Since August 18, 2025, the scope of the EPR batteries has expanded with the implementation of European Regulation 2023/1542.

If you sell portable devices containing batteries (smartphones, electric scooters, cordless tools, connected toys), you become a direct participant in a Scheme highly regulated: CE marking, eco-fees, traceability, EPR representatives EPR foreign sellers… the regulatory framework is becoming stricter and more complex.

The following clearly explains what is changing and how to turn this regulatory requirement into a controlled process.

EPR : New Requirements for Sellers of Portable Devices.

Reading time: ~11 min

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Understanding EPR and Accumulators Under the New European Framework

Extended Producer Responsibility (EPR) is based on a simple principle: whoever places a product on the market must finance and organize the management of its waste throughout its entire life cycle, from initial use through collection to recycling.

With Regulation 2023/1542, Europe is no longer focusing solely on small portable batteries. The regulation now covers all types of batteries and establishes common rules regarding safety, environmental performance, and information requirements.

Stakeholders involved: manufacturers based in France; importers who purchase goods outside France for resale on the French market; marketplace sellers and e-commerce brands that ship products to French customers; producers not established in France who will be required to appoint an EPR agent EPR August 12, 2026.

In short, if you sell a product that contains a battery, you are almost always considered the placeholder and are therefore liable under the EPR batteries.

Which types of batteries are covered?

Main categories

• Portable batteries: smartphones, tablets, smartwatches, toys, small household appliances, and household tools (key players: e-commerce retailers, D2C brands, and mass-market retailers).

• Batteries for light vehicles (LVs): scooters, e-bikes, Segways, hoverboards (micro-mobility platforms, specialized marketplaces).

• Electric vehicle (EV) batteries: electric cars and light commercial vehicles (manufacturers, importers, and car dealers).

• SLI batteries (starting, lighting, ignition): automotive batteries for internal combustion or hybrid engines (auto repair chains, auto parts retailers).

• Industrial batteries: stationary storage, professional equipment, backup power systems (B2B suppliers, energy integrators).

Even if you only sell small portable devices, the categories “portable batteries” and “MTL batteries” are enough to make you subject to EPR.

New key requirements for sellers of portable devices

CE Marking and Placing on the Market

All batteries placed on the European market after August 18, 2025, must bear the CE marking. The seller must verify the certification, retain the technical documentation, and be able to present it in the event of an inspection. If you import products containing batteries from a third country, you are responsible for ensuring compliance.

Extended liability and environmental fees

The manufacturer is responsible for financing the end-of-life management of products. There are two options: joining an accredited eco-organization (the most common approach) or establishing an individual system approved by the authorities. In practice, this involves registering, obtaining an EPR identifier, periodically reporting quantities by category, and paying the corresponding fees. The increasing number of reporting requirements (packaging, WEEE, textiles, furniture, hazardous waste, etc.) can quickly become time-consuming.

EPR Agent EPR Foreign Sellers

Any producer or seller not established in France must appoint an EPR representative EPR France as of August 12, 2026. This representative handles registrations, prepares reports, and pays eco-contributions. CompliancR offers this service.

Removal and replacement of built-in batteries

Portable batteries must be easily removable by the end user without the need for special tools. For MTL, EV, and industrial batteries, replacement must at a minimum be possible by an independent professional. Retailers must verify compliance with their suppliers, provide clear instructions, and anticipate after-sales service returns.

Labeling and Consumer Information

Each battery must specify the chemistry used, capacity, estimated lifespan, collection and recycling instructions, the presence of any hazardous substances, and safety precautions. This information must also be available in open electronic databases.

Due Diligence in the Supply Chain

Manufacturers and distributors must implement a due diligence policy: risk assessment, supplier identification, and preventive and corrective measures. Sellers of portable devices must be able to trace the origin of the batteries.

Recycling Targets and Environmental Performance

Minimum recycling efficiency thresholds will take effect on December 31, 2027. Retailers will be required to offer take-back programs, inform consumers about collection points, and source products from manufacturers that can demonstrate strong performance in terms of recycled content.

Risks and Penalties for Noncompliance

Authorities may restrict or ban the sale of products, order the withdrawal or recall of entire batches, and impose heavy financial penalties. Marketplaces now require proof of EPR registration EPR without a registration ID, your listings may be blocked or removed.

How to Simplify Your EPR Compliance EPR

Two approaches: handle it in-house (regulatory monitoring, data management) or outsource it to an agent and a specialized platform. CompliancR automates catalog analysis, the application of fee schedules, the generation of reports, and multi-channel tracking. Sellers not established in France can also appoint CompliancR EPR agent.

FAQ on EPR Batteries

Who is considered a producer?

Any entity that places a battery or a product containing a battery on the French market for the first time: manufacturers, importers, marketplace sellers, and D2C brands.

I only sell on a marketplace—does this apply to me?

Yes. Marketplaces require your UIN Unique Digital Identifier), which is your registration number in theEPR Scheme EPR your products, and may suspend your listings in the event of non-compliance.

Do I need to join multiple eco-certification organizations if I sell different types of products?

In most cases, yes. EachEPR Scheme EPR batteries, packaging, WEEE, textiles, furniture, hazardous waste, etc.) often requires separate registration, which results in a significant administrative burden.

What are the risks to my business if I don't comply by the deadline?

Financial penalties, product recalls or withdrawals, marketing restrictions, and account suspensions on platforms. The reputational impact can also be significant.