Batteries and accumulators: the third obligation
Batteries have their own producer register, their own collection targets and their own reporting line in Romania. The obligation applies whether you sell batteries as products or ship devices with batteries inside or in the box — and it applies in addition to packaging and, for powered products, to WEEE.
Battery types and how they are reported
| Type | Typical examples | Notes |
|---|---|---|
| Portable | AA/AAA cells, button cells, lithium packs in devices and power tools | The category most distance sellers fall into |
| Industrial | Battery packs for professional equipment and storage | Separate reporting, different targets |
| Automotive | Starter batteries | Distinct rules and collection channels |
| Batteries in products | Built-in cells in devices, toys, lamps, wearables | Reported by the seller of the product, not by the cell manufacturer |
What the duty covers
- Registration in the Romanian producer register before the first sale into the market.
- A contract with a licensed collective scheme that meets the collection targets for your quantities.
- Reporting of quantities placed on the Romanian market, by type and weight.
- Correct marking and end-user information on separate collection.
- Environmental Fund contribution where targets for your quantities are not met.
Why this stream is the one most often missed
A seller looks at the product, sees a lamp or a toy, registers for packaging and considers the file closed. The battery inside makes them a battery producer too, and the EU battery rules that came in with Regulation (EU) 2023/1542 have increased both the information duties and the attention this stream gets from authorities and marketplaces.
The exposure is rarely large in money terms. It is large in consequence: an unregistered producer can be blocked from listing, and past periods can be assessed retroactively.
The practical test
Frequently asked questions
- The batteries come from our supplier. Aren't they the producer?
- For the Romanian market, the party that places the product on it is the producer. If your parcel brings the battery to a Romanian customer, the obligation is yours.
- Is this reported together with WEEE?
- No. Devices go into the WEEE report, cells into the battery report, and both are separate from the packaging declaration.
- What changed with the EU battery regulation?
- Regulation (EU) 2023/1542 tightened information, labelling and due-diligence duties and is being phased in. It does not replace national registration: you still register and report per country where you sell.