Croatia Battery EPR Compliance Training – From A to Z

Understand Croatia's battery EPR requirements through practical, in-person training covering producer registration, reporting, collection, recycling, fees and EU battery legislation.

Entering the Croatian market with batteries is not just a product-sales question. Manufacturers, importers and online sellers may become responsible for Extended Producer Responsibility (EPR) when they first place batteries on the Croatian market, even when those batteries are incorporated into electrical equipment, vehicles or light electric transport. Responsibility depends on how products reach Croatian customers, who places them on the market and which battery category applies.

Croatia operates a national EPR system managed by the Environmental Protection and Energy Efficiency Fund (FZOEU), with producer information submitted through the Register of Producers with Extended Responsibility (RPPO). Regulatory amendments introduced in June 2026 also changed battery reporting periods. Companies must reconcile battery quantities, weights, imports, exports and returns while determining how waste-management fees interact with other product obligations.

Meanwhile, Regulation (EU) 2023/1542 introduces separate product and waste-management requirements for portable, starting, lighting and ignition (SLI), light means of transport (LMT), electric vehicle (EV) and industrial batteries. Different provisions have different application dates.

This one-day onsite training connects these requirements to practical business decisions: identifying the responsible producer, preparing registration information, maintaining accurate records, understanding collection arrangements and preparing for upcoming compliance milestones.

Event Details

 

Important: The training covers Croatian battery compliance obligations. The event takes place physically at ComplyMarket GmbH in Munich, Germany.

What Will You Learn?

By the end of the training, participants will be better prepared to:

1. Understand Croatia's battery legal framework: Identify the national legislation, competent authorities and applicable EU rules.

2. Classify batteries correctly: Distinguish portable, SLI, LMT, EV and industrial batteries under the applicable regulatory definitions.

3. Identify producer responsibility: Assess obligations for manufacturers, importers, private-label businesses and cross-border sellers.

4. Understand RPPO registration: Recognize registration requirements, access arrangements and the documentation needed for reporting.

5. Prepare accurate battery reports: Organize market-placement quantities, battery mass, product categories and supporting evidence.

6. Understand collection and take-back: Identify the responsibilities of producers, distributors, collectors and treatment operators.

7. Assess battery EPR costs: Distinguish statutory waste-management charges from transport, treatment, administration and representation costs.

8. Prepare for upcoming deadlines: Understand the phased requirements for battery passports, marking, removability and supply-chain due diligence.

9. Apply requirements to real business scenarios: Work through a Croatian market-entry example involving battery-containing products.

One-Day Training Program

09:00–09:45 | Session 1: Croatia's Battery Legal Framework and Product Scope

The day begins with an explanation of the Croatian battery regulatory framework and how national waste-management requirements interact with EU legislation.

Topics covered:

• Croatia's Waste Management Act (Zakon o gospodarenju otpadom) and the country's battery implementation legislation, including NN 152/2024.
• The Fund-system Ordinance, NN 124/2023, as amended by NN 60/2026.
• The application of Regulation (EU) 2023/1542 and its phased requirements.
• The roles of FZOEU, the environmental ministry and Croatian supervisory authorities.
• Battery categories: portable, SLI, LMT, EV and industrial batteries.
• Battery-containing equipment, vehicles, replacement batteries and special applications.
• The distinction between EPR responsibilities, product conformity and waste-management permits.

09:45–10:30 | Session 2: Who Is a Battery Producer in Croatia?

Battery producer status does not depend solely on who manufactures a battery. Businesses importing, rebranding or selling batteries across borders may also assume obligations.

Topics covered:

• Producer definitions under Article 3(47) of Regulation (EU) 2023/1542.
• Croatian manufacturers, importers and first suppliers to the national market.
• Private-label brands and batteries sold under another company's trademark.
• Batteries incorporated into electronic devices, appliances, e-bikes and vehicles.
• Cross-border business supply chains and direct online sales to Croatian end-users.
• Authorised representatives for EPR, including the requirements applicable to qualifying distance sellers.
• Determining responsibility where manufacturers, distributors and importers operate in the same supply chain.

10:30–10:45 | Coffee Break

10:45–11:30 | Session 3: RPPO Registration and EPR Participation

Croatia's RPPO provides the national digital mechanism for producer registration and reporting. Participants examine how businesses interact with this system.

Topics covered:

• The purpose of the Registar proizvođača s proširenom odgovornosti (RPPO).
• Registration responsibilities under Croatia's Fund-managed EPR framework.
• RPPO access through the Croatian e-Građani/NIAS system and applicable authorisations.
• Information required to identify the producer and relevant battery products.
• Procedures for representatives of foreign manufacturers, including supporting mandates.
• The Fund-managed system and why a separate commercial PRO membership should not be assumed.
• Maintaining accurate registration information and checking submitted records.

11:30–12:15 | Session 4: Battery Reporting, Data Management and Compliance Records

Reliable reporting starts with accurate information from procurement, sales, logistics and product teams.

A particular focus is Croatia's 2026 transition from monthly battery reporting to annual reporting.

Topics covered:

• Battery quantities, mass, chemistry and category information.
• Recording batteries placed on the Croatian market.
• Imports, intra-EU supplies, exports, withdrawals and transit movements.
• Monthly RPPO reporting for accounting periods up to 30 June 2026.
• Consolidated reporting for 1 July–31 December 2026, due 20 January 2027.
• Annual reporting for subsequent calendar years, due by 20 January of the following year.
• Reconciliation of RPPO submissions with invoices, shipment information, sales data and evidence supporting corrections.

12:15–13:00 | Lunch Break

13:00–13:45 | Session 5: Waste Battery Collection and Take-Back Obligations

Waste battery collection involves several parties. This session explains how the Croatian system operates and how the applicable responsibilities differ by battery category.

Topics covered:

• Separate collection requirements for waste batteries.
• The Fund's role in arranging collection through contracted operators.
• Distributor take-back obligations under the EU Batteries Regulation.
• Collection arrangements for portable batteries.
• Different arrangements for LMT, SLI, industrial and EV batteries.
• Safe handling of used, damaged and potentially hazardous batteries.
• Waste batteries removed from discarded electrical equipment and end-of-life vehicles.

13:45–14:30 | Session 6: Battery EPR Fees and Financial Planning

Battery compliance budgets should reflect actual legal charges rather than assumed membership fees or generic European price estimates.

Croatia's statutory framework includes Fund waste-management charges. Their application depends on the relevant product and fee provisions.

Topics covered:

• Croatia's Waste Management Fee and Deposit Fee Regulation, NN 137/2024.
• The waste-management fee framework for portable batteries under Annex V.
• The treatment of batteries incorporated into electrical equipment or vehicles under the relevant fee provisions.
• The role of battery mass, applicable unit fees and calculation coefficients.
• Differences between statutory Fund charges and commercial service-provider costs.
• Potential collection, storage, transportation, treatment and recycling expenses.
• Budgeting for future volumes, product mix changes and adjustments supported by export or withdrawal records.

The session explains how to check applicable official rates and decisions without assuming that one fee applies to every battery category.

14:30–14:45 | Coffee Break

14:45–15:30 | Session 7: Waste Battery Treatment, Recycling and Logistics

Once batteries become waste, proper collection and treatment are essential to environmental compliance and operational safety.

Topics covered:

• Croatian requirements for waste collectors and treatment operators.
• The Fund's contracts with eligible collection and treatment providers.
• Sorting and managing different battery chemistries and types.
• Managing damaged lithium-ion batteries and associated fire risks.
• Storage, packaging, transport and waste-transfer documentation.
• EU collection, recycling-efficiency and material-recovery requirements.
• Maintaining evidence of transfer to appropriately authorised waste-management operators.

The session also explains how EU collection targets differ between portable and LMT batteries and why they should not be confused with individual retailer collection quotas.

15:30–16:30 | Session 8: Battery Labelling, Product Requirements and Upcoming Milestones

Battery EPR is only one part of battery compliance. Manufacturers and importers must also consider product requirements that apply independently of registration and waste-management fees.

Topics covered:

• Battery marking, separate-collection symbols and applicable heavy-metal information.
• The EU's phased battery information and labelling requirements.
• CE marking, conformity assessment and technical documentation where applicable.
• Battery removability and replaceability rules beginning 18 February 2027, subject to exemptions.
• QR-code and battery passport requirements from 18 February 2027, including the categories requiring a passport.
• Carbon footprint, performance, durability and recycled-content requirements according to their applicable legal schedules.
• Battery supply-chain due diligence obligations scheduled from 18 August 2027, subject to the regulation's scope and exemptions.
• Separating Croatian national EPR reporting from EU product-level documentation.

This session provides a framework for identifying which requirements are already applicable, which are conditional on implementing measures and which begin later.

16:30–17:00 | Session 9: Practical Croatia Battery EPR Case Study and Q&A

The final session applies the day's material to a cross-border company selling battery-containing products to Croatian customers.

Practical exercise:

• Identify the producer responsible for the Croatian market.
• Classify batteries in power tools and e-bikes.
• Determine RPPO registration and representation requirements.
• Identify relevant reporting data and likely financial obligations.
• Review collection responsibilities, documentation and the next compliance actions.

Participants can also raise questions about the regulatory principles covered during the day.

Who Should Attend?

This training is intended for organisations manufacturing, importing, supplying or selling batteries and battery-containing products in Croatia.

It is particularly relevant for:

• Battery manufacturers and importers: Companies placing standalone batteries or accumulators on the Croatian market.
• Electronics and electrical equipment manufacturers: Businesses supplying products containing portable or industrial batteries.
• EV and e-mobility companies: Vehicle manufacturers, importers, e-bike suppliers and businesses handling LMT or EV batteries.
• Brand owners and OEMs: Companies responsible for private-label products or complex supplier arrangements.
• Distributors and online sellers: Businesses selling batteries or battery-powered products to Croatian customers.
• Compliance and sustainability professionals: Teams responsible for producer obligations, reporting, waste management and regulatory monitoring.
• Supply chain and procurement teams: Professionals responsible for gathering reliable battery information from suppliers.
• Finance and operations teams: Employees responsible for compliance budgets, statutory charges and collection arrangements.

The course is suitable for professionals establishing their first Croatian battery compliance process and those reviewing existing arrangements following regulatory changes.

Why Attend ComplyMarket's Battery EPR Training?

Battery compliance responsibilities often involve several departments. Legal teams interpret legislation, product teams classify batteries, logistics departments track shipments and finance teams manage statutory charges.

When these activities are disconnected, reporting errors and uncertainty over producer responsibilities can arise.

ComplyMarket's training is structured around the practical decisions businesses need to make when supplying batteries or battery-powered products to Croatia.

The training focuses on:

• Connecting Croatian legal requirements with real business activities.
• Understanding how RPPO registration and reporting fit into internal processes.
• Recognising differences between battery categories and commercial supply models.
• Identifying information needed from manufacturers, suppliers and distributors.
• Understanding the relationship between waste-management obligations and EU product requirements.
• Applying compliance principles to a realistic cross-border case study.

Participants receive a structured explanation of the relevant requirements and opportunities to discuss practical implementation questions. The training is educational and does not replace company-specific legal advice.

Frequently Asked Questions

1. Is battery producer registration mandatory in Croatia?

Yes. Businesses that qualify as battery producers under the applicable rules must comply with producer registration requirements. Croatia uses the RPPO, administered through FZOEU, for the national registration and reporting process.

The EU Batteries Regulation requires producers to be registered in the Member State where they first make batteries available on the market. A company should determine its producer status and applicable registration obligations before beginning relevant Croatian market activities.

2. How are batteries classified for Croatian EPR purposes?

Croatia applies the EU Batteries Regulation's five categories: portable, starting, lighting and ignition (SLI), light means of transport (LMT), electric vehicle (EV) and industrial batteries.

Classification depends on regulatory definitions rather than chemistry alone. For example, an e-bike traction battery is generally assessed as an LMT battery, while a suitable handheld consumer-device battery may qualify as portable. Category classification affects collection requirements and other obligations.

3. Do foreign manufacturers and importers have battery EPR obligations?

Yes, where they meet the applicable producer definition.

An importer or business first supplying batteries in Croatia may be a producer for EPR purposes. A company established elsewhere that sells batteries directly to Croatian end-users through distance contracts may also qualify.

The assessment should cover the actual sales model, supply chain and product category, including batteries incorporated into equipment or vehicles.

4. Is an authorised representative required in Croatia?

Article 56(3) of Regulation (EU) 2023/1542 requires producers qualifying under Article 3(47)(d)—cross-border distance sellers supplying end-users—to appoint an EPR authorised representative in each relevant Member State.

Croatia's RPPO also supports registration by representatives of foreign manufacturers, with documentary proof of authorisation.

An EU proposal to suspend certain representative requirements remained under legislative consideration in October 2026. Businesses should distinguish this proposal from the requirements currently in force.

5. Must battery producers join a producer responsibility organisation?

Croatia's national battery EPR framework is managed by FZOEU. The Fund acts as the designated producer-responsibility organisation and arranges waste battery collection and treatment through contracted operators.

Producers should therefore follow the applicable Croatian registration, reporting and Fund contribution requirements rather than assume membership in a separate commercial PRO is mandatory.

Commercial support arrangements do not replace statutory obligations.

6. How frequently must battery quantities be reported?

Croatia introduced new reporting periods in June 2026.

Reports for accounting periods up to 30 June 2026 remained subject to monthly reporting. Battery quantities for 1 July–31 December 2026 must be submitted together through RPPO by 20 January 2027.

For calendar years beginning in 2027, the general reporting deadline is 20 January of the following year.

Businesses should retain the underlying records supporting their submissions.

7. Who is responsible for collecting and recycling waste batteries?

The Croatian Fund coordinates the national system, while contracted collectors and treatment operators carry out collection and treatment activities.

Distributors also have take-back obligations under the EU Batteries Regulation, generally covering the battery categories they offer or previously offered. Applicable take-back must be free of charge and cannot be made conditional on purchasing a replacement battery.

Collection arrangements and treatment requirements differ by battery category.

8. How are battery EPR fees determined, including batteries in equipment?

Croatia's statutory fee framework is established under national regulations and applicable Fund decisions.

Annex V of NN 137/2024 addresses waste-management fees for portable batteries and provides specific treatment for batteries incorporated into qualifying electrical equipment or vehicles.

Companies should evaluate the relevant product category, mass, applicable calculation provisions and supporting data. The presence of a battery in a product does not automatically justify applying a separate standalone-battery fee.

9. Which upcoming battery compliance deadlines are important?

Important milestones include:

• 20 January 2027: Croatia's transitional RPPO report for the second half of 2026.
• 18 February 2027: EU battery passport requirements for EV, LMT and industrial batteries above 2 kWh, together with applicable QR-code and removability provisions.
• 18 August 2027: Application of the EU battery due diligence requirements to economic operators within scope.
• 31 December 2027: The EU's 63% collection target for waste portable batteries.

Other product requirements depend on battery category, exemptions and relevant delegated or implementing measures.

10. Is a Croatian battery registration valid in other EU countries?

No. Battery EPR responsibilities are linked to the territory where batteries are first made available.

Registration with Croatia's RPPO does not automatically satisfy producer registration obligations in Germany, Austria, Slovenia or another Member State.

Companies supplying several EU markets must assess the applicable producer definitions, registration arrangements, representation obligations and reporting requirements in each country.

Register Your Interest in Croatia Battery EPR Training

Are you responsible for battery compliance in Croatia or preparing to introduce batteries and battery-powered products to the Croatian market?

Join ComplyMarket's one-day, in-person training to develop a clearer understanding of producer responsibilities, RPPO reporting, battery waste management and upcoming legal requirements.

To register your interest or request event information, contact:

info@complymarket.com