(EU) 2023/1542 · Annex XIII(1)(s) -> Article 74(1)(c)
Collection points in the passport: one record, twenty-seven different answers
Of the six fields, this is the only one whose correct value is not a property of the battery but a property of the country the battery happens to be in. Point (c) requires information on separate collection, on take-back and collection points, and on the preparation for re-use, preparation for repurposing and treatment available for waste batteries. The networks under Articles 59, 60 and 61 are run by producers and producer responsibility organisations per Member State. A passport, however, is a single record for a single battery — and that battery travels.
Everything that has to be stated
Not just collection points. Point (c) names, in the same breath, separate collection, take-back and collection points, preparation for re-use, preparation for repurposing and the treatment available. Text that says only where to hand the battery in omits the other half of the requirement — what can then actually happen to it. For a fleet operator that second half is often the more interesting one.
The answer is tied to the country, not the model
The collection network for the same battery differs between Slovenia, Germany and Poland, because a different obligated party builds it in each Member State. A hardcoded list of addresses in the passport is therefore wrong the moment the battery crosses a border. The arrangement that holds up is a reference that resolves against the country where the battery is placed on the market, not a transcribed list of locations.
The language is not your choice
The closing part of Article 74(1) requires the information to be made available in a language or languages which can be easily understood by end-users, as determined by the Member State in which the battery is to be made available on the market. It must also be made available at regular intervals for each battery model, as a minimum at the point of sale in a visible manner and through online platforms. English on its own is therefore not a sufficient answer.
The value goes stale on its own
Collection networks change, contracts with producer responsibility organisations are signed and terminated, treatment capacity opens and closes. At the same time Article 77 requires the passport to remain available after the economic operator ceases to exist or ceases its activity in the Union. The content of this field therefore has to outlive you — which argues against writing specific addresses into it and in favour of a maintained reference.
Where it goes wrong
- A single static list of collection points for the whole Union.
- Site addresses hardcoded into the passport instead of a reference that is maintained.
- Describing only your own take-back service and not the statutory network under Articles 59 to 61.
- Text in a single language, although Article 74(1) ties the language to the Member State.
- Listing collection points only, with no preparation for re-use, preparation for repurposing or treatment available.
Frequently asked
Do I have to list every collection point in the Union?
Point (c) requires information on the take-back and collection points available. In practice that means a route to the current network in the country where the battery is placed on the market, not an exhaustive list of every location in the Union.
What language does this text have to be in?
A language or languages which can be easily understood by end-users, as determined by the Member State in which the battery is to be made available on the market. The Member State determines that, not you.
What if the collection network changes after the passport is issued?
The content still has to be usable. Since Article 77 requires the passport to remain available even after the economic operator ceases to exist, hardcoded addresses age badly; a maintained reference does not.
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