What is the EU Extended Producer Responsibility (EPR) batteries regulation and what do I need to do?

EPR is a policy approach whereby producers take physical or financial responsibility for the end-of-life management of their products and their packaging. EPR is one of the most important pillars to ensure circularity in the EU. 

Every company that puts certain products, including batteries, or packaging on a national market is EPR responsible and has to ensure its EPR compliance by participating in an EPR system — the so-called Producer Responsibility Organisations (PROs). 

These organisations manage the process of taking back products and ensuring their proper disposal. This involves setting up recycling infrastructure, which is funded by fees that the producers pay to the PROs, based on the quantity of products they introduce to the market.

In order to ensure that their products are EPR compliant, companies therefore register with a PRO, report the quantity of products sold, and pay the respective fee to the PRO.

EPR for batteries, including batteries in electronic products, has already been rolled out in many European countries for years (including Germany, France, Spain, Italy, Sweden, the Netherlands and more). The new EU batteries regulation has now made EPR for batteries mandatory throughout all EU member states. This means that by 18 August 2025, all member states must enable producers to be able to register their battery-containing articles. 

The EU battery regulation sets up a mandatory compliance system for marketplaces that operates as follows: 

Each online marketplace — in this instance, Zalando — is required to ensure that partners are EPR compliant. To comply with this provision, Zalando must be able to prove that our partners who sell in the respective national market via Zalando have been registered with the respective recycling schemes (PRO) for batteries. To do this, Zalando will collect the national EPR registration numbers, EPR IDs, from our partners.

Partners, in turn, are responsible for registering with the relevant PRO and ensuring that they are compliant to be able to continue selling on Zalando. 

For the purposes of EPR, a producer is the company that first brings batteries or products containing batteries onto one of the national markets in the EU. The decisive factor is therefore who brings the specific battery, or the specific product containing batteries, onto the national market. It is not the placing on the EU market that is important here. Please note as well that a producer is not the equivalent of a manufacturer.

With regards to batteries, you are considered a producer if:

• You manufacture batteries or a product containing batteries in the respective national market and sell domestically;

and/or

• You import batteries or a product containing batteries into the respective national market;

and/or

• You sell batteries or a product containing batteries in the respective market and you do not have a registered company address there.

For companies selling their products directly to end-users, it is the distant seller i.e. the company selling online. For Zalando and our partners, this therefore refers to partner brands as well as most retailers. 

However, if a retailer works with an upstream supplier who is considered a producer in the respective market as defined above (e.g. an importer or a manufacturer), the retailer is not considered a producer but its upstream supplier. The upstream supplier also needs to be compliant with the EPR battery regulation.

In the context of EPR for batteries, an upstream supplier refers to a supplier of a retailer that is located in the same country as the retailer, such as an importer or manufacturer. The importer or manufacturer who first brings batteries or products containing batteries onto one of the national markets in the EU is therefore considered the producer in the respective country for EPR purposes.

The EU battery regulation will make EPR for batteries mandatory in all EU member states. Most EU member states have already introduced EPR for batteries, or are expected to introduce EPR shortly. 

This applies to the following countries: Austria, Belgium, Croatia, Czech Republic, Denmark, Finland, France, Germany, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Netherlands, Poland, Romania, Slovakia, Slovenia, Spain, and Sweden. You will need to make sure that you are EPR-compliant in each of these countries that you sell in. 

It is already possible to register your articles containing batteries in France and Germany. Please find information on how to do so below.

For Partner Program partners:

• 
  What are the Extended Producer Responsibility (EPR) obligations in France and what do I need to do?

  For partners who sell, or plan to sell, in France, you must provide Zalando with your EPR number. Find out how to get it below.

• 
  What are the Extended Producer Responsibility (EPR) obligations in Germany and what do I need to do?

  The German government implemented new requirements for online platforms, fulfillment service providers and their partners who sell in Germany. Find out what steps need to be taken to be compliant.

For Connected Retail partners:

• 
  What are the Extended Producer Responsibility (EPR) obligations in France?

  Find out about the EPR guidelines in France and what you need to do to comply.

• 
  The Extended Producer Responsibility (EPR) obligations in Germany

  All partners selling in Germany must ensure that they provide their German EPR number to Zalando. Find out how to request it below.

As soon as we have more information from the other EU member states on how and where to register, we will provide it.

According to the EU batteries regulation, a battery is any device that produces electrical energy through the direct conversion of chemical energy. This includes devices with internal or external storage, composed of one or more battery cells (which may be modules or packs) that are either rechargeable or non-rechargeable. 

Relevant for the Zalando assortment are in particular "portable batteries", i.e. a battery that is sealed, weighs 5 kg or less, is not designed specifically for industrial use and is not an electric vehicle battery, a battery for light means of transport (LMT) or a battery for starting, lighting or ignition (SLI), as well as any battery that is used in electric products (e.g. in earphones, watches, clocks, electric beauty products, etc.).

If you are selling or planning to sell products containing batteries, you should begin registering for an EPR ID for batteries in the relevant country/countries. This will include the following steps: 

• Begin your EPR registration in each country where you are considered a producer. Contact the respective national authority or PRO to start the process. Please find the PROs listed below in question 8.

• The EU batteries regulation requires producers selling batteries in a country where they are not established to appoint and register through an Authorised Representative (AR) in that country. However, AR procedures are still being implemented across the EU. We recommend consulting a professional advisor or PRO for specific guidance on AR registration in the relevant country.

You will also need to implement two new attributes for all newly onboarded articles. Please find more details about that here:

• 
  Article attributes for EU Extended Producer Responsibility (EPR) batteries regulation

  Here we outline what attributes to use and how to add them to your articles to be EPR compliant for the EU batteries regulation.

Please reach out to the relevant PRO for each market that you sell articles containing batteries in:

If you are classified as a producer, you must register for EPR in each country you sell to. There is no EU-wide registration. 

Please also note that there are other EPR obligations for packaging, electronic products and textiles, as well as some other categories, in addition to battery registration.

Zalando is currently developing a solution to collect and validate EPR ID for batteries across all EU markets. In addition to EPR IDs, you will be required to provide two new data points for each article offered through Zalando: ‘contains batteries (yes/no)’ and ‘electronic components (yes/no)’. We will integrate this data collection into all our existing systems. Please find more information on these two attributes here:

• 
  Article attributes for EU Extended Producer Responsibility (EPR) batteries regulation

  Here we outline what attributes to use and how to add them to your articles to be EPR compliant for the EU batteries regulation.

If you sell batteries or articles containing batteries in Germany or France, the process is already established. Please find more details below.

• 
  What are the Extended Producer Responsibility (EPR) obligations in France and what do I need to do?

  For partners who sell, or plan to sell, in France, you must provide Zalando with your EPR number. Find out how to get it below.

• 
  What are the Extended Producer Responsibility (EPR) obligations in Germany and what do I need to do?

  The German government implemented new requirements for online platforms, fulfillment service providers and their partners who sell in Germany. Find out what steps need to be taken to be compliant.

• 
  What are the Extended Producer Responsibility (EPR) obligations in France?

  Find out about the EPR guidelines in France and what you need to do to comply.

• 
  The Extended Producer Responsibility (EPR) obligations in Germany

  All partners selling in Germany must ensure that they provide their German EPR number to Zalando. Find out how to request it below.

Zalando will review all of the current assortment containing batteries, and add the new attributes accordingly. We recommend that you update the special description for all articles containing batteries (both existing and new), using the special_description_en or special_description_de field to clearly state if a battery is included (e.g. if an article uses a battery but is not sold with one).

To help ensure compliance and reduce risk for both you, our partners, and Zalando, we will begin limiting the sale of battery-containing articles starting 18 August 2025. This measure will remain in place until we are able to collect and validate your EPR data. A new zDirect feature to collect your EPR registration details is planned for release towards the end of the year. We will share specific instructions ahead of launch.

Once our system is ready to collect your EPR IDs, you will be required to submit this information for each market where you sell battery-containing articles. If you are unable to provide the necessary EPR information for a specific market, your battery-containing articles will remain deactivated in that particular market until compliance is confirmed. Additionally, incorrect use of attributes or missing battery information in product descriptions will also result in deactivation of the articles in that market. As outlined in our Platform Rules, any financial disadvantages to Zalando due to misrepresentation may be reclaimed from the partner.

Please find an overview of the batteries regulation here. For questions about the process to register or requirements from you, please reach out to the relevant PRO for the market you wish to register in.