New EU battery regulation: mandatory Authorised Representative for producers
The EU Battery Regulation has brought a major change for battery producers across Europe. With Article 56.3 introducing the obligation to appoint an Authorised Representative (AR), companies placing batteries on the EU market must now comply with a harmonised requirement. Until recently, this was only mandatory in some Member States such as Italy and Spain, while others had no such obligation. This update marks an important step toward greater consistency in EU battery and WEEE management.
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Understanding the new Authorised Representative requirement
Article 56.3 of the EU Battery Regulation requires foreign producers established in another EU Member State or third country to appoint an Authorised Representative (AR). The AR acts on behalf of the producer to ensure compliance with registration, reporting, and extended producer responsibility (EPR) obligations.
Previously, there was a fragmented landscape. In countries like Italy and Spain, the appointment of an AR was already mandatory under national law. However, in Germany, it was voluntary, and in France, the concept of an AR did not exist for battery compliance. This discrepancy often caused confusion for producers trying to maintain compliance across multiple EU markets.
Now, with the EU Battery Regulation in force, this requirement has become mandatory in all Member States. France and Germany have already updated their national systems to align with the regulation, and we expect others to follow soon.
How this change affects battery producers
For companies placing batteries on the EU market, whether as standalone products or integrated in electrical equipment, this new requirement represents both a challenge and an opportunity.
Simplifying compliance across borders
From a practical standpoint, the harmonisation of the AR obligation simplifies cross-border operations. Before this regulation, producers had to navigate a patchwork of national rules, which created administrative complexity. Now, every producer based outside the country where they want to sell will know they must have an AR in each of them. This clarity makes planning, cost and compliance management easier.
Ensuring accountability in the supply chain
- Registering the producer in national battery registers.
- Submitting periodic reports on quantities placed on the market.
- Ensuring collection and recycling targets are met.
Examples from leading Member States
France: from no obligation to full compliances
France historically did not require an Authorised Representative for batteries. Since the introduction of the EU Battery Regulation, however, the French authorities now demand that foreign producers appoint an AR when registering in the national system. This ensures that all companies remain accountable for their products’ environmental impact.
Germany: from voluntary to mandatory
In Germany, the AR system existed but was voluntary. Now it is a compulsory step for foreign producers. This change has aligned Germany with the EU framework, offering producers greater regulatory predictability.
These two examples illustrate how national systems are converging under the new regulation, creating a more unified European compliance environment.
What to expect next
We anticipate that other EU countries where the AR obligation was not previously enforced will soon update their national battery compliance system to align with Article 56.3. This harmonisation will help streamline administrative processes and improve data accuracy across Member States.
At Circular Compliance, we help producers navigate these evolving requirements by offering complete support for battery and WEEE compliance, from registration and AR appointment to reporting and take-back obligations. Our expertise ensures that your company stays fully compliant with the latest EU regulations while supporting circular economy goals.
If you need guidance on appointing an Authorised Representative or managing your obligations under the EU Battery Regulation, explore our EU compliance solutions or get in touch with our expert team for tailored assistance.
For businesses placing batteries or electronic products on the EU market, now is the time to review your compliance strategy. Appointing the right Authorised Representative is not just a regulatory necessity, it’s a vital step toward responsible and sustainable product management.
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