A battery product in packaging: the three EU regimes that apply at once
Every guide you will find covers one regime. But if you sell a product that contains a battery, shipped in packaging, into the EU from outside it, three regimes bind you simultaneously, plus a fourth for consumer goods. Which they are, what each demands, and the order to tackle them in.
Reference material, not legal advice. Each answer names the regulation and article it rests on, with the date it was verified.
The three regimes
Which rules apply to my battery product at the same time? three, plus one
Packaging EPR with its per-country authorised representative (the PPWR), the battery importer duties under Regulation (EU) 2023/1542 Article 41, and battery EPR registration in every member state you sell into. If it is a consumer product, GPSR adds its Responsible Person on top. The regimes do not cancel each other out; each has its own registration, its own duties and its own enforcement.
| Regime | What it covers | Key duty for you | Since |
|---|
| Packaging EPR (PPWR) | The box, the foam, the wrap | Register per member state; authorised representative per state if you are not established there (Article 45) | AR from 12 August 2026 |
| Battery Regulation 2023/1542 | The battery itself | Importer verification, labelling, CE, your name on the product (Article 41) | Phasing in through 2027 |
| Battery EPR | The battery at end of life | Producer registration per member state before the first sale; marketplaces check the number | Checks from 18 August 2025 |
| GPSR (consumer goods) | The product as sold to consumers | EU Responsible Person, labelling, ten-year technical file | 13 December 2024 |
Why this page exists: sellers get suspended by marketplaces for one missing registration while holding two others, because each guide they read covered a different single regime.
Source: Regulation (EU) 2025/40 (PPWR) Article 45; Regulation (EU) 2023/1542 Articles 10, 41; Regulation (EU) 2023/988. Checked: 5 September 2026.
Do I need a packaging authorised representative in every country? yes, from August 2026
Yes, if you are established outside the EU: from 12 August 2026 the PPWR requires a written mandate in every member state where your packaging reaches customers. Sell into eight countries, appoint eight. The suspension you may have read about applies only to producers established inside the EU.
This is the clause sellers miss because the headlines said 'suspended': the Commission proposed deferring Article 45 for EU-established producers, not for sellers shipping in from outside. The mandate must be in writing and covers your packaging obligations in that state.
Source: Regulation (EU) 2025/40 Article 45(1) and (3); Commission communication on the deferral proposal. Checked: 5 September 2026.
What does Article 41 of the Battery Regulation demand from me? importer duties
Before placing: verify the CE marking, the technical documentation, the labelling and the manufacturer's identity. On the product: your own name and address. After: keep the documentation ten years and cooperate with market surveillance. It is the same importer logic every CE act uses, now applied to batteries.
- Labelling phases in through 2026–2027: capacity, chemistry, separate-collection symbol, and later the QR-coded information.
- Non-EU manufacturers can send an authorised representative instead, but if you import and resell, Article 41 is yours regardless.
- The battery passport (18 February 2027) applies to LMT, EV and industrial batteries above 2 kWh; most consumer batteries are out of scope for now. See the passport page.
Source: Regulation (EU) 2023/1542 Article 41, Article 13 and Annex VI labelling; Article 77 passport. Checked: 5 September 2026.
The battery EPR registration: whose job is mine? before the first sale
Distance sellers are deemed producers: register in every member state you sell into, before the first sale, exactly like packaging EPR. Marketplaces have been checking battery numbers since 18 August 2025 and suspend listings without them.
The registration is national (Germany Stiftung EAR, France, and so on), the schemes charge per tonne placed on the market, and the take-back symbol must be on the product. If you already handle packaging EPR, expect the battery register in the same countries, separately.
Source: Regulation (EU) 2023/1542 Article 10 (producer responsibility, distance sellers); marketplace compliance checks from 18 August 2025. Checked: 5 September 2026.
In which order do I tackle this? the working sequence
GPSR first (nothing sells without the Responsible Person), then battery EPR and packaging EPR registrations per country, then the Article 41 importer checks on the goods themselves, then the contract clauses (Article 45 mandates) in writing. Verification dates on everything.
- GPSR Responsible Person: without it, listings die first. The fifteen checks.
- Registers before the first sale: packaging and battery EPR per member state; the product check counts your countries.
- Goods checks under Article 41: documentation, labelling, CE, your name on it.
- The paperwork: Article 45 written mandates per country, dated screening of your suppliers with the free check, and a calendar for the 2027 dates.
Source: the regulations cited above; enforcement practice of marketplaces. Checked: 5 September 2026.