Dear All,
As of August 18, 2025, all producers based outside of France placing batteries on the French market will be required to appoint an Authorized Representative, a physical or moral person established and active in France to ensure compliance on behalf of the producer under the Extended Producer Responsibility (EPR) framework.
To better support you through the evolving European regulatory landscape, we are pleased to introduce our
new Battery EPR Authorized Representative service
in compliance with Regulation (EU) 2023/1542.
As one of the leading French EPR Authorized Representatives in the WEEE sector, we are now extending this role to the Battery sector. Our new service enables you to meet this new EPR obligation proactively and seamlessly, with the same level of support and compliance expertise you’ve come to expect from us.
So far, only one decree has been published in France to implement Regulation (EU) 2023/1542. This decree defines the application conditions for only a small number of the Regulation’s provisions, notably:
• The extension of Extended Producer Responsibility (EPR) obligations to all batteries, regardless of their size or intended use;
• The sanctions applicable in case of non-compliance;
• Provisions relating to waste enforcement and the penalties applicable to end-of-life vehicle treatment centers.
In addition, a small number of by-laws (arrêtés) have also been issued, including one specifying the accreditation requirements for battery-related eco-organisms. However, none of these by-laws clarify how the technical aspects of the Regulation will be implemented at the national level. The practical details – such as reporting formats, eco participation fees for the new battery categories, or specific obligations for different types of sales manner (B2C, B2B) – remain unknown at this stage.
While we are still awaiting further application decrees and detailed implementing measures, it’s important to note that not all provisions require national transposition.
Some obligations – such as which types of producers must appoint an Authorised Representative (AR) and by when — derive directly from the Regulation and are already legally binding across the EU, regardless of national implementation.
Until further information becomes available, only a limited number of changes are expected to take effect immediately, as listed here below.
We will continue to monitor updates and share them with you as soon as they are released.
A new mandate agreement will need to be signed for all the below cases. Depending on your current situation, here are the immediate changes to expect :
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You are already registered through our Battery Facilitator Service
The only change is that eco participation invoices will now be issued by us, instead of directly by the compliance scheme. All other aspects – annual service fees, reporting, data format, communication, and general support – remain exactly the same.
You manage your Batteries registration independently until now
The eco participation invoices will be issued by us instead of directly by the eco organism,
You will need to submit your data to us, and we will handle the reporting to your chosen compliance scheme on your behalf.
Your registration details such as your Unique Identification Number will remain the same.
You are not yet registered for Battery EPR compliance
We will guide you through the entire process, just as we do for WEEE, ensuring your compliance is set up properly and efficiently from the start.
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At this stage, we have not received any indication that ongoing registration details – such as the Unique Identification Number (UIN) – will be affected by the transition to an Authorized Representative model. All current registrations are expected to remain unchanged.
Should the authorities introduce updates or modifications, we will monitor the situation closely and ensure you are informed and supported every step of the way.
If you are already benefiting from our Battery Facilitator service or are managing your Batteries EPR obligations independently, please note that all invoices issued by your eco organism prior to this mandate must be paid in full before the mandate can be activated.
We strive to make this transition as smooth and straightforward as possible for every producer. With this new service, our mission remains unchanged: to simplify your compliance journey and ensure your business stays aligned with the latest European and French EPR requirements.
If you have any questions or would like to initiate the mandate process as of now, feel free to reach out to your usual Recy’stem Pro contact or click on the button here below :
Our team will guide you through the next steps and provide all the information you need.
We’re here to support you every step of the way!
All the best,
The Recystem Pro Team