✅ At-a-glance: what you must do

Most producers/importers need to:

• 🧾 Register with the right body (often Stichting OPEN; car batteries via ARN)
• ♻️ Organise and finance collection and processing (alone or via a collective organisation)
• 🗺️ Provide a nationwide collection network
• 📢 Inform consumers about separate battery collection
• 📊 Report annually before 1 August to Rijkswaterstaat (weights placed on market + collected/processed)

👤 Who must comply?

You have UPV/EPR for batteries in the Netherlands if your business is the first to:

• place batteries (or battery-containing products) on the Dutch market under your own brand/name
• trade batteries (or battery-containing products) under your own brand/name
• import and place batteries (or battery-containing products) on the Dutch market
• sell from abroad directly to Dutch end users (distance sales)

🧩 Battery streams and the “registration route” in the Netherlands

1) ♻️ Streams with a general binding statement (AVV)

For certain battery streams, there is a general binding statement (AVV) and registration with a collective organisation becomes compulsory.

AVVs include:

• portable batteries up to 5 kg
• industrial batteries up to 1 kg
• bicycle batteries

For these, you must generally register with Stichting OPEN and pay a waste management fee, unless you have an exemption.

2) 🚗 Car batteries (starter + EV batteries)

Car batteries (including starter batteries and EV batteries) must be registered with Auto Recycling Nederland (ARN).

3) 🏭 Individual compliance route (where applicable)

You may meet obligations on your own or with other producers. Where you do not fall under a compulsory collective route, you still must comply with core duties (collection network, consumer information, reporting), and you must notify Rijkswaterstaat how you intend to collect and process.

📝 Registration & reporting: practical steps this service supports

Step 1: Confirm your obligations and scope

Map what you place on the market:

• battery category (portable / industrial / bicycle / car/EV)
• whether batteries are standalone or integrated in products
• whether you import, manufacture, or sell cross-border into NL

Step 2: Register with the correct organisation

• Stichting OPEN registration for batteries/accumulators (where applicable)
• ARN for starter batteries and EV batteries

Step 3: Set up take-back, collection, and recycling coverage

You must collect/process discarded batteries (or arrange it) and provide a nationwide collection network, using “the cleanest and best way possible.”

Step 4: Submit the required reports

• Annual report to Rijkswaterstaat before 1 August with:
• weight placed on the Dutch market (previous year)
• weight collected and processed (previous year)
• Portal statements for batteries: reporting is commonly done via myBatbase. Stichting OPEN indicates battery producers continue to use myBatbase for monthly, quarterly, or annual statements (depending on setup).

📊 What data you need for accurate reporting

To keep submissions consistent and defensible, you should be able to produce:

• 📦 Placed-on-market quantities by period (units and weights)
• 🧪 Battery type/chemistry and category mapping
• 🧾 Evidence for calculations (invoices, import docs, sales/dispatch reports)
• 🔁 Adjustments (returns, credits, exports where relevant)
• 🧮 A documented method for weight conversions and assumptions

myBatbase confirms that participants register the number of (products with) batteries first placed on the Dutch market and that the declarations are used to report total weight to the Dutch government.

🏪 Retailer take-back obligation (don’t miss this)

Retailers selling batteries (or products containing them) must take back discarded batteries free of charge and inform consumers where they can hand them in.

🧾 Traceability checklist (audit-ready, low friction)

Good traceability is simple when it’s structured. Maintain:

• SKU list + battery BOM (battery weight per product / per battery type)
• period-by-period placed-on-market totals tied to source data
• version history for calculations (what changed, when, and why)
• proof pack for each reporting period (exports/returns/credits, if used)
• approvals log (who validated submissions)

EU Batteries Regulation (EU) 2023/1542: what to watch

The EU Batteries Regulation applies directly across the EU and includes phased obligations; Chapter VIII (producer responsibility) applies from 18 August 2025.

In the Netherlands, EPR is referred to as UPV, and the Human Environment and Transport Inspectorate (ILT) oversees compliance with EPR regulations.

⭐ Why ComplyMarket is the best ever solution for Netherlands Battery EPR

ComplyMarket is a great and exceptional company for Netherlands battery EPR because it combines registration workflows, reporting operations, and traceability in one integrated Compliance Management Software platform—designed to keep every declaration consistent, evidence-based, and audit-ready.

With ComplyMarket, you can:

• centralise producer registration tasks (entities, scope, evidence)
• automate placed-on-market calculations (SKU/BOM logic + validation checks)
• manage deadlines and approvals for annual and periodic declarations
• maintain end-to-end traceability (data → submission → proof) with a clean audit trail
• scale across teams, product lines, and entities without spreadsheet risk

If you want the best ever, end-to-end way to comply with Extended Producer Responsibility requirements for batteries in the Netherlands, ComplyMarket delivers the most complete solution.