Survey on collective recycling in the battery chain
New European regulations effective Aug. 18, 2025 - What does this mean for you as a manufacturer/importer of battery systems (small to large)?
On Aug. 18, 2025, the European Batteries Regulation will enter into force. This new European regulation brings big changes for producers of industrial batteries - which includes both home batteries and large batteries. You are a producer if you produce or import batteries and market them in the Netherlands.
From Aug. 18, new obligations will apply to producers (importers/manufacturers), including an obligation to organize collection and treatment. This must be arranged by all producers individually, unless a majority supports setting up a collective system. Therefore, it is important that we hear your views on which solution is preferable.
In this post, you'll read about what's changing, what obligations are coming your way and about the poll that industry associations Holland Solar, Techniek Nederland and Energy Storage NL are conducting on support for a collective solution.
What exactly is changing?
- Mandatory free intake
Department of Public Works (RWS) states: as of August 18, 2025, manufacturers/importers of industrial batteries are required to all ingest - free of charge, regardless of chemical composition, brand or origin. This also applies to industrial batteries that you did not market yourself.
- Responsibility for processing
After collection, you are responsible for the proper disposal and recycling of the batteries, according to legal requirements. This involves costs. Costs of industrial batteries taken in by you that you did not put on the market yourself you may then try to recover from the original producer/importer.
What are your options as a producer?
You can meet the new obligations in two ways:
- Individual
You arrange your own collection, processing, reporting and financing. To do this, you must apply for individual approval from the Department of Public Works (RWS). The application is reviewed by RWS. You must report the results to RWS each year.
- Collectively
You join a collective arrangement (a Producer Organization). This Producer Organization arranges the implementation on your behalf - from collection to recycling - and charges a waste management fee per battery to cover the costs. To be clear: that collective system does not exist (yet). The industry associations are currently investigating its feasibility. Several preconditions apply. Part of the study is a survey to determine the support among producers for such a collective collection and processing system and their willingness to bear the costs of such a collectively financed system.
General binding declaration (GTC)
A collective system can be voluntary, or it can become mandatory for all producers through a so-called General Binding Declaration (AVV). An AVV can be requested from the Ministry of Infrastructure and Water Management if it can be shown that a majority of producers support the request. If the AVV is approved, each producer is obliged to contribute to the financing of the collective system. This is done based on the weight of systems placed on the market. This prevents unfair competition and free riders.
Cost
Battery systems are estimated to enter the waste phase only after 10 to 15 years. Then the battery must be collected and processed/recycled. Therefore, a financial system is needed that puts money aside now to cover future costs (a provision). To cover the costs/provision, ca €3.00 per kilogram should be charged to the producer/importer at the time of marketing (waste management fee). In the absence of a collective system, all producers are individually responsible for financing the collection and processing of producers that are returned to them.
Polling preference individual vs. collective
In this poll Holland Solar and Energy Storage NL ask you a number of questions. This will take a maximum of 5 minutes and will help us to assess whether there is support among producers for a collective recycling system, or whether individual fulfillment of the obligations is preferred. Based in part on the outcome of this poll, we may proceed with the application for a mandatory collective system.
So if you are a manufacturer or importer, it is important to voice your opinion. The deadline for completing the survey is May 21.
Thank you so much for your time and cooperation!
