✅ Who must comply

You are typically in scope if you are the entity that first makes batteries available in Lithuania, for example:

• Lithuanian manufacturers placing batteries on the market
• Importers bringing batteries (or products containing batteries) into Lithuania
• Distance sellers/non-established producers selling into Lithuania (often needing a local EPR setup under EU rules)

🧭 What Battery EPR requires in Lithuania (practical checklist)

1) 📝 Register (or update registration) in GPAIS

Producers and importers register in the GPAIS “Gamintojų ir importuotojų sąvadas” (public register).

Prepare the essentials

• Company details and contacts
• Battery scope (types/categories and required attributes)
• Your chosen compliance route (collective fulfilment via an organisation)

2) 🤝 Fulfil obligations collectively via a licensed organisation (PRO)

Lithuania’s planned approach is that producers organise battery waste management collectively by appointing a producer responsibility organisation authorised under the EU Batteries Regulation.

3) ♻️ Organise take-back, separate collection, and treatment

Under the EU Batteries Regulation, producers must ensure separate collection and the transfer of waste batteries to treatment/recycling, with requirements varying by battery category.

4) 🛒 Distributor (retailer) take-back duties

Distributors must accept waste batteries free of charge from end users without requiring a purchase, then hand them to the producer responsibility organisation or designated waste operators.

5) 🧾 Keep placed-on-market accounting (major 2026 change)

From 1 January 2026, producers no longer need to keep battery accounting inside GPAIS, but must maintain internal accounting (including a battery list and required data points) and provide it to the organisation fulfilling EPR on their behalf.

6) 📤 Annual reporting pathway + first key deadline

After each calendar year, the appointed organisation submits the annual battery report into GPAIS.

The Ministry of Environment states the first annual battery reports are due by 30 June 2027 (for the first reporting year under the new approach).

🏢 Licensed producer responsibility organisations (PROs) in Lithuania

Lithuania publishes an official list of licensed producer/importer organisations and the licence scopes they hold (including licences covering batteries/accumulators).

Use this list to identify eligible organisations for collective compliance.

📦 What data you should track for audit-ready compliance

To stay defensible (and to support your organisation’s annual reporting), maintain a clean internal dataset that can answer:

• What batteries you placed on the Lithuanian market (product/SKU → battery type)
• Which category/chemistry each battery belongs to (as required under EU rules)
• How much you placed on the market per year (by category)
• Supporting evidence: sales/shipping extracts, BOMs, supplier declarations, and calculation logic

⚠️ Common pitfalls to avoid

• Missing registration updates when scope changes (new categories/chemistries)
• Weak SKU mapping (products with embedded batteries not captured properly)
• Unverifiable calculations (no source files, no change history, no versioning)
• Late data handover to the organisation—leading to rushed reporting and higher error risk

🧩 What this Lithuania Battery EPR service delivers (registration → reporting → traceability)

🗂️ Registration readiness (GPAIS)

• Structured onboarding checklist and data pack for GPAIS registration/updates
• Scope mapping for batteries sold standalone and embedded in products

📊 Reporting-ready placed-on-market dataset

• Automated aggregation by battery type/category/required attributes
• Built-in validation checks to reduce misclassification and double counting
• Year-end handover pack aligned to the organisation’s reporting needs

🔍 Traceability & audit trail

• Evidence repository (supporting files, declarations, contracts)
• Change logs and version history for calculations
• Audit exports showing SKU → battery attributes → quantities → annual totals

❓ Quick FAQs

Do producers still have obligations if the organisation reports?
Yes. Producers must keep internal accounting and provide required annual data to the organisation in the format and timelines it sets.

When do the new reporting timelines start?
Lithuania indicates the first reporting year for the new approach is 2026, with the first annual submissions due 30 June 2027.

Are retailers obligated to accept waste batteries?
Yes—take-back must be free of charge and without a purchase requirement.

⭐ Why ComplyMarket for Lithuania Battery EPR

ComplyMarket provides a single, integrated Compliance Management platform to run Lithuania battery EPR end-to-end: GPAIS registration support, structured placed-on-market accounting for the post-2026 model, PRO coordination packs, and audit-ready traceability.

It reduces manual work, improves data accuracy, and keeps every obligation defensible when annual reporting is compiled and submitted through licensed organisations.