🇮🇹 EPR Compliance for Batteries in Italy |
Guide and Checklist 2026

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

The sale of batteries, rechargeable batteries, and devices with integrated energy storage in Italy requires strict compliance with Extended Producer Responsibility (EPR). As a distributor, you are responsible for take-back, proper recycling, and complete data reporting. Due to the new EU Battery Regulation and stricter enforcement in Italy – including the mandatory registration number in the Registro Pile for online marketplaces – compliance hurdles have noticeably increased.

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 Italy |
Guide and Checklist 2026

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

The sale of batteries, rechargeable batteries, and devices with integrated energy storage in Italy requires strict compliance with Extended Producer Responsibility (EPR). As a distributor, you are responsible for take-back, proper recycling, and complete data reporting. Due to the new EU Battery Regulation and stricter enforcement in Italy – including the mandatory registration number in the Registro Pile for online marketplaces – compliance hurdles have noticeably increased.

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” (Produttore) in Italy?

A manufacturer is any natural or legal person who first makes batteries available on the Italian market (regardless of the sales method, including distance selling):

  • Domestic manufacturers: Companies based in Italy that produce batteries or place them on the market under their own name or brand.
  • Importers: Companies that import batteries or battery-powered devices into Italy from abroad (EU or non-EU).
  • E-commerce / Distance Selling: Foreign suppliers that sell directly to Italian end users.
  • Marketplace Operators: Platforms are liable for violations committed by their sellers if the sellers are not registered.

Practical example:
A Swiss company sells e-bike batteries (LMT batteries) directly to Italian end customers through its own online store → is considered a manufacturer (placer on the market) → must appoint an authorized representative in Italy → must register with the national battery registry (Registro Pile) → must join an approved collective take-back system → pays regular environmental fees

The 7 Key Steps to EPR Compliance in Italy

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

Foreign manufacturers not based in Italy must appoint an authorized representative residing in Italy for distance selling.

Requirements for the authorized representative:

  • Registered office in Italy
  • The text of the power of attorney must be in Italian.
  • The authorized representative assumes legal liability for registration, EPR financing, and reporting.

Step 2: Membership in a collective collection system (Sistema Collettivo)

Manufacturers must ensure collection and recycling by joining a system approved by the Ministry (MASE).

In Italy, there is no single, centralized monopoly system for battery disposal, but rather several state-approved, competing collective systems.

All systems must be affiliated with the national coordination center CDCNPA, which manages collection nationwide.

The approved collection system is responsible for the proper take-back, sorting, and recycling of batteries placed on the market in Italy.

Step 3: Mandatory Registration in the Registro Nazionale Pile

Registration in the national Registro Pile must be completed exclusively online before batteries are first placed on the Italian market.

Procedure:

  • Online entry: The Italian authorized representative enters company data and battery categories into the Registro Pile.
  • Upload of proof: The confirmation of membership in the Italian collection system is attached digitally.
  • Payment: The official fees are paid directly electronically via the portal.
  • Number: Receipt of the IT registration number.

Step 4: Assign battery categories according to EU standards

  1. Portable batteries: Up to 5 kg, for general household use
  2. LMT batteries: For light vehicles such as e-bikes or e-scooters (up to 25 kg)
  3. SLI batteries: For starting, lighting, and ignition in vehicles
  4. Industrial batteries: For industrial purposes or energy storage solutions
  5. EV batteries: For powering hybrid or electric vehicles

In Italy, the correct battery category determines whether your EPR number is approved in accordance with the law, thereby actively preventing your account from being blocked on online marketplaces. Furthermore, accurate classification avoids costly fines and additional fees from Italian recycling consortia.

Step 5: Environmental Contributions and Financial Guarantees

Manufacturers pay an environmental contribution (Contributo Ambientale) to their collection system, based on weight and battery type.

New as of 2026: Manufacturers must provide a financial guarantee to cover disposal costs in the event they cease operations.

Step 6: Reporting Requirements

  • Annual volume reporting: By March 31 of each year, the previous year’s volumes must be reported via the Registro Pile portal
  • Carbon footprint: As of February 18, 2026, the carbon footprint declaration is mandatory for rechargeable industrial batteries (> 2 kWh)
  • Due Diligence: Larger companies must disclose raw material sourcing strategies starting in August 2027; preparation for this is already required

Step 7: Labeling and QR Codes

  • WEEE Symbol: The crossed-out trash can is standard
  • NEW as of February 18, 2027: All batteries must carry a QR code. Depending on the battery class, this provides access to a digital data sheet or the digital battery passport (including CO₂ data and recycled content for industrial and electric vehicle batteries).

Who is considered a “manufacturer” (Produttore) in Italy?

A manufacturer is any natural or legal person who first makes batteries available on the Italian market (regardless of the sales method, including distance selling):

  • Domestic manufacturers: Companies based in Italy that produce batteries or place them on the market under their own name or brand.
  • Importers: Companies that import batteries or battery-powered devices into Italy from abroad (EU or non-EU).
  • E-commerce / Distance Selling: Foreign suppliers that sell directly to Italian end users.
  • Marketplace Operators: Platforms are liable for violations committed by their sellers if the sellers are not registered.

Practical example:
A Swiss company sells e-bike batteries (LMT batteries) directly to Italian end customers through its own online store → is considered a manufacturer (placer on the market) → must appoint an authorized representative in Italy → must register with the national battery registry (Registro Pile) → must join an approved collective take-back system → pays regular environmental fees

The 7 Key Steps to EPR Compliance in Italy

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

Foreign manufacturers not based in Italy must appoint an authorized representative residing in Italy for distance selling.

Requirements for the authorized representative:

  • Registered office in Italy
  • The text of the power of attorney must be in Italian.
  • The authorized representative assumes legal liability for registration, EPR financing, and reporting.

Step 2: Membership in a collective collection system (Sistema Collettivo)

Manufacturers must ensure collection and recycling by joining a system approved by the Ministry (MASE).

In Italy, there is no single, centralized monopoly system for battery disposal, but rather several state-approved, competing collective systems.

All systems must be affiliated with the national coordination center CDCNPA, which manages collection nationwide.

The approved collection system is responsible for the proper take-back, sorting, and recycling of batteries placed on the market in Italy.

Step 3: Mandatory Registration in the Registro Nazionale Pile

Registration in the national Registro Pile must be completed exclusively online before batteries are first placed on the Italian market.

Procedure:

  • Online entry: The Italian authorized representative enters company data and battery categories into the Registro Pile.
  • Upload of proof: The confirmation of membership in the Italian collection system is attached digitally.
  • Payment: The official fees are paid directly electronically via the portal.
  • Number: Receipt of the IT registration number.

Step 4: Assign battery categories according to EU standards

  1. Portable batteries: Up to 5 kg, for general household use
  2. LMT batteries: For light vehicles such as e-bikes or e-scooters (up to 25 kg)
  3. SLI batteries: For starting, lighting, and ignition in vehicles
  4. Industrial batteries: For industrial purposes or energy storage solutions
  5. EV batteries: For powering hybrid or electric vehicles

In Italy, the correct battery category determines whether your EPR number is approved in accordance with the law, thereby actively preventing your account from being blocked on online marketplaces. Furthermore, accurate classification avoids costly fines and additional fees from Italian recycling consortia.

Step 5: Environmental Contributions and Financial Guarantees

Manufacturers pay an environmental contribution (Contributo Ambientale) to their collection system, based on weight and battery type.

New as of 2026: Manufacturers must provide a financial guarantee to cover disposal costs in the event they cease operations.

Step 6: Reporting Requirements

  • Annual volume reporting: By March 31 of each year, the previous year’s volumes must be reported via the Registro Pile portal
  • Carbon footprint: As of February 18, 2026, the carbon footprint declaration is mandatory for rechargeable industrial batteries (> 2 kWh)
  • Due Diligence: Larger companies must disclose raw material sourcing strategies starting in August 2027; preparation for this is already required

Step 7: Labeling and QR Codes

  • WEEE Symbol: The crossed-out trash can is standard
  • NEW as of February 18, 2027: All batteries must carry a QR code. Depending on the battery class, this provides access to a digital data sheet or the digital battery passport (including CO₂ data and recycled content for industrial and electric vehicle batteries).

Step-by-Step Checklist

(a) Companies based in Italy

1. Correctly classify batteries into the 5 EU categories

2. Determine the responsible collection system (consortium)

3. Complete registration on the Registro Pile portal and sign the contract

4. Publish the IT number on all documents and websites

5. Record built-in batteries in electrical and electronic equipment (EEE) separately from the WEEE report

6. Submit the annual government volume report via the portal (deadline March 31)

7. Submit interim reports to the consortium and pay the environmental contribution

8. Prepare the carbon footprint for industrial batteries >2 kWh

9. Check labeling: trash can + chemical symbols + QR code

10. Retain documentation for audits by Italian authorities

 

(b) Companies from other EU countries

1. Check sales channel: Direct sales to Italian end customers (B2C / marketplace) → proceed to step 2

2. Appoint an authorized representative in Italy

3. Complete registration with the Registro Pile and the Italian consortium

4. Submit proof of compliance (IT number) to online marketplaces

5. Ensure structured data for Italy

6. Monitor CO₂ reporting requirements and timeline for Italy

7. Adapt packaging labeling and language for the Italian market

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

1. Option A – Delivery to an Italian importer (B2B) – the importer becomes the legal manufacturer

2. Option B – Direct B2C sales without an Italian intermediary: Appoint an authorized representative; handle all steps from checklist (b) through this representative.

3. Legalize documents for the Italian registry

4. Ensure customs clearance and assignment of the IT number

5. Submit proof of compliance on all Italian marketplaces

Step-by-Step Checklist

(a) Companies based in Italy

1. Correctly classify batteries into the 5 EU categories

2. Determine the responsible collection system (consortium)

3. Complete registration on the Registro Pile portal and sign the contract

4. Publish the IT number on all documents and websites

5. Record built-in batteries in electrical and electronic equipment (EEE) separately from the WEEE report

6. Submit the annual government volume report via the portal (deadline March 31)

7. Submit interim reports to the consortium and pay the environmental contribution

8. Prepare the carbon footprint for industrial batteries >2 kWh

9. Check labeling: trash can + chemical symbols + QR code

10. Retain documentation for audits by Italian authorities

 

(b) Companies from other EU countries

1. Check sales channel: Direct sales to Italian end customers (B2C / marketplace) → proceed to step 2

2. Appoint an authorized representative in Italy

3. Complete registration with the Registro Pile and the Italian consortium

4. Submit proof of compliance (IT number) to online marketplaces

5. Ensure structured data for Italy

6. Monitor CO₂ reporting requirements and timeline for Italy

7. Adapt packaging labeling and language for the Italian market

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

1. Option A – Delivery to an Italian importer (B2B) – the importer becomes the legal manufacturer

2. Option B – Direct B2C sales without an Italian intermediary: Appoint an authorized representative; handle all steps from checklist (b) through this representative.

3. Legalize documents for the Italian registry

4. Ensure customs clearance and assignment of the IT number

5. Submit proof of compliance on all Italian marketplaces

Are you planning to sell your products in Italy?

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

Are you planning to sell your products in Italy?

We’ll help you ensure compliance with Italy’s 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