The EU Battery Regulation extends producer responsibility to energy storage systems
The growing demand for energy storage systems is already visible in the European recycling system. Manufacturers and importers of energy storage systems should understand the requirements that the EU Battery Regulation and related legislation place on battery producers, users, and recycling operators.
The EU Battery Regulation (2023/1542), particularly Chapter 8, changed battery producers’ responsibilities in August 2025. Manufacturers and importers of batteries, and in certain cases distributors and distance sellers operating outside Finland, are subject to collective producer responsibility. This means that producers jointly bear the costs arising from the recycling of end-of-life batteries.
In practice, companies fulfill these obligations by joining a producer responsibility organization, which manages the collection and recycling of used batteries on their behalf. Similar systems are already in place for the recycling of vehicles and tires.
Collective responsibility means that producers must arrange the take-back not only of their own products but also of equivalent batteries placed on the market by other producers. Producer responsibility organizations carry out statutory obligations on behalf of their member companies and distribute the associated costs among producers.
Producer responsibility supports Europe’s battery self-sufficiency
Producer responsibility is linked to the EU’s objective of ensuring self-sufficient production and recycling of key battery raw materials in Europe. The Critical Raw Materials Act (CRMA) aims to increase the extraction, processing, and recycling of strategically important raw materials within Europe while reducing dependence on imports from outside the EU.
Among battery materials, lithium, cobalt, nickel, manganese, and graphite have been designated as strategic raw materials. The EU aims to establish recycling capacity sufficient to cover 25% of its annual consumption of these materials.
Additional CRMA targets for strategic raw materials by 2030 include:
- Mining capacity equal to at least 10% of annual consumption.
- Processing capacity equal to at least 40% of annual consumption (raw materials may be imported from outside the EU but processed within Europe).
The Battery Regulation also sets targets for the share of recycled materials used in key battery components. Compliance is ensured through technical documentation demonstrating that recycled content requirements are met. In addition, the regulation defines requirements for material recovery and recycling efficiency.
Producer responsibility fees also fund the recycling system
Increasing Europe’s self-sufficiency in battery production and recycling requires not only regulatory obligations, but also effective monitoring and enforcement. The EU Battery Regulation introduces a digital battery passport to improve the traceability of individual batteries. The passport will be introduced gradually for the different battery categories covered by the Regulation.
Companies placing batteries on the EU market must provide information in the battery passport on, among other things:
- the manufacturer
- the raw materials used and their origin
- the battery’s carbon footprint and
- its recyclability.
The battery passport enhances product traceability and makes it easier to monitor compliance with producer responsibility obligations. If an importer or distance seller based outside the EU fails to meet its producer responsibility obligations, the remaining producer community may ultimately have to cover the recycling costs of these “free-rider” products.
Producer responsibility fees must cover not only the recycling of battery materials, but also the establishment and maintenance of an effective recycling system. Stakeholders across the battery industry need to be able to develop appropriately scaled recycling systems and producer responsibility fee structures.
Producer responsibility organisations may also have to cover the recycling costs of products placed on the market by ‘free riders‘.
Battery production supports recycling – and recycling supports production
Battery production and recycling are closely interconnected. In addition to end-of-life batteries, rejected materials and production by-products generated at different stages of battery manufacturing must also be recycled. Recycling facilities recover and refine valuable raw materials that can replace virgin materials extracted through mining.
Locating both battery production and recycling in Europe shortens supply chains while strengthening material traceability and security of supply. Battery recycling in Europe:
- enables the use of secondary and recycled raw materials in battery manufacturing instead of virgin mined materials;
- strengthens the EU’s security of supply for battery raw materials by making recycled materials available for battery production;
- improves transparency and oversight of both production and recycling when the entire value chain is located in Europe; and
- supports investment in the battery industry and the development of new technologies.
The growing use of industrial batteries requires producers to adopt comprehensive, multidimensional risk management practices.
Circular economy expertise throughout the battery value chain
In Finland, producer responsibility for batteries, including non-lead-acid batteries, is managed by Recser Oy. Recser Industrial Oy was established specifically to implement producer responsibility for industrial batteries. Our experts have worked closely with Recser to develop a responsible and resilient producer responsibility model for industrial batteries.
From a producer responsibility perspective, the growing use of industrial batteries calls for comprehensive and multidimensional risk management. Recycling costs may change significantly over a battery’s long lifecycle, so the system must ensure that recycling costs are covered under all future scenarios.
Forecasting battery demand is challenging in a rapidly evolving market. Nevertheless, we aim to support all members of the producer community throughout the value chain, from battery imports and raw material processing to material recycling. Our organisation also includes dedicated specialists in circular economy systems.
Our battery industry experts have participated in projects aimed at strengthening Europe’s self-sufficiency in battery production and recycling. We support our clients across the entire battery value chain, from raw material extraction and battery material production to battery manufacturing and the implementation of recycling solutions.
Would you like to discuss the future of the European battery industry?
Would you like to learn more about the direction of the European battery industry and explore how these developments could affect your business and operations in the battery sector?
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Erno Voutilainen, Lead Expert, Battery Industry, erno.voutilainen@sweco.fi