about registration fee and annual fee for DPA here.

Which authority is in charge of supervision and control relating to the Battery Regulation?

The Danish Environmental Protection Agency is the supervisory authority. The Agency carries out control and supervision of compliance with the rules of the Battery Regulation and Statutory Order no. 986 of 20 June 2025. This also means that any complaints against decisions made by DPA may be brought before the Danish Environmental Protection Agency.