New EU Battery Regulation Impact on Pan-EU Sellers
The New EU Battery Regulation (2023/1542) has introduced important changes for online sellers, particularly Amazon sellers who use Pan-EU operations. This rule has a direct impact on sellers operating in European markets, including registration requirements and compliance obligations. Understanding its implications is essential to maintaining uninterrupted sales and avoiding penalties.
Who needs to register the New EU Battery Regulation?
The EU Batteries Regulation aims to enhance the sustainability and safety of batteries by making producers of batteries responsible for take-back, recycling and final disposal. If you are considered a producer of batteries or products containing batteries under the EU Batteries Regulation, you must follow EPR requirements by registering in each EU country where you sell such products, and providing the registration numbers to Amazon through the new Compliance Portal for Batteries on the Account Health page of Seller Central. Amazon is obligated to check your EPR Compliance by August 18, 2025.
You are considered a "producer" of batteries if you are a manufacturer, importer or distributor or other natural or legal person who, irrespective of the selling technique used (including by means of distance contracts):
- is established in an EU member state and resells batteries or products containing batteries within the territory of that member state, under your own name or trademark; or
- is established in an EU member state and resells batteries or products containing batteries within the territory of that country, under your own company name or trademark (batteries on which the name or trademark of the manufacturers do not appear); or
- is established in an EU member state and supplies batteries or products containing batteries for the first time in that member state on a professional basis, from another member state or from a third country; or
- sells batteries or products containing batteries, by means of distance contracts directly to end-users (whether or not they are private households), and is established in another EU member state (not the country of sale) or in a third country.
What is the situation if you are considered as a “non-producer”? If you are a company established in an EU country, reselling batteries or battery-containing products within this country, using the original manufacturer's name or trademark rather than your own, and you're not the manufacturer or importer, you don't need to register the Battery Regulation. However, you must obtain a minimum of one registration number from your upstream supplier (who is the "producer") and submit that for each country where you sell batteries or products containing batteries. If you are using multiple suppliers, you are required to provide their registration numbers to Amazon through a declaration by contacting the Selling Partner Support.
Different Registration and Reporting Requirements by Country
The EU Battery Regulation imposes varying registration and reporting obligations depending on the country:
- Strict Registration Countries: Germany, Sweden, Poland, and the Netherlands require mandatory registration; failure to comply will result in sales suspension.
- Countries Allowing Amazon Pay-on-Behalf Services: In France and Belgium, Amazon can deduct recycling fees on your behalf after registration.
- Pending Confirmation Countries: Spain and Italy are still finalizing their processes with national authorities, so sellers should monitor Amazon updates for these countries.
How Amazon Sellers Upload Battery Registration Numbers？
To support compliance with the EU Battery Regulation, Amazon has opened dedicated entry points on its European marketplaces for sellers to upload their Battery EPR registration numbers. This is necessary for both new and existing Pan-EU sellers.
- If you sell batteries or products containing batteries in Germany, Sweden, Poland or Netherlands, you will be able to submit registration numbers through two options:
- The first option is submitting your registration number via“Regulatory Compliance” in the Amazon Compliance Portal. This option allows you to view a dashboard showing where your registration number submission is required or pending.
- The second option is also available in all other EU countries, provide your information via “Submit compliance information” in the Amazon Compliance Portal. With this option, you won't have access to an overall dashboard and will need to proactively track registration number status for each country where you sell batteries.
- If you sell batteries or products containing batteries in Spain, Italy or Belgium, you can only submit your information via “Submit compliance information” in the Amazon Compliance Portal. In this portal experience, you will not see upfront products for which registration submission is still pending. You will have to track the products and countries where you have not yet submitted registration numbers.
The consequences of non-compliance vary by EU country and are based on country regulations, some of which are still being adapted. If you are considered non-compliant, Amazon will need to deactivate your non-compliant offers in Germany, Netherlands, Poland and Sweden from August 18, 2025. Other EU country regulations may permit Pay-on-Behalf Services from Amazon in future; currently this is available for France.
Registration Pitfalls in the EU Battery Regulation
While the regulation aims to harmonize standards across the EU, sellers must pay close attention to the specific requirements of each country. Here are some common pitfalls to avoid:
EPR and WEEE Numbers Are Not Interchangeable
The Battery EPR registration number is distinct from the WEEE registration number, even if both cover similar environmental responsibilities. Sellers must apply for these separately to avoid compliance errors.
Special Note for the Netherlands: While the Battery and WEEE registration numbers in the Netherlands currently share the same identifier (e.g., “activated Battery/WEEE number”), they still require separate registration processes. Successfully obtaining a Battery EPR registration number does not automatically apply to WEEE compliance, which must be applied for independently to ensure regulatory adherence.
Separate Registration for Resellers
Resellers are treated as producers under the regulation. This means they must complete their own EPR registration in each country they sell to, even if their upstream suppliers already hold an EPR registration number.
Mismatch in Registration Entities
Sellers must ensure the entity listed on their EPR registration matches their Amazon account details. Any discrepancies could lead to rejected registrations and potential listing issues.
No “One Registration for All”
Unlike some EU initiatives, the Battery EPR registration is not a one-size-fits-all solution. Sellers must register in each country individually, adhering to specific local requirements. Missing registration in one country could lead to penalties and listing removals.
Impact on Pan-EU sellers
For sellers using Amazon's Pan-EU fulfillment services, battery EPR registration in the Netherlands, Poland, and Sweden is closely tied to participation in the program. Starting from June 25, 2025, new ASINs added to the Pan-EU program must not only comply with registration requirements in Germany, France, Italy, and Spain but also be listed and maintain sellable status in the Netherlands. Sellers who have already joined the Pan-EU program must ensure your listings remain active in the Netherlands to retain your participation.
It’s important to note that registration under the EU Battery Regulation is mandatory. This means that if you don't complete the battery EPR registration in the Netherlands, your products can't be sold there and will lose their eligibility for the Pan-EU program. Sellers risk losing the Pan-EU benefits, such as local fulfillment cost reductions and faster delivery services.
Similarly, Poland and Sweden are key nodes in the Pan-EU logistics network. Non-compliance with the battery EPR in these countries can lead to products being deemed non-compliant, potentially resulting in listing removals or sales suspensions. You can refer to this VATAi's article to learn the details of the Pan-EU program update.
Essential Compliance Requirements for Battery Products
In addition to uploading battery registration numbers, online sellers must also ensure your battery products meet the following compliance requirements:
Product Certification:
Products containing batteries must have a CE mark and associated documentation proving compliance with EU standards.
Labeling:
All battery products must display bin symbols. The Battery Regulation requires battery products producer have to provide information of battery health and lifespan. By 2026, all batteries sold in the EU must include manufacturing dates, chemical composition, and key safety data.
Declaration of Conformity (DoC):
Sellers must issue a Declaration of Conformity confirming follow EU battery laws and keep all related documentation and test reports. From February 18, 2027, Industrial batteries and Electric vehicle batteries will display unique serial numbers to track production and recycling.
Environmental Standards:
Batteries must comply with RoHS directives. Sellers must also ensure proper recycling and disposal, either by joining approved recycling organizations or setting up your own systems to meet EU requirements.
In terms of the details of New EU Battery Regulations, please refer to this VATAi's blog of Batteries Regulation Compliance Guide for Amazon Sellers
VATAi can provide professional assistance to support your Battery Regulation compliance and Pan-EU operations.
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