How to proceed when the new rules on batteries enter into force
On 18 August 2025, the new producer responsibility for batteries will enter into force. If you are covered by the producer responsibility, this means that you must register again and report expected quantities put on the market for the year you register as well as the subsequent year. In addition, you must register the battery’s battery chemistry.
New categories of batteries
The new rules apply to all types of batteries. This means everything from ordinary household batteries, batteries for vehicles, bicycles and scooters, to large specially designed industrial batteries. The EU Battery Regulation divides batteries into five categories:
- Portable battery – weighs 5 kg or less and is not an industrial battery
- Battery for light means of transport (LMT) – motive power for, e.g., electric bicycles
- Industrial battery – specifically designed for industrial uses or that does not belong to other categories
- Starting battery – used for vehicles’ combustion engines
- Electric vehicle battery – power for traction in, e.g., hybrid or electric vehicles
Precise definitions can be found in Article 1, point 3 of the Battery Regulation.
Must we be a member of a collective scheme or have an authorised representative?
If you are covered by the producer responsibility you can find help for meeting your obligations by becoming a member of a collective scheme. Such scheme can help you with administrative and practical tasks that are 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 batteries for light means of transport.
- It is voluntary for you 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.
When to register?
From 18 August when the new rules on batteries enter into force, we open for the registration.
In connection with your registration, you must report expected quantities put on the market for 2025 and 2026. You must also report the battery chemistry of the batteries.
What you should do on 18 August depends on your status:
- Danish producer with no collective scheme
- Danish producer member of collective scheme
- foreign producer
When you are a Danish producer and are not a member of a collective scheme you must:
- make sure to have access right to our system where you report
- register in our system as from 18 August where you must report expected quantities put on the market for 2025 and 2026.
Please note that you must select a collective scheme if you are a producer of portable batteries and batteries for light means of transport.
If you are a Danish producer and are a member of a collective scheme you or your collective scheme can register you in the system.
If your collective scheme registers you, you get a request from the system where you approve the creation. If you register yourselves, your collective scheme will get a request that they must approve.
In order to approve the request, you must make sure to have access right to the system.
If you are established abroad (EU and non-EU) and if you sell batteries for end-users in Denmark, you must register in our system where you are to report expected quantities put on the market for 2025 and 2026.
In connection with the registration, you must designate an authorised representative who can meet your obligations.
If you are a producer of portable batteries and batteries for light means of transport, your authorised representative must select a collective scheme for the categories.
Good to know before registration
Yes, you must.
If it is the first time you register, you must pay a one-off fee of DKK 1,000 to Dansk Producentansvar.
If you are already registered in the producer register under one of the following statutory orders, you must pay a one-off fee of DKK 500:
- Statutory Order no. 1453 of 7 December 2015 on batteries and accumulators and waste batteries and accumulators.
- Statutory Order on End-of-Life Vehicles.
- WEEE Order.
- Statutory Order on extended producer responsibility for certain single-use plastic products.
- Statutory Order on extended producer responsibility for plastic fishing gear.
- Statutory Order on certain requirements for packaging and extended producer responsibility for packaging and filled packaging.
If you are already covered by producer responsibility for packaging, fishing gear, or single-use plastic products, you already have access to this system.
If you do not have access to our system, you must make sure to set up your rights on MitID.
In connection with your registration, you must report expected quantities put on the market for the year you register and the subsequent year. This means for 2025 and 2026.
It is not possible for a collective scheme to pre-register a foreign producer, since the foreign producer must first select an authorised representative.
Just like for the product areas of packaging and single-use plastic products you can pre-register many producers at a time by uploading a JSON file.