How Are Waste LMT Batteries Collected and Recycled?

LMT collection and recycling duties are the extended producer responsibility and waste handling duties that apply after an LMT battery reaches end of life, as set out in Regulation (EU) 2023/1542. Producers must finance and organise collection, treatment and recycling, and Member States must achieve collection objectives for waste LMT batteries. The passport supports those duties by carrying the identity, chemistry and dismantling information that a collector and recycler need, but the passport does not itself collect or recycle a battery.

The LMT collection picture differs from the portable collection picture in scale, handling and targets. LMT packs are larger, heavier and more varied than portable cells, collection points must handle packs safely, and transport must manage damaged packs separately. The collection objective for waste LMT batteries is 51 percent by the end of 2028 and 61 percent by the end of 2031, as stated in the Regulation summary material. Those objectives are system level targets, not duties placed on a single holder of one battery.

Who is the producer for LMT collection purposes?

The producer for extended producer responsibility purposes is the person who first makes a battery available on the market in a Member State, including by distance selling, subject to the detailed producer definition in the Regulation. Producer duties include registration in the Member State register, financing collection and treatment, meeting collection objectives through a producer responsibility organisation or individually, and reporting quantities placed on the market and collected. A producer who sells in several Member States carries producer duties in each Member State of sale, under the national arrangements that implement the Regulation.

Producer registration should be recorded per Member State, with the register entry, the producer responsibility organisation where used, and the reporting calendar for each state. A single Union level registration does not satisfy a national register duty, and a registration in one Member State does not cover sales in another. The record file should show, for each Member State, the registration evidence, the financing arrangement and the reporting evidence, so that a gap in one state is visible without searching the whole file.

What collection arrangements must exist?

Collection arrangements for waste LMT batteries must provide accessible collection points, safe handling, transport to permitted treatment facilities, and information for end users on separate collection and the separate collection symbol. Collection must be free of charge for end users and must not be conditional on purchase of a new battery. Distributors and other collection points play a defined role in taking back waste batteries, and producers must finance the network that makes collection available in practice, not only on paper.

Worked check: a cycle retailer takes back a damaged scooter pack. The retailer check covers safe storage apart from undamaged packs, labelling as a damaged pack where the procedure requires it, and handover to the producer collection route with a consignment record. A retailer who stores the damaged pack with general waste, or who charges the holder for take back, fails the collection arrangement on safety and on cost. The consignment record is the evidence that the pack entered the correct route.

What treatment and recycling targets apply?

Treatment and recycling of waste batteries must meet the recycling efficiency and material recovery targets in Annex XII to Regulation (EU) 2023/1542. Recycling efficiency targets are set by battery chemistry group, and material recovery targets are set for cobalt, copper, lead, nickel and lithium, with higher targets applying from the end of 2031 for lithium and for the other listed materials. The Commission assessment reported in September 2026 found the recycling targets fit for purpose, as checked on 28 October 2026, which means the targets in the Regulation remain the reference for planning.

Target reading needs care. Recycling efficiency measures the share of battery mass recycled, while material recovery measures the share of each targeted material recovered. A treatment process can meet one measure while missing the other, because chemistry, casing share and process route affect the two measures differently. A recycler report should therefore present both measures separately, with the chemistry group and the calculation method stated. A combined recycling claim that merges the two measures misstates the target structure.

How does the passport support collection and recycling?

The passport supports collection and recycling by carrying chemistry, hazardous substance, critical raw material, dismantling and safety information in the access tiers defined in Annex XIII. A collector uses the public and legitimate interest information to identify the pack, handle it safely and route it correctly. A recycler uses dismantling and substance information to select the treatment route and to meet the calculation and verification rules for recycling efficiency and material recovery. The passport does not replace consignment, treatment or reporting records, but it reduces the information gap at the point of handover.

Information access at end of life should be tested before it is needed. A collection point that cannot resolve a carrier, or a recycler that cannot reach dismantling information for a pack in hand, faces a handling delay at the point where delay creates safety and storage pressure. Periodic access testing, using sample packs and the access routes that collectors and recyclers will use, is part of collection readiness. A system that works for the placing operator but not for the end of life actor is incomplete for the full battery life cycle.

What information must end users receive?

End users must receive information on separate collection, on the meaning of the separate collection symbol, on the role of the end user in separate collection, and on the availability of collection points, together with safety information for handling and storage before handover. The information must be clear, accessible and tied to the battery model and the Member State collection arrangements that apply. General statements about recycling, without a collection route that the holder can actually use, do not meet the information purpose.

Information should be checked from the holder perspective: can a holder with a spent pack in hand find a collection point, understand that the pack must not enter mixed waste, and hand the pack over without charge. A check that starts from the producer website and ends at a collection point list that is current and local is a holder perspective check. A check that starts and ends with the producer information page is a publication check, not a holder check, and it can miss broken links, closed points and out of date lists.

What reporting and record duties follow collection?

Producers, producer responsibility organisations, collectors, recyclers and Member States carry reporting duties on quantities placed on the market, collected, treated and recycled, under harmonised reporting formats set by implementing acts. Reporting must be consistent across the chain, so that a quantity placed on the market in one report can be reconciled with a quantity collected and treated in later reports. Reporting errors that break reconciliation, such as double counting, missing chemistry splits or inconsistent units, undermine the collection objective assessment even when physical collection has taken place.

As checked on 28 October 2026, harmonised waste reporting formats were adopted in late 2025 and apply to Member State reporting, with the chain reporting duties set in the Regulation. A reporting file should carry the format version, the reporting period, the chemistry split and the reconciliation check performed. This guide gives general educational information only and is not individual legal advice. A reader with a specific battery or market decision should check the current Regulation text and any applicable delegated act, as checked on 28 October 2026, before acting.

This guide gives general educational information only and is not individual legal advice. A reader with a specific battery or market decision should check the current Regulation text and any applicable delegated act, as checked on 28 October 2026, before acting. Collection succeeds when a holder can find a point, hand over a pack without charge, and the pack can be traced to permitted treatment.