Battery EPR in Czechia for online sellers
A customer in Czechia orders a wireless sensor with two AA batteries in the box. Your sales export shows one sensor. Your battery records need to show the two batteries that went with it. If a customer orders a rechargeable sensor instead, its built-in battery also belongs in those records. The same applies to replacement batteries you sell separately. EU Batteries Regulation, Article 1(3)
These records support extended producer responsibility, or EPR. In practice, battery EPR covers registration, financing and organising the collection and treatment of waste batteries, and reporting the batteries you supply. Czech equipment and packaging obligations can apply to the same shipment. The order data can be shared, with separate quantities and compliance arrangements for each obligation. EU Batteries Regulation, Articles 55–61 · Worked example for Czech WEEE reporting
Identify who supplies the battery to the Czech market
If your business is based in another EU country or outside the EU and sells by distance directly to Czech end users, you are the battery producer for EPR purposes. An end user can be a consumer or a business using the product itself. Appoint a representative established in Czechia by written mandate and confirm the Czech registration before making the batteries available on the market. The same analysis applies when you sell through a marketplace and remain the seller to the end user. EU Batteries Regulation, Articles 3(1)(47)(d), 55 and 56
If a Czech distributor buys the goods for resale, check which business first supplies the batteries on the Czech market and which registrations cover that route. If you use a distributor for some orders and sell directly to Czech end users for others, record the routes separately. Start with the seller named on the order or invoice and what the Czech buyer actually does with the goods. EU Batteries Regulation, Article 3(1)(47)
Check what each model and bundle contains
Ask the supplier for a specification that identifies the exact battery model, its chemistry, unit weight and how many are supplied with the product. Keep the supporting document with the version of the product it describes. For a product with several bundles, record which ones come with batteries and how many each bundle contains. A listing that says “batteries required” leaves a question for the supplier about what is actually in the box.
The EU rules distinguish portable batteries, batteries for light means of transport such as e-bikes, starter batteries, industrial batteries and electric vehicle batteries. A sealed battery weighing up to 5 kg can qualify as portable if it meets the other criteria for that category. Check its intended use, especially for equipment designed for industry or transport. EU Batteries Regulation, Articles 1 and 3
Calculate the battery weight from actual Czech sales
Imagine an e-shop has these three lines in its Czech sales export for a reporting period. The battery weights are illustrative.
| Product supplied | Czech units | Batteries per unit | Weight per battery | Battery total |
|---|---|---|---|---|
| Wireless sensor kit with two AA cells | 120 kits | 2 | 23 g | 240 cells, 5.52 kg |
| Replacement pack with four of the same AA cells | 30 packs | 4 | 23 g | 120 cells, 2.76 kg |
| Rechargeable device with a built-in pack | 40 devices | 1 | 48 g | 40 packs, 1.92 kg |
The first two rows account for 360 AA cells weighing 8.28 kg. The last row accounts for 40 rechargeable packs weighing 1.92 kg. Keep the battery types separate in your source records so you can apply your scheme’s categories and reporting format. For the rechargeable device, use the weight of the battery pack supplied with the product and confirm how the scheme wants it recorded. EU Batteries Regulation, Article 75
If a supplier changes the battery during the year while your shop keeps the same SKU, record when the change took effect. Match each Czech sale to the version actually supplied. A missing supplier weight is an item to resolve before you confirm the figures. Keep the sales export, the version of the catalogue used to calculate the figures and the report that was submitted.
Confirm the Czech registration and reporting arrangements
Check the producer and any existing representative in the Ministry of the Environment’s public registers. If you plan to fulfil your obligations through a collective scheme, confirm that its authorisation and your agreement cover the categories you supply. Agree who handles the registration, which period your first report covers and how to submit updates or corrections. Czech battery producer register · Authorised representatives · Collective battery schemes
The EU rules provide for annual reporting to the competent authority by the relevant producer or producer responsibility organisation. For your own reporting to a scheme, use the deadlines, format and instructions agreed with that scheme. Battery distributors also have take-back duties for categories they offer as new batteries. If this applies to your online shop, arrange free take-back without requiring a new purchase and explain to Czech customers where they can return their batteries. Discarded devices containing batteries follow the applicable equipment collection route. EU Batteries Regulation, Articles 57, 62 and 75
Start with one product specification
Pick a product you sell to Czech customers and check whether a battery ships with it, what the battery weighs and who is responsible for its first supply on the Czech market. A supplier specification and a sample Czech sales export are enough to start the discussion with Kodo. We can help you identify the applicable scope and organise battery records alongside your equipment and packaging records in the client portal. Czech WEEE and battery EPR services · Contact Kodo
Czech battery EPR: which batteries to record and how to prepare