Do Foreign Battery Producers Need an EPR Authorized Representative in France?
FR EPR AR
Ying
8/18/20262 min read
For international companies selling batteries, battery-powered products or electrical and electronic equipment in France, Battery EPR in France is an important compliance requirement.
Many foreign companies ask:
“I already have a Battery EPR UIN. Do I still need a French EPR Authorized Representative?”
For eligible foreign producers, the answer is yes. The Authorized Representative requirement for Battery EPR did not start only in 2026.
1. When Did the Battery EPR Authorized Representative Requirement Start?
France introduced important changes to its Battery EPR system from 18 August 2025.
French Decree No. 2024-1221 of 27 December 2024 revised the Battery EPR framework and introduced five main battery categories.
At the same time, Regulation (EU) 2023/1542 on batteries and waste batteries requires certain producers to appoint an EPR Authorized Representative in the Member State where they sell batteries, through a written mandate.
Since 10 July 2026, France has also introduced a broader legal framework for a French EPR Authorized Representative (Mandataire REP) under Article L.541-10-9-1 of the French Environmental Code.
For foreign battery producers, Battery EPR registration and the appointment of an EPR Authorized Representative should therefore be checked separately.
2. What Are the 5 Battery EPR Categories in France?
The French Battery EPR system currently covers 5 main categories:
Portable Batteries Examples: AA, AAA, button cells, etc.
Light Means of Transport (LMT) Batteries Examples: E-bikes, e-scooters, etc.
Industrial Batteries Examples: Industrial equipment, energy storage systems, UPS, etc.
SLI Batteries Examples: Starting, lighting and ignition batteries for vehicles
Electric Vehicle (EV) Batteries Examples: Batteries for electric and hybrid vehicles
Companies need to identify the applicable battery category based on the type, weight and intended use of the battery.
3. Multiple Battery Categories Must Be Managed Separately
If a company sells several types of batteries, for example:
Portable + LMT + Industrial
the applicable categories must be covered and reported separately.
In simple terms:
Multiple battery categories → separate management and reporting.
However, this does not mean that each category has its own UIN.
4. Minimum Annual EPR eco-contribution per Battery Category
Under the 2026 Battery EPR fee structure published by ecosystem and Batribox, the minimum annual EPR contribution is €200 excluding VAT per battery category.
For example, if a company is subject to:
Portable Batteries
LMT Batteries
Industrial Batteries
the minimum annual contribution would be:
€200 × 3 = €600 excluding VAT per year
The actual EPR contribution may vary depending on the battery category, quantity, weight, chemistry and applicable fee structure.
5. One UIN for the Battery EPR Scheme
The French UIN (Unique Identification Number) is assigned by EPR scheme.
The five battery categories belong to the same Battery EPR scheme, so companies do not receive a separate UIN for each battery category.
In simple terms:
5 battery categories → separate management and reporting → one Battery EPR UIN.
If a company is also subject to other EPR schemes, such as Packaging EPR or WEEE EPR, those schemes must be managed separately and have their own UIN.
6. How Can Foreign Companies Check Their Battery EPR Compliance?
Foreign producers should check:
Whether their products contain or are sold with batteries;
Which of the five Battery EPR categories apply;
Whether each applicable category is properly covered and reported;
Whether the Battery EPR UIN is in place;
The applicable EPR contributions and annual fees;
Whether a French EPR Authorized Representative has been properly appointed.
Need a French EPR Authorized Representative for Battery EPR?
LINK GREEN INTERNATIONAL supports international companies with their Battery EPR compliance in France, including:
Battery EPR registration
UIN application and management
Identification of the five battery categories
Battery data reporting
Communication with EPR compliance organizations
EPR contribution management
French EPR Authorized Representative services
If your products involve batteries, WEEE, packaging or other French EPR schemes, LINK GREEN can help identify your applicable obligations and manage your French EPR compliance.