Foreign battery manufacturers, electric-vehicle suppliers, importers and industrial groups placing batteries on the Italian market must navigate a new directly applicable EU framework and Italian implementation. Regulation (EU) 2023/1542 covers battery sustainability, product information and waste-battery producer responsibility. Italian Legislative Decree No 29 of 10 February 2026 entered into force on 7 March 2026.
Product categories and supply-chain roles
The EU framework differentiates portable batteries, starting-lighting-ignition (SLI) batteries, light means of transport (LMT), electric vehicle (EV) and industrial batteries. Requirements must be assessed for the specific category, product, battery incorporated in another product and actual route to the Italian market. A producer for EPR purposes is not necessarily the entity that physically assembled the battery.
Italian producer register and producer responsibility
Article 20 of Legislative Decree No 29/2026 establishes the national Register of Battery Producers as part of the national register system; Article 25 sets out producer responsibility for batteries first made available on the Italian market. The provision is also relevant to batteries resulting from certain preparation for re-use, repurposing and remanufacturing operations. Registration, responsible economic operator and applicable representation arrangements call for a documented legal assessment.
Waste-battery collection, financing and second-life arrangements
Legal questions include producer responsibility schemes, the allocation of collection and treatment costs, contracts with distributors, batteries recovered from products, second-life applications and claims relating to reused or remanufactured products. EU product-level sustainability and information obligations have different application dates; they must not be collapsed into one general deadline.
Defined Italian-law legal mandates
We provide opinions on producer qualification, registration responsibilities, sector-specific obligations, supply and distribution agreements, duties affecting repurposed batteries and disputes with public authorities or schemes. Specialist engineering, laboratory analyses and operational recycling activity remain outside the legal service.
Academic approach and IR Global cooperation
From 28 November 2026, Alfonso Maria Fimiani holds IR Global’s exclusive Environmental Law position for Italy. The professional work is informed by university research on EPR and the circular economy.
An initial request should identify battery categories, commercial actors, Italian import or distribution arrangements, relevant contracts and the legal question. Circular economy and EPR · Contact · Italiano · Français.
Primary sources: Regulation (EU) 2023/1542; Italian Legislative Decree No 29/2026.
