EPR Compliance for Batteries in France |
Guide and Checklist 2026

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

Batteries and accumulators are one of the most heavily regulated product segments in France – and since August 2023, the new EU Battery Regulation 2023/1542 has also been in effect, gradually replacing the old Battery Directive and fully superseding it as of August 18, 2025.

The result: more categories, new reporting requirements, CO₂ footprint declarations, and increased demands for supply chain transparency. Anyone placing batteries or battery-powered devices on the French market faces a dense regulatory framework – one that will continue to evolve through 2028.

Here are the 7 most important steps to compliance – including a checklist

EPR Compliance for Batteries in France |
Guide and Checklist 2026

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

Here are the 7 most important steps to compliance – including a checklist

Who is considered a “producteur”?

Under the Extended Producer Responsibility (EPR) scheme for batteries in France, a “producteur” is any natural or legal person who, for the first time, places batteries or products containing batteries on the French market on a commercial basis.

Specifically, this applies to:

Based in France: Produces batteries or has them manufactured under their own name/brand and places them on the market in France for the first time.
Importer: Imports batteries or battery-powered devices from abroad (EU or third country) into France – and thereby assumes the EPR obligations of the original manufacturer.
Distance Selling / E-Commerce: Companies based in other EU countries or third countries that sell directly to French end consumers (including marketplace sales).
Distributors of devices with built-in batteries: Anyone who sells electrical and electronic equipment (WEEE) with permanently installed or included batteries is also considered the producer of the batteries contained in the equipment, regardless of whether they sell the batteries separately.

Practical example: An Austrian company sells electric scooters (LMT batteries) directly to French end consumers via its own website → is considered a producer → must appoint an authorized representative → requires an IDU and membership in an approved environmental organization

Overview of Battery Categories

The EU Battery Regulation 2023/1542 defines five categories that are reported and priced separately in France:

Category	Description	Typical Examples
Portable batteries	Under 5 kg, portable, for general consumer products	AA/AAA batteries, coin cells, laptop batteries, smartphone batteries
LMT batteries	Light-duty vehicles	E-bike batteries, e-scooter batteries, hoverboards
Starter batteries / SLI batteries	Starting, Lighting, Ignition	Automotive starter batteries
Industrial batteries	Large-format, stationary or industrial applications	Energy storage systems, forklifts, UPS systems
Electric Vehicle Batteries (EV Batteries)	Drive Batteries for Vehicles	Passenger Car, Truck, and Bus Traction Batteries

Important: Batteries installed in WEEE devices are subject to both WEEE EPR and Battery EPR. Both registrations are required separately.

The 7 Key Steps to EPR Compliance in France

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

Companies outside the EU: For non-EU companies, appointing a French authorized representative is mandatory. This representative assumes full legal responsibility for registration, reporting quantities, and paying fees to ADEME and the eco-organization.

Companies from other EU countries: Companies from the EU must appoint a French authorized representative (mandataire) unless they have their own physical branch in France. The mandataire assumes all battery manufacturer obligations locally.

Step 2: Membership in an eco-organization

Membership in an approved Éco-Organisme is mandatory for all battery manufacturers in France. Without this agreement, batteries may not be legally sold in France.

Step 3: Mandatory registration with ADEME (SYDEREP) & obtaining the IDU number

As with all EPR streams in France, government registration is handled through SYDEREP, administered by ADEME.

Process:

Join the eco-organization
The eco-organization automatically submits your data to ADEME
ADEME issues the IDU within approximately 48 hours
The IDU must then be displayed prominently: in the Terms and Conditions, legal notice, invoices, marketplace profiles (Amazon, eBay, etc.), and on the website.

Step 4: Financial Obligations & Contribution Structure

The amount of the eco-contributions varies depending on the battery category, weight, and chemical composition. The basic calculation formula:

(Weight in kg × base rate per category and chemistry) + any quantity component ± eco-modulation adjustments

Step 5: Reporting Requirements & New Requirements of the EU Battery Regulation

Quantity Reporting (Basic Requirement):

Annual report by the end of February at the latest for the previous year (submitted digitally via the eco-organization’s portal)
Content: Quantity, weight, chemical composition, destination (B2C vs. B2B), battery category
First report after registration: required retroactively for the past years

CO₂ footprint declaration: Manufacturers must calculate and declare the carbon footprint of their batteries using the PEF methodology – expressed in kg CO₂ equivalent per kWh of total energy over the battery’s lifetime.

Step 6: Labeling Requirements

1. Crossed-out wheelie bin (WEEE/battery symbol): This well-known EU pictogram is mandatory on all batteries and packaging (Article 13 of the EU Battery Regulation 2023/1542). It signals to the consumer: This battery does not belong in household waste, but must be returned.

2. Triman logo + Info-Tri: For portable batteries sold to households, the Triman logo and Info-Tri instructions in French are also mandatory – on the product or packaging.

3. Chemical Composition / Capacity Information: Batteries must include information on their chemical composition (e.g., “Li-Ion,” “Pb,” “NiMH”) and capacity (in Ah or Wh).

Step 7: Take-back obligations & collection targets

As a member of an eco-organization, the manufacturer is indirectly involved in the collection and recycling targets of the EU Battery Regulation. The eco-organization organizes and finances the collection through a network of collection points (retailers, recycling centers, collection boxes).

Who is considered a “producteur”?

Specifically, this applies to:

Based in France: Produces batteries or has them manufactured under their own name/brand and places them on the market in France for the first time.
Importer: Imports batteries or battery-powered devices from abroad (EU or third country) into France – and thereby assumes the EPR obligations of the original manufacturer.
Distance Selling / E-Commerce: Companies based in other EU countries or third countries that sell directly to French end consumers (including marketplace sales).
Distributors of devices with built-in batteries: Anyone who sells electrical and electronic equipment (WEEE) with permanently installed or included batteries is also considered the producer of the batteries contained in the equipment, regardless of whether they sell the batteries separately.

Overview of Battery Categories

The EU Battery Regulation 2023/1542 defines five categories that are reported and priced separately in France.

Portable batteries (Under 5 kg, portable, for general consumer products): e.g. AA/AAA batteries, coin cells, laptop batteries, smartphone batteries
LMT batteries (Light-duty vehicles): e.g. E-bike batteries, e-scooter batteries, hoverboards
Starter batteries / SLI batteries (Starting, Lighting, Ignition): e.g. Automotive starter batteries
Industrial batteries (Large-format, stationary or industrial applications): e.g. Energy storage systems, forklifts, UPS systems
Electric Vehicle Batteries (Drive Batteries for Vehicles): e.g. Passenger Car, Truck, and Bus Traction Batteries

Important: Batteries installed in WEEE devices are subject to both WEEE EPR and Battery EPR. Both registrations are required separately.

The 7 Key Steps to EPR Compliance in France

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

Step 2: Membership in an eco-organization

Membership in an approved Éco-Organisme is mandatory for all battery manufacturers in France. Without this agreement, batteries may not be legally sold in France.

Step 3: Mandatory registration with ADEME (SYDEREP) & obtaining the IDU number

As with all EPR streams in France, government registration is handled through SYDEREP, administered by ADEME.

Process:

Join the eco-organization
The eco-organization automatically submits your data to ADEME
ADEME issues the IDU within approximately 48 hours
The IDU must then be displayed prominently: in the Terms and Conditions, legal notice, invoices, marketplace profiles (Amazon, eBay, etc.), and on the website.

Step 4: Financial Obligations & Contribution Structure

The amount of the eco-contributions varies depending on the battery category, weight, and chemical composition. The basic calculation formula:

(Weight in kg × base rate per category and chemistry) + any quantity component ± eco-modulation adjustments

Step 5: Reporting Requirements & New Requirements of the EU Battery Regulation

Quantity Reporting (Basic Requirement):

Annual report by the end of February at the latest for the previous year (submitted digitally via the eco-organization’s portal)
Content: Quantity, weight, chemical composition, destination (B2C vs. B2B), battery category
First report after registration: required retroactively for the past years

Step 6: Labeling Requirements

2. Triman logo + Info-Tri: For portable batteries sold to households, the Triman logo and Info-Tri instructions in French are also mandatory – on the product or packaging.

3. Chemical Composition / Capacity Information: Batteries must include information on their chemical composition (e.g., “Li-Ion,” “Pb,” “NiMH”) and capacity (in Ah or Wh).

Step 7: Take-back obligations & collection targets

Step-by-Step Checklist

(a) Companies based in France

1. Correctly identify the battery category(ies) and clarify the B2C/B2B breakdown

2. Select an eco-organization and sign a membership agreement

3. Apply for an IDU number from ADEME through the eco-organization

4. Include the IDU in the terms and conditions, legal notice, invoices, and all marketplace profiles

5. Check labeling: Crossed-out trash can + Triman + Info-Tri on product/packaging (for B2C)

6. Calculate and declare the CO₂ footprint for EV batteries using the PEF methodology

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

8. Submit annual volume report by the end of February (weight, chemistry, quantity, B2C/B2B)

9. Calculate eco-contributions and pay them on time

10. Retain documents for 6 years for ADEME audits

(b) Companies from other EU countries

1. Appoint an authorized representative (mandataire) in France

2. Enter into a written mandate agreement (legal entity or natural person with a SIREN number)

3. The authorized representative handles registration with the eco-organization and ADEME

4. Communicate the IDU number to all French marketplaces and trading partners

5. Ensure structured data: weight by chemical composition and battery category for volume reporting

6. Check CO₂ reporting requirements by battery category and prepare data

7. Provide marketplaces (Amazon, Fnac, etc.) with a valid IDU (listing suspensions possible if IDU is missing)

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

1. Appoint an authorized representative (mandataire) in France

2. The authorized representative registers the company with ADEME and an environmental organization

3. Clarify customs declaration: The importer must ensure that the manufacturer’s IDU is used correctly – or the importer registers as the manufacturer and assumes the EPR obligations

4. Provide the IDU to all marketplaces and trading partners in France

5. Submit annual volume reports via the authorized representative

6. Comply with CO₂ footprint requirements according to battery category and schedule