Extended producer responsibility for the sale of items with batteries (BATT)
Do you sell battery-operated watches or accessories? Then the extended producer responsibility (EPR) applies to you. Our blog article provides detailed information on your obligations, including registration in take-back systems, reporting, verification, disposal, and much more.
New: Manage EPR Obligations Easily in the Compliance Hub
According to EU regulations on Extended Producer Responsibility (EPR), a dealer is considered a producer in an EU country as soon as they place certain products or packaging for end consumers on this market for the first time – including in the context of distance selling and regardless of where the dealer is based.
As a Chrono24 partner selling new and pre-owned watches, you may be subject to EPR obligations with regard to packaging (PACK), electrical and electronic equipment (EEE), or batteries (BATT), depending on the products sold and the destination country.
Our new Compliance Hub provides you with step-by-step guidance and a central dashboard where you can review your EPR obligations, submit required data, and track their status at any time.
Once you have submitted the required data, the status will change to “Submitted” and the obligation in question will be considered fulfilled – unless we contact you for further verification.
Please note: We cannot offer legal advice. The information provided here is for general guidance only. For specific advice on how the battery regulations apply to your individual case, we recommend that you contact qualified legal counsel. Chrono24 is entitled to request proof of compliance with your EPR obligations at any time. As a dealer, you must ensure that you have all the necessary registrations and evidence so that your listings remain active.
In order to improve the sustainability of batteries throughout their life cycle and promote the circular economy, the EU Battery Regulation (EU) 2023/1542 has been in force since August 18, 2025. If you sell items with batteries to end customers in EU countries, you may be considered a producer under the EU Battery Regulation in terms of extended producer responsibility (EPR) and are legally obliged to comply with certain requirements. There are comparable EPR obligations in all EU countries: Anyone selling batteries or items containing batteries must register, participate in a take-back system, report quantities, and comply with labeling requirements. EPR obligations for batteries apply across all EU countries — the sections below cover Germany, France, Austria, and Spain in detail, with a full EU overview table covering all member states further down the page.
- Sale of battery-operated items to Germany
- Sale of battery-operated items to France
- Sale of battery-operated items to Austria
- Sale of battery-operated items to Spain
Who is affected?
The EU Battery Regulation affects all dealers on Chrono24 who offer batteries or items with batteries, such as quartz watches, smartwatches, or watch winders. In short: As soon as you offer batteries, including batteries installed in items, for the first time in an EU country and sell them to end consumers, you are considered a producer within the meaning of the EU Battery Regulation. This means that dealers based outside the EU who sell or offer batteries for sale to buyers in the EU via Chrono24 must also comply with the respective national battery regulations.
Who is considered a producer according to the Battery Regulation?
You are considered a producer in an EU country when you place batteries on the market for end consumers there for the first time, i.e., when you offer or sell the batteries commercially in this country for the first time. It does not matter whether the batteries are part of an item and whether the item or the batteries are new or used.
You are considered a producer if one of the following points applies to you:
- You are not based in the EU country to which you sell battery-powered items or batteries: → As a distance retailer selling to end consumers in this country, you are considered a producer and must fulfill EPR obligations there.
- You are based in an EU country and sell items produced by you or manufactured for you with batteries under your own brand to end consumers there: → As soon as you offer and sell these items in this country for the first time, you place them "on the market" there and are deemed to be the producer.
- You are based in an EU country and sell items with batteries that originate from another EU country or a third country (e.g., Switzerland, Japan, USA) to end consumers there: → Since these items with batteries were not previously on the market in your country, you are placing them on the market there for the first time and are considered to be the producer.
- You purchase items with batteries from private sellers and offer them commercially in EU target countries: → In this case, you place the devices on the market commercially and are therefore considered a producer on Chrono24.
Note: The information is for guidance only. Different regulations may apply in individual EU countries. You can read more about this under country-specific information.
Which batteries are affected?
The new EU Battery Regulation applies to all types of batteries – regardless of whether they are sold individually or are built into or attached to items.
What does this mean for me as a dealer on Chrono24?
Below you will find an overview of the central obligations under the EU Battery Regulation in connection with the sale of watches and watch accessories via Chrono24.
The requirements that apply to you depend, among other things, on whether your company is based in the EU country in which you offer battery-powered items.
Below you will find additional country-specific information on the respective obligations for select target markets.
If your company is based in the EU country where you offer batteries or battery-powered items:
- Obligation to register: You must register with the competent national authority.
- System participation / take-back obligation: You must have a contract with a Producer Responsibility Organization (PRO).
- Quantity reporting: You must regularly report the quantities of batteries placed on the market to the relevant competent authority or producer responsibility organization.
If your company is not based in the EU country where you offer batteries or battery-powered items:
- Authorization: In all EU countries in which you have neither your registered office nor a branch, you must appoint an authorized representative to assume the obligations under the EU Battery Regulation on your behalf.
- An authorized representative may be a natural or legal person resident there or a corresponding service provider.
In general, for each EU country in which you sell battery-operated items, you must confirm to Chrono24 with self-certification that you only offer batteries – including batteries installed in devices – for which you meet the requirements of extended producer responsibility in accordance with Article 56(1), (2), (3), and (4); Article 57(1) and Article 58(1), (2), and (7) of the EU Battery Regulation.
Information that Chrono24 requires from you: For each EU country in which you offer batteries or battery-operated items:
- A unique EPR number
- Self-certification to Chrono24
- If applicable (depending on the location of your company), the name of the authorized representative and proof of authorization
Country-Specific Information
Sale of battery-operated items such as quartz watches in or to Germany
If your company is based in Germany and is considered a producer for one or more brands:
Requirements:
- Visit the website of the EAR Foundation (Battery Register) and create an account for your company.
- Submit a registration application (category "portable batteries") for each brand for which you are considered a producer within the meaning of the EU Battery Regulation.
- In accordance with the EU Battery Regulation, as a producer, you must sign a contract with a PRO (Producer Responsibility Organization) in addition to registering your brands. These may also be called OfH on their page.
- Alternatively, you can make contact with a PRO and work with them to register with the EAR Foundation.
Information that Chrono24 requires from you:
- Your EPR number, under which you have registered in the EAR the brands of the battery-powered items you place on the market.
If your company is based outside of Germany:
Requirements:
- As a foreign company without a registered office or branch in Germany, you must appoint an authorized representative based in Germany to assume the legal obligations arising from the provisions of the German Batteries Act (BattG) on your behalf.
- Possible first point of contact: Interzero or Get-E-Right.
- The authorized representative will register your brands in the EAR for you. After successful registration, you will receive your individual EPR number, which is valid for all your brands registered in the EAR.
Information that Chrono24 requires from you:
- Name of the authorized representative
- Evidence of authorization (e.g., a confirmation)
- Your EPR registration number, under which the brands of the battery-powered items you place on the market have been registered in the EAR (Battery Register) by your authorized representative.
Sale of battery-operated items such as quartz watches in or to France
If your company is based in France and is considered a producer:
Requirements:
- Register with an approved eco-organization (French: Éco-organisation, equivalent to PRO) for batteries (e.g., Ecosystem) and take out a license.
- The eco-organization registers your company in the French ADEME/SYDEREP register. After successful registration, you will receive your EPR number(UIN – Unique Identification Number from the eco-organization.
Information that Chrono24 requires from you:
- EPR number (UIN for the "Batteries" category)
Note: We regularly check your EPR number in the SYDEREP system for validity.
If your company is based outside of France:
Requirements:
- As a foreign company without a registered office or branch in France, you must appoint an authorized representative based in France to assume the obligations under the EU Battery Regulation on your behalf.
- Your authorized representative will register you with an approved eco-organization for batteries (e.g., Ecosystem) and provide you with your EPR number (UIN – Unique Identification Number for the category "batteries") from the ADEME/SYDEREP register.
- Possible first point of contact: Recystem Pro or Get-E-Right.
Information that Chrono24 requires from you:
- Name of the authorized representative
- Evidence of authorization (e.g., a confirmation)
- EPR number (UIN for the "Batteries" category)
Note: We regularly check your EPR number in the SYDEREP system for validity.
Sale of battery-operated items such as quartz watches in or to Austria
If your company is based in Austria and is considered a producer:
Requirements:
- Register in the EDM portal (see edm.gv.at).After successful registration, you will receive your individual GLN number, which is valid as an EPR number for Chrono24.
- Conclude a contract with a collection and recycling system (e.g., ERA, ERP Austria, Interzero Europe).
- A list of approved collection and recycling systems can be found here.
Information that Chrono24 requires from you:
- EPR number (GLN)
If your company is based outside of Austria:
Requirements:
- As a foreign company without a registered office or branch in Austria, you must appoint an authorized representative based in Austria to assume the obligations under the EU Battery Regulation on your behalf.
- The authorized representative carries out the registration in the EDM portal for you. After successful registration, you will receive your individual GLN number, which is valid as an EPR number for Chrono24.
- More information about authorized representatives can be found here.
Information that Chrono24 requires from you:
- Name of the authorized representative
- Evidence of authorization (e.g., a confirmation)
- EPR number (GLN)
Sale of battery-operated items such as quartz watches in or to Spain
If your company is based in Spain and is considered a producer:
Requirements:
- Sign a contract with a take-back system for batteries (e.g., Ecopilas, ERP España).
- Register in the National Registry of Producers RII_PYA.
- Once you have successfully registered, you will receive your ERN (Número de Registro de Fabricante), which is your EPR number for Chrono24.
Information that Chrono24 requires from you:
- EPR number (ERN)
If your company is based outside of Spain:
Requirements:
- In order to fulfill your EPR obligations in Spain, you need a Spanish NIF (Número de Identificación Fiscal). If you do not have one, you can apply for one from Gestoraz.
- As a foreign company without a registered office or branch in Spain, you must appoint an authorized representative based in Spain to assume the obligations under the EU Battery Regulationon your behalf. You can apply for this service via Interzero España, for example.
- Your authorized representative carries out the registration in the Spanish National Registry of Producers RII_PYA as well as the licensing via an approved take-back system (e.g., Ecopilas, ERP España). After successful registration, you will receive your ERN (Número de Registro de Fabricante), which is valid as the EPR number for Chrono24.
Information that Chrono24 requires from you:
- Name of the authorized representative
- Evidence of authorization (e.g., a confirmation)
- EPR number (ERN)
EU Overview: Authorities, PROs, and Authorization
To make it easier to navigate which requirements apply in individual EU countries, we have compiled the most important information for you in a table. There you can see:
- The responsible authorities or registers
- Examples of Producer Responsibility Organizations (PRO)
- Whether you need an authorized representative as a retailer without a registered office or branch in the same EU country
Some countries are still adapting their national regulations to the new EU Battery Regulation, so we will regularly update the overview as soon as new information is available.
|
Country |
Authority / register |
Producer Responsibility Organizations (PROs) |
Authorized representative required (if no registered office in the respective country)? |
| Germany | EAR Foundation (stiftung ear) | GRS Batterien ERP Deutschland take-e-way |
Authorized representative required |
| France | ADEME / SYDEREP | Ecosystem Batribox |
Authorized representative required |
| Austria | EDM-Portal | UFH ERA ERP Austria |
Authorized representative required |
| Spain | RII_PYA | Fundación ECOPILAS ERP España |
Authorized representative required |
| Italy | Registro Nazionale dei Produttori di Pile e Accumulatori | Cobat ERP Italia |
Authorized representative required |
| The Netherlands | Stichting OPEN | Stichting OPEN | Authorized representative required |
| Belgium | Bebat | Bebat | Authorized representative required |
| Poland | BDO | REBA ERP Polska |
Authorized representative required |
| Czech Republic | ISOH2 / VISOH2 | ECOBAT REMA Battery |
Authorized representative required |
| Hungary | OKIR | MOHU | Authorized representative required |
| Sweden | Naturvårdsverket | El-Kretsen ERP Sweden |
Authorized representative required |
| Denmark | Producentansvarsregistret (DPA) | Batteriretur ERP Denmark |
Authorized representative required |
| Finland | Waste Management Compass | Recser Oy ERP Finland |
Authorized representative required |
| Portugal | SIRER / APA | ERP Portugal GVB |
Authorized representative required |
| Ireland | Producer Register (PRL) | WEEE Ireland ERP Ireland |
Authorized representative required |
| Luxembourg | Administration de l’environnement (AEV) | Ecobatterien | Authorized representative required |
| Greece | National Producers’ Register (EOAN) | AFIS S.A. | Authorized representative required |
| Croatia | RPPO / FZOEU | CIAK Grupa Interzero Croatia |
Authorized representative required |
| Slovakia | MŽP SR Battery Register | SEWA NATUR-PACK |
Authorized representative required |
| Romania | ANPM / ANMAP | ECOTIC BAT Recobat Plus |
Authorized representative required |
| Bulgaria | ExEA Register | ECOBATTERY ERP Bulgaria |
Authorized representative required |
| Cyprus | Department of Environment | AFIS Cyprus | Authorized representative required |
| Slovenia | MOPE Register | ZEOS Interzero Slovenia |
Authorized representative required |
| Estonia | PROTO | Eesti Elektroonikaromu Information on EPR and PROs |
Authorized representative required |
| Latvia | elektroregistrs.lv (BARR Register) | Latvijas Zaļais punkts Zaļā josta |
Authorized representative required |
| Lithuania | GPAIS | GIA EEPA |
Authorized representative required |
| Malta | ERA | GreenPak | Authorized representative required |
Frequently asked questions (FAQ)
If you are based in an EU country and purchase all your batteries exclusively from commercial suppliers (so-called upstream suppliers) from the same country, these suppliers are generally considered to be the producer, not you. The prerequisite is that your upstream suppliers are registered in the national battery register and fulfill their producer obligations.
If you buy and sell within the same EU country and your commercial suppliers (upstream suppliers) are already registered as producers there, the producer responsibility lies with these upstream suppliers.
In this case, you do not have to register, but you should have the relevant proof (e.g., EPR number and registration data) from your upstream suppliers available.
This exception only applies if all batteries, including built-in batteries, that you offer come exclusively from domestic suppliers. As soon as you purchase items from abroad or from private sources and sell them in your country, you are considered a producer for these items and must register accordingly in the national battery register.
Yes, separate registration and system participation is required for each country to which you sell batteries if you are considered a producer there.
Yes, many PROs offer registration and EPR participation for several EU countries or different EPR product categories (e.g., batteries, packaging, electronic devices). If you work with a PRO, ask them whether they offer cross-border services. Examples of PROs that offer EPR services in several countries:
Foreign retailers without a registered office or branch in the respective target country must generally appoint an authorized representative based in this country to fulfil their obligations under extended producer responsibility (EPR).
This authorized representative – a natural or legal person based there – acts on behalf of the retailer and takes on tasks such as registration in the national registers, the submission of legally required notifications, and communication with the relevant authorities.
This ensures that even retailers without a local registered office properly fulfill their EPR obligations and comply with the legal requirements in the respective country.
Yes, some services provide authorized representatives in several EU countries or different EPR product categories (e.g. batteries, packaging, electronic equipment). If you are already working with a service provider, ask whether they cover several countries. Examples of PROs that offer EPR services in several countries:
Most systems offer flat fees for small quantities.
As a dealer on Chrono24, you must ensure that you fulfill all legal obligations regarding extended producer responsibility (EPR). If you do not comply with these requirements, your listings will be considered non-compliant. In this case, Chrono24 may have to block or remove affected listings in order to comply with legal requirements. Depending on the country, fines or sales bans may also be imposed.
Yes, devices with built-in or permanently installed batteries are also affected.
Yes, the Battery Regulation also applies to used items when they are placed on the market commercially for the first time in an EU country.
Yes, according to the EU Battery Regulation, producers, importers, and retailers are obliged to label batteries and battery-operated items with certain markings. This includes, for example, the symbol of the crossed-out waste bin (“separate collection”) as well as any other information. The marking must be clearly visible, legible, and permanently affixed to the battery or, if applicable, to the packaging and accompanying documents.
Yes, according to the EU Battery Regulation, retailers (including online retailers) are obliged to inform buyers (end users) about their role in waste prevention, the meaning of the markings on batteries, and environmentally-friendly disposal and return options for used batteries, among other things.
You can find the current legal texts here:
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