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Extended responsibility for battery manufacturers

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In accordance with the provisions of the amended law of 21 March 2012 on waste and Regulation (EU) 2023/1542 on batteries and waste batteries, waste batteries are subject to the principle of extended producer responsibility.

With a view to promoting prevention, reuse, reutilisation, recycling and any other form of recovery of waste, the producers of products (i.e. those who place batteries on the market) are subject to the extended producer responsibility scheme.

As a result, the producer of products must fulfil a number of obligations.

Who is concerned

Producers of products

The 'producer' is any manufacturer, importer or distributor or any other natural or legal person who, regardless of the sales technique used, including by means of distance contracts:

  • is established in Luxembourg and manufactures batteries under its own name or brand, or has batteries designed or manufactured and supplies them for the first time under its own name or brand on Luxembourg territory; or
  • is established in Luxembourg as a business and sells, on Luxembourg territory, under its own name or brand, batteries manufactured by other manufacturers; or
  • is established in Luxembourg and supplies batteries originating in another Member State or a third country for the first time in Luxembourg on a professional basis; or
  • sells batteries, by means of distance contracts, directly to end users, whether or not they are private households, in one Member State, and its business is located in another Member State or in a third country.

The term 'batteries' includes those incorporated into appliances, light transport or other vehicles.

Products concerned

Batteries are defined as any source of electrical energy:

  • obtained by direct conversion of internal or external chemical energy;
  • consisting of one or more non-rechargeable cells or one or more rechargeable cells, battery modules or battery assemblies; and
  • which includes a battery that has been prepared for reuse, prepared for repurposing, repurposed or remanufactured. 

The following battery types are concerned:

  • portable batteries;
  • LMT batteries (batteries intended for light means of transport);
  • SLI batteries (starting, lighting and ignition batteries for vehicles);
  • industrial batteries;
  • electric vehicle batteries.

How to proceed

Portable batteries, LMT batteries and SLI batteries

Manufacturers of these types of batteries must contractually appoint an approved body to fulfil all their obligations. For the time being, the non-profit organisation Ecobatterien ASBL is the only organisation authorised to endorse these obligations. Producers of products must therefore become members of the accredited organisation Ecobatterien.

For further information, please contact Ecobatterien ASBL by email at: administration@ecobatterien.lu or by telephone on (+352) 26 09 87.

Industrial or electric vehicle batteries

Manufacturers of these types of batteries may:

  • either become members of the accredited organisation Ecobatterien;
  • or apply for an individual approval. Individual approval must be applied for online using the e-RA tool. Any producer who fulfils the take-back obligation themselves (individual approval) must submit an annual report to the Environment Agency using the e-RA tool, by 30 June at the latest.

If you would like more information, please contact the Environment Agency (Administration de l’environnement) by email at batt@aev.etat.lu.

Who to contact

Ecobatterien ASBL

Address:
11, boulevard du Jazz L-4370 Belvaux
Email address:
info@ecobatterien.lu

Environment Agency Strategies and Concepts

Address:
1, avenue du Rock'n'Roll L-4361 Esch-sur-Alzette Luxembourg
Email address:
emballages@aev.etat.lu
Packaging
Email address:
deee@aev.etat.lu
WEEE
Email address:
batt@aev.etat.lu
Batteries
Email address:
sup@aev.etat.lu
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