What is Lithuania EPR Batteries

Lithuania's battery EPR framework is governed by Regulation (EU) 2023/1542 — the EU Battery Regulation — which applies directly in all EU Member States from 18 August 2025. At national level, Lithuania implements battery EPR through its Law on Waste Management and subordinate legislation governing producer and importer responsibilities for batteries and accumulators. The competent authority for producer registration and EPR enforcement is the Environmental Protection Agency (Aplinkos apsaugos agentūra — AAA). All producers must register in the GPAIS — the Unified Product, Packaging and Waste Information System (Vieninga gaminių, pakuočių ir atliekų apskaitos informacinė sistema) — operated at gpais.eu. GPAIS serves as Lithuania's central environmental information system for producer registration, accounting, and annual reporting for batteries, packaging, WEEE, and other regulated product streams. A new battery registration form aligned with the five categories of the EU Battery Regulation has been active in GPAIS since 11 August 2025, replacing the former three-category structure and incorporating an updated chemistry classification. Zalando scheduled Lithuania for its battery EPR verification rollout by 31 March 2026.

Does This Apply to E-Commerce & Online Sales

Yes. The EU Battery Regulation and Lithuanian waste legislation explicitly capture distance sellers and e-commerce operators as producers. A foreign brand selling batteries or battery-containing products directly to Lithuanian consumers via an online store is treated as a producer and must comply with Lithuanian battery EPR obligations. A distinctive feature of Lithuania's EPR system is that foreign producers are not required to appoint a Lithuanian authorised representative and can independently fulfil their registration and reporting obligations through GPAIS. This makes Lithuania more accessible for direct foreign producer registration compared to many other EU member states.

Who is the "Producer" under Lithuania EPR?

Under Regulation (EU) 2023/1542 and Lithuanian waste legislation, a producer is any person who, in the course of commercial activity, makes batteries available on the Lithuanian market for the first time. This covers:

1. Manufacturers established in Lithuania who produce and sell batteries domestically under their own brand.
2. Importers bringing batteries into Lithuania from non-EU countries for the first time under their own name.
3. Companies introducing batteries from another EU Member State into Lithuania for the first time.
4. Private label owners whose brand name appears on batteries manufactured by third parties.
5. Distance sellers and online retailers established outside Lithuania who sell batteries or battery-containing products directly to Lithuanian consumers.
6. Economic operators who prepare batteries for re-use or repurposing — treated as producers for the second life of the battery.

Who Must Register for EPR Batteries in Lithuania

All producers placing batteries on the Lithuanian market must register in the GPAIS producer register (gpais.eu), administered by the Environmental Protection Agency (AAA). Registration has been mandatory since the former Batteries Directive was transposed into Lithuanian law, and the GPAIS battery registration module was updated on 11 August 2025 to align with the new EU Battery Regulation's five-category structure. Producers must also join an approved Producer Responsibility Organisation (PRO) for batteries or demonstrate individual compliance with collection and recycling obligations. The public GPAIS producer register (Viešai skelbiamas gamintojų ir importuotojų sąvadas) is accessible at gpais.eu under the section "Vieši GII sąvado duomenys" — all registered battery producers are publicly listed there.

Lithuania EPR Battery Registration Threshold

Regulation (EU) 2023/1542 does not establish a minimum volume or turnover threshold below which producers are exempt from EPR obligations. All producers placing batteries on the Lithuanian market must register and comply regardless of size or volume. The only exemption in the Regulation concerns batteries used in military or space equipment, which are outside the scope entirely. For due diligence obligations, companies with annual net turnover below €150 million (as adopted under the Omnibus IV package, July 2025) may be exempt — but this does not affect EPR registration and reporting obligations.

Batteries Covered (and Excluded)

From 11 August 2025, Lithuania updated its GPAIS battery registration module to reflect the five categories of Regulation (EU) 2023/1542: Portable batteries (nešiojamosios baterijos) Batteries under 5 kg not designed for industrial or vehicle use. Includes batteries in consumer electronics, power tools, household devices, and toys. Light Means of Transport (LMT) batteries (mažųjų transporto priemonių baterijos) Batteries used in e-bikes, e-scooters, e-mopeds, and similar light electric vehicles. Automotive (SLI) batteries (automobilių baterijos) Starting, lighting, and ignition batteries used in vehicles. Industrial batteries (pramoninės baterijos) Batteries used in industrial applications and stationary energy storage systems. Those above 2 kWh have additional requirements including battery passports from 2027. Electric vehicle (EV) batteries (elektrinių transporto priemonių baterijos) Batteries used in electric cars and heavy electric vehicles. Key exclusions:

• Batteries designed for military or space equipment — outside scope entirely
• Batteries in nuclear installations — excluded
• Second-life batteries where the operator performing re-use or repurposing becomes the new producer

Producer Responsibility Organization (PRO)

Lithuania operates an approved PRO system for batteries. Producers join a licensed PRO that manages collection, recycling, and reporting obligations on their behalf. The PRO reports aggregated compliance data to the Environmental Protection Agency (AAA) through GPAIS. PROs operating in Lithuania for various product streams include Žaliasis taškas (Green Dot Lithuania) and Gamtos ateitis. Producers should confirm with the AAA which PROs are currently approved for battery collection and recycling under the updated EU Battery Regulation framework. Alternatively, producers may establish an individual compliance arrangement — demonstrating their own take-back, collection, and recycling capacity — subject to approval by the AAA.

EPR Registration in Lithuania

The registration process for battery producers in Lithuania is as follows:

1. Determine whether your business qualifies as a producer under the EU Battery Regulation and Lithuanian waste legislation.
2. Register in GPAIS (gpais.eu) using the updated battery registration form active from 11 August 2025, under the section "GII registracija — Baterijos nuo 2025-08-11". Provide company details, battery categories, brand names, and chemistry classification.
3. Join an approved PRO for batteries or establish an individual compliance arrangement approved by the AAA.
4. Submit annual declarations of battery volumes placed on the Lithuanian market through GPAIS by the applicable deadline.
5. Pay applicable contributions to the PRO based on battery category, weight, and chemistry.
6. Retain records for audit by the AAA.

Foreign companies may register and report directly through GPAIS without appointing a Lithuanian authorised representative — Lithuania does not require a local AR for foreign producers.

Authorized Representative

Lithuania's EPR system has a distinctive feature: foreign producers are not required to appoint a Lithuanian authorised representative and can independently fulfil their registration and reporting obligations through the GPAIS online system. This differs from most other EU member states where AR appointment is mandatory for foreign producers. Important development: In December 2025, the European Commission proposed suspending the authorised representative requirement for EU-established companies until 2035. This proposal has not been formally adopted as of May 2026. For Lithuania specifically, this change would have limited practical impact given that foreign producers can already register independently.

What Data Must Be Reported

Producers registered in Lithuania must submit annual declarations through GPAIS covering:

• Total weight (kilograms) of batteries placed on the Lithuanian market during the reporting year, broken down by the five EU Battery Regulation categories and by battery chemistry type
• Brand names under which batteries were placed on the market
• Collection and recycling performance data, compiled and reported by the PRO to the AAA on behalf of members
• For EV and LMT batteries: number of batteries made available and amounts of waste batteries collected and delivered to treatment facilities

Annual declarations are submitted through GPAIS no later than 50 days after the end of the previous calendar year — equivalent to approximately 19 February — for most product streams. However, for annual waste accounting reports, the deadline has been changed from 1 February to 1 April, with the AAA reviewing submissions by 1 August. Producers should confirm the applicable battery declaration deadline directly with the AAA or their PRO.

First Reporting Period & EPR Reporting Deadlines

Battery EPR has been mandatory in Lithuania for many years. The GPAIS battery module was updated on 11 August 2025 to align with the new EU Battery Regulation. Key dates:

• 11 August 2025: Updated GPAIS battery registration form active with new five-category structure and updated chemistry classification.
• 18 August 2025: EU Battery Regulation EPR obligations fully in force.
• 31 March 2026: Zalando's Lithuanian battery EPR verification scheduled to activate.
• Annual (approximately 19 February or 1 April): Annual declaration of batteries placed on the Lithuanian market — confirm exact deadline with AAA.
• 18 February 2027: Battery passports mandatory for industrial batteries (>2 kWh) and EV batteries.
• 18 August 2027: Due diligence obligations in force (delayed under Omnibus IV).

Labels & Marketing Claims

Crossed-out wheeled bin symbol From 18 August 2025, all batteries must display the separate collection symbol covering at least 3% of the area of the largest side of the battery, up to a maximum of 5 × 5 cm. Chemical symbols Batteries containing more than 0.002% cadmium must be marked Cd. Batteries containing more than 0.004% lead must be marked Pb. Capacity marking Portable and rechargeable batteries must display capacity information. QR code From 18 August 2026, all batteries must carry a QR code. For LMT, industrial (>2 kWh), and EV batteries, this links to the Digital Battery Passport from 18 February 2027. CE marking Mandatory from 18 August 2024. Language requirements Consumer-facing information on batteries sold in Lithuania must be provided in Lithuanian where required under Lithuanian consumer protection law. Environmental claims The Empowering Consumers for the Green Transition Directive (2024/825/EU) must be transposed by March 2026, after which unsubstantiated green claims will be prohibited across the EU including Lithuania.

EPR Eco Fees & Eco-Modulation

Lithuanian battery PROs set contribution rates for their members based on the weight, category, and chemistry of batteries placed on the Lithuanian market. Specific fee schedules should be confirmed directly with the chosen PRO at the time of membership registration. Under Regulation (EU) 2023/1542, eco-modulation — adjusting contributions based on battery environmental performance — is required across all Member States. Lithuania's specific eco-modulation framework under the new Regulation has not been separately published as of May 2026.

Risks, Penalties & Common Mistakes

1. Registering under the old three-category structure after August 2025. The GPAIS battery module updated to the new five-category system from 11 August 2025. Registrations under the old structure must be updated to reflect the new categories and chemistry classification.
2. Failing to register in GPAIS. Operating without GPAIS registration is a breach of Lithuanian waste legislation. The AAA conducts compliance inspections and may impose administrative sanctions.
3. Missing annual declaration deadlines. Annual battery declarations must be submitted through GPAIS by the applicable deadline. Late or missing submissions attract penalties under Lithuanian waste law.
4. Not joining a PRO. GPAIS registration alone is insufficient — producers must also join an approved PRO or establish an individual compliance arrangement for battery collection and recycling.
5. Assuming one EU registration covers Lithuania. Battery EPR registration is national. Registration in another EU member state does not fulfil Lithuanian obligations.
6. Missing labelling requirements. The crossed-out wheeled bin symbol and CE marking are mandatory from August 2025.
7. Missing the QR code deadline of August 2026.

What E-Commerce Sellers Should Do Now

1. Confirm whether your products contain batteries and whether they are being sold to Lithuanian consumers.
2. Register in GPAIS (gpais.eu) using the battery registration form active from 11 August 2025 — foreign producers can register directly without an authorised representative.
3. Join an approved PRO for batteries in Lithuania and complete the required membership and contribution arrangements.
4. Submit annual declarations of battery volumes by category and chemistry through GPAIS by the applicable deadline.
5. Monitor the Zalando battery EPR verification rollout for Lithuania (scheduled by 31 March 2026) and ensure your GPAIS registration number is ready to submit.
6. Verify that all batteries carry the crossed-out wheeled bin symbol, CE marking, capacity information, and Lithuanian-language consumer instructions as required.
7. Plan for the QR code requirement by August 2026 and the Digital Battery Passport for industrial and EV batteries by February 2027.

FAQ

Is battery EPR mandatory in Lithuania?

• Yes. Battery EPR has been mandatory in Lithuania for many years. From 18 August 2025, the EU Battery Regulation (2023/1542) fully applies. The GPAIS battery registration module was updated from 11 August 2025 with the new five-category structure. All producers placing batteries on the Lithuanian market must register in GPAIS, join an approved PRO, and submit annual declarations.

Do foreign brands selling online into Lithuania need to register?

• Yes. Distance sellers and e-commerce operators selling batteries to Lithuanian consumers are captured as producers under the EU Battery Regulation and Lithuanian waste legislation. A distinctive feature of Lithuania's system is that foreign producers can register and report directly through GPAIS without appointing a local authorised representative — which simplifies compliance compared to most other EU member states.

Does Lithuania require an authorised representative for foreign battery producers?

• No. Unlike most EU member states, Lithuania does not require foreign producers to appoint a Lithuanian-established authorised representative. Foreign companies can independently fulfil their registration and reporting obligations directly through the GPAIS online system.

What changed in Lithuania's battery registration from August 2025?

• Lithuania updated its GPAIS battery registration module from 11 August 2025 to implement the new five EU Battery Regulation categories (portable, LMT, automotive/SLI, industrial, EV), replacing the previous three-category structure. The chemistry classification was also updated. All new registrations must use the updated form; existing registrations under the old structure should be reviewed and updated.

Is there a minimum volume threshold below which registration is not required?

• No. The EU Battery Regulation does not establish a minimum volume or turnover exemption for EPR registration. All producers placing batteries on the Lithuanian market must register regardless of size.

Packaging EPR law in Lithuania: None enacted

Lithuania is not among the countries with enacted textile EPR legislation.