The French Décret No. 2024-1221 outlines significant regulations for the management and recycling of batteries under the Extended Producer Responsibility (EPR) framework. As environmental concerns grow, this decree ensures that producers of batteries are accountable for the entire lifecycle of their products. This shift aligns with both national and European efforts to promote sustainability and circular economy practices.

What Does the Decret Entail?

The decree applies to all types of batteries, including portable, industrial, automotive, and electric vehicle (EV) batteries. It mandates that producers, including manufacturers, importers, and distributors, are responsible for the design, collection, and recycling of their batteries. The key focus is on reducing the environmental impact of battery waste by improving recycling rates and ensuring that battery design supports efficient recycling processes.

Key Dates to Remember:

• Application Date: August 18, 2025
• Eco-Organism new data transmission rules : January 1, 2026

Application Date: August 18, 2025

Eco-Organism new data transmission rules : January 1, 2026

These deadlines mark the beginning of full implementation of the extended EPR obligations, requiring producers to adapt their processes well in advance.

Impacts on Battery Producers

The EPR Scope Expansion means that producers of all battery types must now comply with recycling and waste management obligations. This includes portable batteries, industrial batteries, and even batteries used in EVs. These obligations involve financial responsibility for the collection and recycling of batteries, which must be displayed transparently at the point of sale. Producers also have the option to delegate these responsibilities to eco-organisms or implement individual systems approved by the Ministry of Environment and Economy.

Design Requirements:

Battery producers are now required to design products that are easier to recycle, as per EU Regulation 2023/1542. This regulation, which replaced the 2006 Battery Directive, sets higher standards for sustainability, recycling, and material recovery across the EU.

Recycling Targets:

For example, the new regulation sets ambitious recycling goals, including:

• Lithium-based batteries: 65% by 2025 and 70% by 2030.
• Lead-acid batteries: 75% by 2025 and 80% by 2030.

Lithium-based batteries: 65% by 2025 and 70% by 2030.

Lead-acid batteries: 75% by 2025 and 80% by 2030.

Producers must ensure that their products meet these targets to comply with regulations.

Collection and Waste Management Responsibilities

Producers are also tasked with ensuring that batteries are collected separately from other waste and are processed by certified waste operators. Collection points must have clearly marked bins, and only approved operators can process the waste. Failure to comply can lead to significant fines, up to €3,750 per ton for non-compliant companies.

Financial Contributions and Modulation

Producers' contributions to EPR schemes will vary depending on the recyclability of their batteries. For instance, batteries designed for easy disassembly or recycling could result in lower fees for producers. This introduces a financial incentive to prioritize eco-design and circular economy principles.

Broader Industry Implications

For producers, the new regulations require adjustments across the supply chain. Companies will need to:

• Redesign products to meet eco-design requirements.
• Adapt to higher recycling and waste management costs.
• Meet new reporting obligations regarding the quantities of batteries placed on the market and those recycled.

Redesign products to meet eco-design requirements.

Adapt to higher recycling and waste management costs.

Meet new reporting obligations regarding the quantities of batteries placed on the market and those recycled.

However, these challenges present opportunities for innovation. Companies that invest in sustainable battery designs may benefit from lower EPR fees and enhanced market positioning, offering a competitive edge in the growing green economy.

Conclusion

The Decret Français No. 2024-1221 introduces significant responsibilities for battery producers, with a strong focus on sustainability, transparency, and the circular economy. Producers must anticipate increased costs and administrative obligations but also have opportunities to innovate and gain market advantages by prioritizing recycling-friendly designs. By complying with these new regulations, companies will not only contribute to reducing environmental impact but also position themselves for success in the evolving green energy market.

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