EPR Batteries Requirements Expanded in 2025

Amazon has announced that it will begin implementing new regulations on product listings containing batteries for several regional marketplaces in August 2025, in line with European Union requirements on Extended Producer Responsibility (EPR). 

What is Extended Producer Responsibility?

Many consumers are already familiar with the concept of producers taking some form of responsibility for their products, often for upkeep and maintenance.  For example, when a customer purchases something from a retailer, they expect the retailer (or manufacturer) to offer a time-limited warranty.

Extended Producer Responsibility (EPR) takes this one step further – producers are made responsible for the entire lifecycle of their products.  The entire lifecycle not only refers to the lifespan of the product, but also end-of-life management, such as recycling or disposal. 

EPR regulations aim to introduce these responsibilities by requiring producers to fund the proper disposal or recycling of their products. 

Many EPR regulations therefore involve producer registration, requiring businesses to register with a designated local authority, declare the products they sell, and pay upfront fees for disposal or recycling.

These regulations are designed not only to cover waste management costs in advance but also to motivate producers to create more sustainable products by factoring in the environmental impact of disposal and recycling from the outset.

The European Union has introduced several Directives which individual Member States will need to implement in order to enforce EPR measures on a national level.  There is currently no EU-wide EPR scheme.

The Batteries Directive has already been implemented by several Member States, supplemented by the Batteries Regulation which has automatic direct effect in all Member States.

Who is affected?

All ‘producers’ are affected.   This includes:

• Manufacturers
• Retailers
• Resellers (including distance sellers)
• Importers

All Amazon sellers are affected as they will fall under one or more of the above categories of producers.

The European Union has specified that the Batteries category must include most types of batteries, including:

• Single-use
• Rechargeable
• Automotive (including transport and electric vehicles)

This includes batteries sold as a standalone product, or products containing batteries.

Amazon EPR Enforcement Timeline and Marketplaces Affected

Amazon will begin enforcement of the Batteries category in several regional marketplaces on 18 August 2025.  The following regional marketplaces will be regulated:

• Belgium
• France
• Germany
• Italy
• Netherlands
• Poland
• Spain
• Sweden
• Ireland

All product listings which have been identified as containing batteries must have a valid EPR registration number associated with the listing, in the region that that product listing is sold.  If you are selling in multiple regions, you must upload a valid EPR registration number for each individual region.

In order to help sellers comply with the enforcement date, Amazon has launched a centralised Compliance Portal.    

Additional EU Compliance Requirements: CE Certification & Responsible Person

The European Union has mandated that all products containing batteries will also need to pass additional product testing and receive CE certification. 

It is illegal to sell goods containing batteries in the EU without the appropriate CE certification, even if you have the relevant EPR registration.

Businesses that are not already established in the European Union will also need to appoint a Responsible Person.

Consequences of Non-Compliance with Battery EPR Regulations

For sellers that fail to upload a valid EPR registration number, Amazon will take steps to ensure that their sellers remain compliant with local regulations.

Sellers on Amazon France and Amazon Spain will be automatically enrolled onto Pay on Behalf – this is an additional chargeable service where Amazon will automatically make the relevant EPR declarations on your behalf for an additional fee. 

Sellers on all other regional marketplaces may face enforcement measures, including:

• Removal of product listings (including their associated ASINs)
• Suspension of selling privileges – regional or across all Amazon marketplaces

Sellers that fail to obtain CE certification for your products (and appoint a Responsible Person where required) will be subject to national law enforcement measures, including:

• Goods being seized and/or destroyed at customs
• Financial penalties, including confiscation of earnings

Ongoing Compliance with TBA Global

At TBA Global, we can help ensure that your business operates smoothly – our renowned compliance services can help you:

• Register for EPR in all your active trading regions
• File your EPR declarations on time
• Ensure you pay the correct EPR contribution fees

If you’re looking to get started with sales, we can also help:

• Get your products tested and CE-certified
• Act as your Responsible Person in the European Union