Battery EPR, from the waste stream up.
Extended Producer Responsibility makes the producer of a battery responsible for financing and organising what happens to it at end of life. Most advisers approach EPR from the boardroom down. RAW TG approaches it from the waste stream up — because the evidence EPR runs on is created where batteries are collected, treated, traded and recovered.
Understand it below. Or simply hand it to us.
This page explains battery EPR plainly, because producers deserve to know what they're carrying. But you don't have to run it yourself: RAW TG discharges the obligation as a single partner — the Authorised Representative appointments, the registrations and declarations, the fees, and the physical recycling and digital evidence that stand behind them.
What battery EPR means in the UK today.
In the UK, producer responsibility for batteries broadly derives from the Waste Batteries and Accumulators Regulations 2009. The framework is compact, but the obligations are real — and they run on evidence generated by the treatment and recycling chain RAW TG trades within.
Producers placing batteries on the UK market are expected to register, report the batteries they place on the market, and — for larger portable-battery producers — join a battery compliance scheme that finances the collection, treatment and recycling of an equivalent share of waste batteries. Distributors above a threshold provide in-store take-back.
The part most producers never see is where the obligation is actually discharged: at approved battery treatment operators and approved battery exporters, whose evidence of treatment and recycling is what compliance schemes ultimately count. That is the end of the chain RAW TG works in every day — and it is why our view of EPR starts with the material, not the paperwork.
Industrial and automotive batteries carry their own duties, including free take-back of waste industrial batteries on request. Battery chemistry, classification and documentation determine how each stream is treated — the same disciplines that govern every RAW TG trade.
| Obligation | Who carries it |
|---|---|
| Producer registration & reporting | Anyone placing batteries on the UK market |
| Compliance scheme membership | Larger portable-battery producers (financing collection & recycling) |
| Distributor take-back | Retailers above the supply threshold |
| Treatment & recycling evidence | Approved battery treatment operators & approved exporters |
| Industrial battery take-back | Producers of industrial batteries, on request |
Summarised as context, not legal advice. Obligations depend on battery type, volumes and role in the chain, and each party remains responsible for its own compliance.
UK batteries EPR is being rebuilt — and the direction is clear.
The 2009 regulations were written for a market of AA cells and car batteries. They were not written for e-bikes, power tools, EVs and grid storage — and DEFRA has signalled reform of the UK batteries regime to catch up.
The consistent themes across UK reform thinking and the EU's new framework are the same: broader producer categories that reflect modern chemistries and formats, more ambitious collection and recovery expectations, tighter rules on exports and evidence, and digital reporting in place of annual paper returns.
For producers and compliance schemes, the practical consequence is simple: the quality of your evidence becomes the quality of your compliance. Organisations whose material already moves on documented, auditable routes will absorb reform as an update. Those relying on reconstructed paperwork will feel it as a shock.
- Producer categories that reflect today's chemistries and formats.
- Higher collection ambition, especially for lithium-ion streams.
- Tighter control of exported evidence and end destinations.
- Digital tracking and reporting as the default, not the exception.
- Convergence with the EU Battery Regulation's lifecycle approach.
Reform is a moving target. Proposals evolve through consultation; specifics here describe the direction of travel rather than settled law. Read our analysis of UK batteries EPR reform →
The EU Battery Regulation: EPR for the whole battery lifecycle.
Regulation (EU) 2023/1542 replaced the old Batteries Directive with a single regulation covering the entire lifecycle — carbon footprint, due diligence, recycled content, collection, recovery and the digital battery passport. Its extended producer responsibility obligations have applied since 18 August 2025.
Registration in every market
Producers register in each member state where they make batteries available, appointing an authorised representative where they have no establishment.
Financing end of life
Producers finance separate collection, transport, treatment and recycling of waste batteries — including the streams that arrive mixed, damaged or unbranded.
Due diligence & reporting
Larger economic operators adopt supply-chain due diligence policies covering raw materials risks, with third-party verification and public reporting.
The regulation also rewrote the categories — adding light means of transport (LMT) batteries alongside portable, automotive (SLI), industrial and EV — so obligations now track how batteries are actually used. For anyone holding or trading battery material, the message is that every category now has a numbered destiny: a collection target, a recycling efficiency, a recovery rate and, eventually, a recycled-content quota.
The numbers, on a timeline.
The EU Battery Regulation phases in through 2036. These are the headline milestones the battery value chain is planning around — and the dates behind every serious feedstock, recycling and passport conversation we have.
Regulation applies
Regulation (EU) 2023/1542 applies, replacing the Batteries Directive with a lifecycle framework covering production, use and end of life.
Carbon footprint declarations begin
Carbon-footprint declarations for EV batteries were slated here — but the methodology delegated act is delayed, and declarations now apply 12 months after it enters into force. Performance classes and thresholds follow later.
EPR & due diligence obligations apply
Extended producer responsibility obligations apply across member states — producer registration and financing of collection become live compliance questions. Supply-chain due diligence, originally due here, was postponed to 18 August 2027 by the 2025 Omnibus.
First recycling-efficiency targets
Recyclers must achieve minimum recycling efficiencies by weight: broadly 65% for lithium-based batteries, 75% for lead-acid, 80% for nickel-cadmium and 50% for other waste batteries.
The digital battery passport
EV, LMT and industrial batteries above 2 kWh placed on the EU market must carry a digital battery passport, accessible via QR code. See how RAW TG approaches the passport.
Collection & recovery step up
Portable battery collection target rises to 63%. Material-recovery targets apply to recycled streams: broadly 90% for cobalt, copper, lead and nickel, and 50% for lithium.
LMT collection targets begin
A dedicated 51% collection target applies for light means of transport batteries — the e-bike and e-scooter streams growing fastest in the waste system.
Higher efficiency, recovery and collection
Recycling efficiency rises to 70% for lithium-based and 80% for lead-acid batteries, and portable collection reaches 73% (end-2030). LMT collection reaches 61%, and recovery targets rise to 95% for cobalt, copper, lead and nickel and 80% for lithium (end-2031).
Recycled content becomes mandatory
New industrial, EV and SLI batteries must declare minimum recycled content: broadly 16% cobalt, 85% lead, 6% lithium and 6% nickel — rising again from 2036. Recovered material stops being optional and becomes a bill-of-materials requirement.
Why traders care about these numbers. Recycled-content quotas mean manufacturers must buy verified recovered material. Recovery targets mean recyclers must prove what they extracted. Both depend on documented, auditable chains of custody — which is precisely what a RAW TG trade produces. Figures are stated as headline milestones; transitional detail and delegated acts refine them, and they should be verified against the regulation for any specific decision.
How a documented trade becomes EPR-grade evidence.
EPR systems run on proof: proof of collection, proof of treatment, proof of recovery, proof of export done properly. Every RAW TG trade generates that proof as a by-product of running the trade on our platform — not as an after-the-fact reconstruction.
Material assessed
Chemistry, classification and condition established up front — the same data EPR categories and evidence depend on.
Movement documented
Digital duty of care, transfer documentation and timestamped custody captured as the material moves.
Treatment evidenced
Receipt, inspection and assay at the destination close the loop on what was actually treated and recovered.
Evidence retrievable
One auditable record per consignment — the shape of answer producers, schemes and regulators ask for.
For producers & OEMs
- End-of-life evidence you can put in front of a scheme or auditor.
- A route from EPR financing to verified recycled content.
- Passport-ready lifecycle data from the waste-stream end.
For compliance schemes
- Treatment and export routes documented movement by movement.
- Provenance questions answered from a system of record.
- Visibility of where evidence actually comes from.
For recyclers & exporters
- Feedstock routed with the documentation already attached.
- Recovery and efficiency data captured where it is created.
- Cross-border movements handled inside the TFS regime.
Battery EPR, answered.
What is Extended Producer Responsibility for batteries?
EPR is the principle that whoever places a battery on the market is responsible for financing and organising its end of life — collection, treatment and recycling. In the UK this broadly derives from the Waste Batteries and Accumulators Regulations 2009; in the EU it now sits inside Regulation (EU) 2023/1542, whose EPR obligations have applied since August 2025.
Who counts as a "producer" of batteries?
Broadly, anyone who first places a battery on a national market — including batteries inside appliances and vehicles, and including distance sellers. Under the EU regulation, producers without an establishment in a member state appoint an authorised representative there. Precise scope depends on the jurisdiction and how the battery reaches the market.
What are battery compliance schemes, and what evidence do they need?
Compliance schemes discharge producers' collection and recycling obligations collectively. What they ultimately count is evidence of treatment and recycling issued at approved treatment operators and approved exporters. That evidence is generated in the treatment and trading chain — which is why documented chain-of-custody at the material level matters so much to scheme integrity.
How does EPR connect to the battery passport and recycled content?
They are the same lifecycle seen from different ends. EPR finances collection and recycling; recovery targets require recyclers to prove what they extracted; recycled-content quotas from 2031 require manufacturers to buy that verified material back; and the battery passport carries the data across the whole loop. Unbroken chain-of-custody is the thread that makes all four work.
Is RAW TG a compliance scheme or an EPR consultancy?
Neither. RAW TG is a trading business that buys, manages and routes battery materials — and because every trade runs on our digital platform, it produces the documented, auditable evidence that EPR systems depend on. We describe a capability; producers, schemes and counterparties remain responsible for their own regulatory obligations.
Do the EU targets apply in the UK?
Not directly — the UK has its own regime, currently the 2009 regulations, with reform signalled. But any UK business selling into the EU meets the EU rules for those products, and UK reform thinking points in the same direction: higher collection ambition, tighter evidence and digital tracking. Planning against the EU timeline is the prudent baseline either way.
EPR runs on evidence. We generate it every trade.
Whether you are a producer facing new obligations, a scheme testing its evidence chain, or a recycler proving recovery — talk to the desk that lives where the evidence is made.
Accuracy & scope
This page summarises UK and EU battery producer-responsibility frameworks as context for RAW TG's trading and traceability capability. It is not legal or regulatory advice; figures and dates are stated as headline milestones and may be refined by transitional provisions, delegated acts and future reform. Producers, schemes and counterparties remain responsible for their own obligations and should verify requirements against the applicable legislation.