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Built-in battery, no battery EPR? A common mistake when selling electronics in Spain

2026-10-30 · IberTrust Global

Many sellers of electronics assume battery rules only concern companies that sell loose batteries. Marketplaces and authorities do not see it that way: a battery inside your product is still a battery placed on the market.

Short answer

If your product contains a battery and you ship it to end users in Spain from outside Spain, you should assume you have battery EPR obligations there, in addition to WEEE (electrical equipment) obligations for the device.

Why built-in batteries count

  • The EU Batteries Regulation (EU) 2023/1542 has applied since 18 February 2024, and its extended producer responsibility rules since 18 August 2025.
  • Producer responsibility covers batteries whether sold separately or incorporated in appliances, light means of transport or other vehicles.
  • A seller who ships directly to end users in another Member State is normally treated as the producer in that country.

Two registrations, not one

Typical products such as wireless earbuds, smart watches, electric toothbrushes, toys with rechargeable packs or e-bikes usually trigger both:

  • WEEE for the electrical device (Directive 2012/19/EU and Spain's Royal Decree 110/2015)
  • Batteries for the cell or pack inside it

Having a WEEE number does not cover the battery, and the reverse is also true.

What this means in practice for Spain

  • Registration as a battery producer and membership of a collective scheme for the relevant battery category (portable, LMT, industrial…)
  • Periodic reporting of the quantities and weights placed on the market
  • Producer registration numbers shown on invoices and, for distance sales, on the sales website or marketplace listing, according to MITECO guidance
  • For companies with no establishment in Spain: an authorised representative for EPR purposes

Typical warning signs

  • A marketplace asks for a battery or WEEE registration number for Spain and your listing is suppressed
  • Your supplier says “the battery is already compliant” — that refers to product safety and CE, not to your EPR registration
  • You registered packaging in Spain but never battery or WEEE

Next step

Send us your product list (with battery type and whether it is removable), your target countries and sales channels. IberTrust Global S.L. will tell you which registrations apply in Spain and what documents to prepare.

Request a WEEE / battery check →
Or email contact@ibertrust.info.

Sources: Regulation (EU) 2023/1542 (EUR-Lex); MITECO guidance on battery producers; Directive 2012/19/EU. General information, not legal advice.