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Does your company have EPR obligations for batteries?

Do you place batteries or products containing batteries on the Danish market? Here you can get an overview of whether the EPR applies to you and what the next steps are.

The main rule: the company that first places the battery on the market in Denmark has the responsibility

Extended Producer Responsibility for batteries applies to the company that first makes batteries available on the Danish market — whether sold separately or incorporated into products. This typically includes Danish importers, manufacturers, companies selling under their own brand, and foreign companies using distance sales.

What matters is not only what you sell, but also your company's role in the value chain. If you are the first party to bring the battery onto the Danish market, the EPR obligations will typically rest with you.

Typical scenarios

1. You import batteries or products with batteries and resell them in Denmark

If you import a product with a battery and sell it on the Danish market, you are generally responsible for the battery under the producer responsibility rules. This also applies when the battery is built into the product.

2. You sell directly from abroad to Danish end users

If your company is based outside Denmark and sells batteries or products with batteries directly to Danish end users, you are generally subject to producer responsibility in Denmark. You must also be aware of the rules on authorised representatives.

3. You import industrial batteries and use them in products you sell in Denmark

If you import batteries and use them in products that you subsequently sell in Denmark, you are generally responsible for the batteries under the producer responsibility rules.

4. You have batteries manufactured under your own name

If you have batteries manufactured by another company but sell them under your own name or trademark, you are generally responsible for the batteries under the producer responsibility rules.

5. You buy batteries from a Danish producer that sells them under its own name

If a Danish producer manufactures and sells batteries under its own name to your company, the producer responsibility generally lies with the Danish producer - not with you.

Batteries in products count too

Many companies do not place batteries on the market as standalone products. They sell products that contain batteries. This does not change the EPR obligation.

The battery must still be assessed and reported separately, even if it is built in, permanently installed or not visible to the end user. There is no de minimis threshold.

Read about which batteries are covered

What should you do if you are covered?

1

Registration

You must register with Danish Producer Responsibility (DPA) before placing batteries on the market. Batteriretur can guide you on which information you typically need to have ready.

2

Annual reporting

As a member, you must report data to Batteriretur no later than 20 April. Batteriretur then reports to Danish Producer Responsibility before the official deadline of 30 June.

3

Environmental fees and handling

You must finance the collection and treatment of end-of-life batteries through the environmental fee. For portable batteries and LMT batteries, membership of a PRO is mandatory.

Read more about what EPR involves

Get support from Denmark’s most experienced Producer Responsibility Organisation

As part of the Retur family, we have more than 20 years of experience with Extended Producer Responsibility.

For a single annual membership fee of just DKK 1,500, your company gets a clear and coordinated setup for managing its obligations for batteries, electronics, packaging and textiles.

Become a member of Batteriretur

Shortcuts to useful knowledge

What do your EPR obligations for batteries involve?

Which batteries are covered?

Data and reporting for batteries

The EU Battery Regulation

Become a member

Frequently asked questions