Implementation of EPR for industrial and starter batteries (SLI): challenges and compliance

As part of the roll-out of the European Green Deal, announced by the European Commission in 2019, a number of regulatory texts have been drafted to enable Europe to achieve its ambitious target of reducing greenhouse gas emissions by at least 55% by 2030. In this context, European Regulation 2023/1542 on batteries and battery waste has extended the extended producer responsibility (EPR) already in place for many products, such as batteries and accumulators weighing less than 5 kg, to all types of batteries.

The regulation, which came into force on 18 August 2025, divides batteries into five categories:

• Portable batteries (≤ 5 kg, non-industrial use)
• Batteries for light transport (LTT) (≤ 25 kg, bicycles, scooters, etc.)
• SLI batteries (starting, lighting, ignition of vehicles)
• Industrial batteries (> 5 kg, professional or stationary use)
• Batteries for electric vehicles (EV) (> 25 kg)

All producers, as defined by European regulations, who place batteries on the market in France are responsible for the collection, removal and treatment of waste from their products, at no cost to the holders.

To do so, they have two options: join an approved eco-organisation or set up an individual system that must be approved.

The regulation defines a battery producer as any natural or legal person (company, manufacturer, importer, distributor) who places batteries on the market, regardless of the method of sale used (online, in-store, etc.). 

More specifically:

1. Manufacturer or own brand: A company established in a Member State that manufactures batteries under its own name or brand, or has them designed/manufactured for sale under its name (even if the batteries are incorporated into appliances or vehicles).

2. Reseller under own brand: A company established in a Member State that resells batteries manufactured by others under its own name or brand, without mentioning the original manufacturer (even if the batteries are integrated into appliances or vehicles).

3. Professional importer: A company established in a Member State that imports batteries (or appliances/vehicles containing batteries) from another Member State or a third country, in order to supply them to the market for the first time.

4. Distance seller: A company (established in another Member State or a third country) that sells batteries directly to end users (private individuals or professionals) in a Member State via distance contracts (e.g. online).

The regulation also sets progressive targets:

• Collection rates for portable and MTL batteries
• Recycling rates for lead, nickel-cadmium and lithium batteries
• Material recovery rates for cobalt, copper, lead, lithium and nickel

These measures aim to enhance the circularity of the sector, secure the supply of critical raw materials and reduce the environmental impact of batteries.

AFDIB actively supports the implementation of EPR for batteries in France, particularly for starter batteries (SLI) and industrial batteries. The association has established close dialogue with the administration, the two approved eco-organisations for these categories of batteries and all stakeholders to ensure the successful implementation of EPR in France, taking into account the specific challenges faced by players in the battery sector and ensuring harmonisation with EPR in other EU Member States.