+49 6196 5835357

info@ecopv-eu.com

🇳🇱 EPR Compliance for Batteries in the Netherlands |
Guide and Checklist 2026

Extended Producer Responsibility (EPR) for Batteries and Rechargeable Batteries – 7 Steps to Compliance + Step-by-Step Checklist

Anyone placing batteries, accumulators, or products with integrated energy storage devices on the Dutch market is subject to the statutory Extended Producer Responsibility (EPR). Companies are thus responsible for collection, proper recycling, and comprehensive reporting throughout the entire product lifecycle. With the entry into force of the new EU Battery Regulation and the organizational merger of Stibat and Stichting OPEN, compliance requirements in the Netherlands have become even stricter.

What does this mean specifically for your company?

Here are the 7 most important steps – including a checklist to get you started.

🇳🇱 EPR Compliance for Batteries in the Netherlands |
Guide and Checklist 2026

Extended Producer Responsibility (EPR) for Batteries and Rechargeable Batteries – 7 Steps to Compliance + Step-by-Step Checklist

Anyone placing batteries, accumulators, or products with integrated energy storage devices on the Dutch market is subject to the statutory Extended Producer Responsibility (EPR). Companies are thus responsible for collection, proper recycling, and comprehensive reporting throughout the entire product lifecycle. With the entry into force of the new EU Battery Regulation and the organizational merger of Stibat and Stichting OPEN, compliance requirements in the Netherlands have become even stricter.

What does this mean specifically for your company?

Here are the 7 most important steps – including a checklist to get you started.

Who is considered a “manufacturer”?

Under European and Dutch law, manufacturer status is determined by the first commercial supply to the Dutch market:

  • Companies based in the Netherlands: Produce batteries or battery-powered devices domestically and market them under their own name – or import batteries/battery-powered devices from abroad (EU or third country) and distribute them in the Netherlands.
  • Companies from other EU countries: Sell batteries or battery-powered products via distance selling (online store, marketplaces) directly to end consumers or commercial end users in the Netherlands.
  • Companies outside the EU: Deliver directly to Dutch end consumers via e-commerce. In traditional B2B supply chains, the manufacturer’s obligations are transferred to the Dutch importer.
  • White-label / private-label manufacturers: Anyone who markets devices with built-in batteries under their own label in the Netherlands is legally considered the first distributor of the batteries contained therein.
  • Marketplace operators: Under national implementing legislation, platforms such as Bol.com and Amazon.nl bear subsidiary liability for unregistered foreign sellers. They actively verify compliance and suspend accounts without proof of registration.

Practical example: A Swiss company sells e-bike batteries (LMT batteries) directly to Dutch end customers through its own online store → is considered a manufacturer → must register with Stichting OPEN → pays an annual waste disposal fee based on weight → reports the quantities placed on the market quarterly or annually via myOPEN → must report built-in batteries separately.

The 5 EU battery categories

Category

Description

Portable batteries

Encapsulated batteries up to 5 kg, not for industrial, LMT, or vehicle use

LMT batteries

E-bikes, e-scooters, e-mopeds, and similar light vehicles

Industrial batteries

All batteries for industrial purposes or weighing over 5 kg (not LMT/EV)

SLI batteries

Starter batteries (Starting, Lighting, Ignition) for motor vehicles and machinery

EV batteries

Power batteries for electric vehicles

Special case –  Industrial batteries: Since there is not yet a fully developed, nationwide collective system in the Netherlands for the new, broad EU category of industrial batteries, a special legal provision applies.

As of August 18, 2025, manufacturers and importers of industrial batteries in the Netherlands are legally required to submit an individual authorization and registration request directly to the government agency Rijkswaterstaat.

The 7 Most Important Steps for EPR Compliance in the Netherlands

Step 1: Appoint an Authorized Representative (for foreign companies)

For companies outside the EU, it is mandatory to appoint an authorized representative based in the Netherlands if they sell directly to Dutch customers. The authorized representative assumes full legal and financial responsibility for registration, volume reporting, and payment of contributions.

For companies from other EU countries, appointing an authorized representative in the Netherlands is not required. Thanks to the highly centralized system, foreign online retailers can register directly on the Stichting OPEN portal – without intermediaries – when making direct sales to Dutch end consumers. The collective organization handles legal coverage and automatic reporting to the National Register (NWR) directly as part of the standardized system enrollment.

Requirements for the authorized representative:

  • Headquarters in the Netherlands
  • Written power of attorney agreement in Dutch or English
  • Signed by authorized representatives of both parties
  • A Hague Apostille is not required as a standard

Step 2: Correctly classify the battery category and identify the responsible organization

Choosing the right organization depends on the battery category. Incorrect classification can lead to duplicate reports, missing reports, or compliance gaps.

Is the battery built into the end product or separate?
→ Built-in batteries: Record separately from the WEEE report and report to Stichting OPEN

Which category?
→ Portable (up to 5 kg, not LMT/EV/industrial use)
→ LMT (e-bike, e-scooter, light vehicle)
→ SLI (automotive starter battery)
→ EV (electric vehicle drive)
→ Industrial (>5 kg, industrial use)

Note on dual registration (WEEE + battery): Devices with built-in batteries (e.g., laptops, smartphones, power tools) require both registrations: WEEE EPR for the device (Stichting OPEN) and battery EPR for the built-in battery (also Stichting OPEN via myOPEN). Integrated batteries and rechargeable batteries must be reported separately.

Step 3: Register with the relevant Producer Organization

For portable batteries and LMT/bicycle batteries: Stichting OPEN

As of January 1, 2024, Stibat has been fully integrated into Stichting OPEN. New registrations for portable batteries and LMT/e-bike batteries are handled exclusively through the myOPEN portal.

Procedure:

  1. Online registration on the myOPEN portal (my.stichting-open.org)
  2. Signing the ABBO (Afvalbeheerbijdrageovereenkomst)
  3. Automatic forwarding of registration data to the national battery registry
  4. Inclusion in the public list of manufacturers on stichting-open.org

For SLI and EV batteries: ARN (Auto Recycling Nederland)
Propulsion (EV) and starter batteries (SLI) for motor vehicles are subject to Extended Producer Responsibility through ARN. As of April 1, 2026, the statutory recycling fee will also apply mandatorily to the commercial import of used vehicles with electric or hybrid propulsion. Manufacturers and importers are therefore required to properly register the batteries via the ARN portal.

Step 4: Financial Obligations & Contribution Structure

The Afvalbeheerbijdrage (waste management fee) is calculated per kilogram or per unit of batteries placed on the market. The rates are set annually by Stichting OPEN and published in the Battery Product and Rate List (separately for devices and lamps).

Calculation basis:

Weight in kg (or number of units) × rate per battery category and chemical composition

 

Differentiation criteria:

CriteriaDetails
Battery categoryPortable, LMT/EPAC, SLI, EV, Industrial – separate rates
Chemical composition

Lithium-ion, lead-acid, nickel-cadmium (NiCd), NiMH are assessed differently

B2C vs. B2BSeparate reporting; B2B rates may be reduced
Advance paymentThose who pay more than €6,000 in waste management fees on an annual basis must make monthly advance payments

Eco-modulation: Stichting OPEN applies eco-modulation criteria. Batteries that are easily removable from devices or that demonstrably contain a high proportion of recycled materials may be eligible for fee reductions.

Step 5: Reporting Requirements & New EU Regulations

Volume Reporting (Basic Requirement)

All manufacturers and importers must report their Put on Market (POM) data via the myOPEN portal. Stichting OPEN automatically notifies members by email when the report is ready to be submitted.

Report content:

  • Weight (kg) and quantity of batteries placed on the market in the Netherlands for the first time
  • Breakdown by battery category and chemical composition
  • Separation by B2C and B2B status
  • Separately: built-in batteries in EEE devices

CO₂ footprint declaration: In the Netherlands, the CO₂ footprint declaration applies to industrial, e-bike, and electric vehicle batteries with a capacity of 2 kWh or more.

The EU Battery Due Diligence Regulation will become mandatory in the Netherlands as of August 18, 2027, for all economic operators with an annual turnover exceeding 150 million euros. It requires large companies to assess their supply chains for social and environmental risks.

Step 6: Labeling Requirements

  1. Crossed-out wheelie bin: As of August 18, 2025, in accordance with the EU Battery Regulation, all batteries and rechargeable batteries placed on the market must be labeled with the symbol for separate collection.
  2. Nominal capacity indication: Mandatory for all portable batteries and SLI/automotive batteries – in mAh, Ah, or Wh. This information must appear directly on the battery or, if space is limited, on the packaging.
  3. Chemical labeling (Pb / Cd): If a battery exceeds the legal limits – lead (>0.004% by weight) or cadmium (>0.002% by weight) – the corresponding chemical symbol (Pb or Cd) must be displayed below the crossed-out trash can.
  4. Labeling for Non-Rechargeable Batteries (effective August 2026): Starting August 18, 2026, non-rechargeable portable batteries must bear a label indicating their minimum average operating time in specific applications, as well as the statement “non-rechargeable.”

Step 7: Take-back Obligations & Collection Targets

As a member of Stichting OPEN, the manufacturer is indirectly involved in meeting national collection and recycling targets. Starting in 2024, Stichting OPEN’s Wecycle trademark will centralize the collection of e-waste and batteries. All 30,000 existing battery drop-off points will remain in place.

Take-back obligation for retailers: Retailers and online sellers who sell batteries are required to accept used batteries free of charge – regardless of whether the consumer makes a purchase. Stichting OPEN membership collectively funds this take-back obligation.

Who is considered a “manufacturer”?

Under European and Dutch law, manufacturer status is determined by the first commercial supply to the Dutch market:

  • Companies based in the Netherlands: Produce batteries or battery-powered devices domestically and market them under their own name – or import batteries/battery-powered devices from abroad (EU or third country) and distribute them in the Netherlands.
  • Companies from other EU countries: Sell batteries or battery-powered products via distance selling (online store, marketplaces) directly to end consumers or commercial end users in the Netherlands.
  • Companies outside the EU: Deliver directly to Dutch end consumers via e-commerce. In traditional B2B supply chains, the manufacturer’s obligations are transferred to the Dutch importer.
  • White-label / private-label manufacturers: Anyone who markets devices with built-in batteries under their own label in the Netherlands is legally considered the first distributor of the batteries contained therein.
  • Marketplace operators: Under national implementing legislation, platforms such as Bol.com and Amazon.nl bear subsidiary liability for unregistered foreign sellers. They actively verify compliance and suspend accounts without proof of registration.

Practical example: A Swiss company sells e-bike batteries (LMT batteries) directly to Dutch end customers through its own online store → is considered a manufacturer → must register with Stichting OPEN → pays an annual waste disposal fee based on weight → reports the quantities placed on the market quarterly or annually via myOPEN → must report built-in batteries separately.

The 5 EU battery categories

1. Portable batteries: Encapsulated batteries up to 5 kg, not for industrial, LMT, or vehicle use

2. LMT batteries: E-bikes, e-scooters, e-mopeds, and similar light vehicles

3. Industrial batteries: All batteries for industrial purposes or weighing over 5 kg (not LMT/EV)

4. SLI batteries: Starter batteries (Starting, Lighting, Ignition) for motor vehicles and machinery

5. EV batteries: Power batteries for electric vehicles

Special case –  Industrial batteries: Since there is not yet a fully developed, nationwide collective system in the Netherlands for the new, broad EU category of industrial batteries, a special legal provision applies.

As of August 18, 2025, manufacturers and importers of industrial batteries in the Netherlands are legally required to submit an individual authorization and registration request directly to the government agency Rijkswaterstaat.

The 7 Most Important Steps for EPR Compliance in the Netherlands

Step 1: Appoint an Authorized Representative (for foreign companies)

For companies outside the EU, it is mandatory to appoint an authorized representative based in the Netherlands if they sell directly to Dutch customers. The authorized representative assumes full legal and financial responsibility for registration, volume reporting, and payment of contributions.

For companies from other EU countries, appointing an authorized representative in the Netherlands is not required. Thanks to the highly centralized system, foreign online retailers can register directly on the Stichting OPEN portal – without intermediaries – when making direct sales to Dutch end consumers. The collective organization handles legal coverage and automatic reporting to the National Register (NWR) directly as part of the standardized system enrollment.

Requirements for the authorized representative:

  • Headquarters in the Netherlands
  • Written power of attorney agreement in Dutch or English
  • Signed by authorized representatives of both parties
  • A Hague Apostille is not required as a standard

Step 2: Correctly classify the battery category and identify the responsible organization

Choosing the right organization depends on the battery category. Incorrect classification can lead to duplicate reports, missing reports, or compliance gaps.

Is the battery built into the end product or separate?
→ Built-in batteries: Record separately from the WEEE report and report to Stichting OPEN

Which category?
→ Portable (up to 5 kg, not LMT/EV/industrial use)
→ LMT (e-bike, e-scooter, light vehicle)
→ SLI (automotive starter battery)
→ EV (electric vehicle drive)
→ Industrial (>5 kg, industrial use)

Note on dual registration (WEEE + battery): Devices with built-in batteries (e.g., laptops, smartphones, power tools) require both registrations: WEEE EPR for the device (Stichting OPEN) and battery EPR for the built-in battery (also Stichting OPEN via myOPEN). Integrated batteries and rechargeable batteries must be reported separately.

Step 3: Register with the relevant Producer Organization

For portable batteries and LMT/bicycle batteries: Stichting OPEN

As of January 1, 2024, Stibat has been fully integrated into Stichting OPEN. New registrations for portable batteries and LMT/e-bike batteries are handled exclusively through the myOPEN portal.

Procedure:

  1. Online registration on the myOPEN portal (my.stichting-open.org)
  2. Signing the ABBO (Afvalbeheerbijdr
    ageovereenkomst)
  3. Automatic forwarding of registration data to the national battery registry
  4. Inclusion in the public list of manufacturers on stichting-open.org

For SLI and EV batteries: ARN (Auto Recycling Nederland)
Propulsion (EV) and starter batteries (SLI) for motor vehicles are subject to Extended Producer Responsibility through ARN. As of April 1, 2026, the statutory recycling fee will also apply mandatorily to the commercial import of used vehicles with electric or hybrid propulsion. Manufacturers and importers are therefore required to properly register the batteries via the ARN portal.

Step 4: Financial Obligations & Contribution Structure

The Afvalbeheerbijdrage (waste management fee) is calculated per kilogram or per unit of batteries placed on the market. The rates are set annually by Stichting OPEN and published in the Battery Product and Rate List (separately for devices and lamps).

Calculation basis:

Weight in kg (or number of units) × rate per battery category and chemical composition

 

Differentiation criteria:

Battery category: Portable, LMT/EPAC, SLI, EV, Industrial – separate rates

Chemical composition: Lithium-ion, lead-acid, nickel-cadmium (NiCd), NiMH are assessed differently

B2C vs. B2B: Separate reporting; B2B rates may be reduced

Advance payment: Those who pay more than €6,000 in waste management fees on an annual basis must make monthly advance payments

Eco-modulation: Stichting OPEN applies eco-modulation criteria. Batteries that are easily removable from devices or that demonstrably contain a high proportion of recycled materials may be eligible for fee reductions.

Step 5: Reporting Requirements & New EU Regulations

Volume Reporting (Basic Requirement)

All manufacturers and importers must report their Put on Market (POM) data via the myOPEN portal. Stichting OPEN automatically notifies members by email when the report is ready to be submitted.

Report content:

  • Weight (kg) and quantity of batteries placed on the market in the Netherlands for the first time
  • Breakdown by battery category and chemical composition
  • Separation by B2C and B2B status
  • Separately: built-in batteries in EEE devices

CO₂ footprint declaration: In the Netherlands, the CO₂ footprint declaration applies to industrial, e-bike, and electric vehicle batteries with a capacity of 2 kWh or more.

The EU Battery Due Diligence Regulation will become mandatory in the Netherlands as of August 18, 2027, for all economic operators with an annual turnover exceeding 150 million euros. It requires large companies to assess their supply chains for social and environmental risks.

Step 6: Labeling Requirements

  1. Crossed-out wheelie bin: As of August 18, 2025, in accordance with the EU Battery Regulation, all batteries and rechargeable batteries placed on the market must be labeled with the symbol for separate collection.
  2. Nominal capacity indication: Mandatory for all portable batteries and SLI/automotive batteries – in mAh, Ah, or Wh. This information must appear directly on the battery or, if space is limited, on the packaging.
  3. Chemical labeling (Pb / Cd): If a battery exceeds the legal limits – lead (>0.004% by weight) or cadmium (>0.002% by weight) – the corresponding chemical symbol (Pb or Cd) must be displayed below the crossed-out trash can.
  4. Labeling for Non-Rechargeable Batteries (effective August 2026): Starting August 18, 2026, non-rechargeable portable batteries must bear a label indicating their minimum average operating time in specific applications, as well as the statement “non-rechargeable.”

Step 7: Take-back Obligations & Collection Targets

As a member of Stichting OPEN, the manufacturer is indirectly involved in meeting national collection and recycling targets. Starting in 2024, Stichting OPEN’s Wecycle trademark will centralize the collection of e-waste and batteries. All 30,000 existing battery drop-off points will remain in place.

Take-back obligation for retailers: Retailers and online sellers who sell batteries are required to accept used batteries free of charge – regardless of whether the consumer makes a purchase. Stichting OPEN membership collectively funds this take-back obligation.

Step-by-Step Checklist

(a) Companies based in the Netherlands

1. Correctly classify batteries into the 5 EU categories

2. Determine the responsible organization: Stichting OPEN (portable/LMT), ARN (SLI/EV)

3. Complete registration on the myOPEN portal and sign the ABBO (for portable/LMT)

4. For EV batteries: Sign the ARN contract

5. For industrial batteries: Collect data and prepare an individual registration with Rijkswaterstaat

6. Record built-in batteries in EEE devices separately from the WEEE report and report them to Stichting OPEN

7. Submit quarterly POM report via myOPEN (weight, quantity, chemistry, B2C/B2B)

8. Calculate the waste management fee and pay it on time (advance payments starting at €6,000/year)

9. Document and declare the CO₂ footprint for EV batteries

10. Prepare the CO₂ footprint for industrial batteries >2 kWh

11. Check labeling: trash can symbol + capacity indication + chemical symbols on all batteries

12. Retain records for 7 years for ILT audits

(b) Companies from other EU countries

1. Check distribution channel: Direct sales to Dutch end customers → proceed to step 2

2. Appoint an authorized representative or engage an EPR service provider (agreement in Dutch or English)

3. Complete registration with Stichting OPEN or ARN

4. Submit proof of compliance to marketplaces (Amazon.nl, Bol.com)

5. Ensure structured data: Weight based on chemical composition and battery category for volume reporting

6. Check CO₂ declaration requirements by battery category and timeline, and prepare data

7. Check labeling requirements on all products for the Dutch market

(c) Companies from third countries (outside the EU)

1. Option A – Delivery to a Dutch importer (B2B): Submit all product and weight data (category, chemical composition, quantity) in a timely manner – the importer becomes the legal manufacturer.

2. Option B – Direct B2C sales without a Dutch intermediary: Appoint an authorized representative in the Netherlands (mandatory); complete all steps from checklist (b) through this representative.

3. Customs declaration: Ensure that the battery data (category, weight, chemistry) is correctly assigned to the manufacturer’s or importer’s Stichting OPEN or ARN member account.

4. Ensure proof of compliance on all Dutch marketplaces.

Step-by-Step Checklist

(a) Companies based in the Netherlands

1. Correctly classify batteries into the 5 EU categories

2. Determine the responsible organization: Stichting OPEN (portable/LMT), ARN (SLI/EV)

3. Complete registration on the myOPEN portal and sign the ABBO (for portable/LMT)

4. For EV batteries: Sign the ARN contract

5. For industrial batteries: Collect data and prepare an individual registration with Rijkswaterstaat

6. Record built-in batteries in EEE devices separately from the WEEE report and report them to Stichting OPEN

7. Submit quarterly POM report via myOPEN (weight, quantity, chemistry, B2C/B2B)

8. Calculate the waste management fee and pay it on time (advance payments starting at €6,000/year)

9. Document and declare the CO₂ footprint for EV batteries

10. Prepare the CO₂ footprint for industrial batteries >2 kWh

11. Check labeling: trash can symbol + capacity indication + chemical symbols on all batteries

12. Retain records for 7 years for ILT audits

(b) Companies from other EU countries

1. Check distribution channel: Direct sales to Dutch end customers → proceed to step 2

2. Appoint an authorized representative or engage an EPR service provider (agreement in Dutch or English)

3. Complete registration with Stichting OPEN or ARN

4. Submit proof of compliance to marketplaces (Amazon.nl, Bol.com)

5. Ensure structured data: Weight based on chemical composition and battery category for volume reporting

6. Check CO₂ declaration requirements by battery category and timeline, and prepare data

7. Check labeling requirements on all products for the Dutch market

(c) Companies from third countries (outside the EU)

1. Option A – Delivery to a Dutch importer (B2B): Submit all product and weight data (category, chemical composition, quantity) in a timely manner – the importer becomes the legal manufacturer.

2. Option B – Direct B2C sales without a Dutch intermediary: Appoint an authorized representative in the Netherlands (mandatory); complete all steps from checklist (b) through this representative.

3. Customs declaration: Ensure that the battery data (category, weight, chemistry) is correctly assigned to the manufacturer’s or importer’s Stichting OPEN or ARN member account.

4. Ensure proof of compliance on all Dutch marketplaces.

Are you planning to sell your products in the Netherlands?

We’ll help you ensure compliance with Dutch EPR regulations for batteries so you can get started with legal certainty.

Are you planning to sell your products in the Netherlands?

We’ll help you ensure compliance with Dutch EPR regulations for batteries so you can get started with legal certainty.

Contact

We look forward to your message!

info@ecopv-eu.com

+49 6196 5835357

Frankfurter Str. 70-72
65760 Eschborn

Contact

We look forward to your message!

info@ecopv-eu.com

+49 6196 5835357

Frankfurter Str. 70-72
65760 Eschborn