Do Products That Contain Batteries Fall Under the Batteries Regulation?

The short answer is yes. The Batteries Regulation (EU) 2023/1542 applies not only to batteries sold on their own but also to products that contain batteries. If your catalogue includes toys, power tools, wireless keyboards, electronics or anything else with a cell inside, the Regulation is relevant to you.

Why finished products are covered

The Regulation replaces the old Batteries Directive and deliberately casts a wide net. Its aim is to make sure that every battery placed on the EU market can be collected, recycled and traced, regardless of whether the consumer bought the battery loose or as part of a gadget. A battery hidden inside a product still becomes waste one day, so the same collection and recycling logic has to apply.

What that means in practice

Because the batteries inside your products are in scope, several duties can follow. The most common are labelling, extended-producer-responsibility (EPR) registration and take-back arrangements.

• Labelling: the battery should carry the required marks, including the crossed-out wheeled-bin separate-collection symbol and, from 2027, a QR code.
• EPR registration: you may need to register as a producer, and this applies per Member State where you place products on the market.
• Take-back: you may have obligations to accept used batteries back for collection.

Do not assume your supplier has it covered

A frequent mistake is to assume the manufacturer or importer further up the chain has dealt with everything. Obligations often attach to the party that places the product on the market in a given country, which can be you. If you import goods with batteries, or sell into several Member States, check each country’s registration requirements rather than relying on a supplier’s assurance.

For more detail, see the complete battery guide, the Batteries Regulation overview, or the battery passport explainer.

This article is educational and is not legal advice.