Battery-management fee also applicable for imported used EVs and hybrids
A new European Battery Directive is set to make a phased entry, starting 18 August, 2025. The Directive will impact every link in the chain: from design and production up to and including collection and recycling.
Importers of used electric vehicles will also soon be subject to Extended Producer Responsibility (EPR) for the waste management of propulsion batteries.
Note: A new vehicle is regarded as one that has not previously been registered in an EU member state. Conversely, a used vehicle is regarded as one that has already been registered in a member state.
What changes on 18 August, 2025?
Rules collection, processing and reporting
From 18 August, 2025, the end-of-life battery management section of the new Battery Directive will come into force. From then on, all member states will have to comply with the basic rules governing their collection, processing, and reporting.
From 1 October, 2025, regulations in The Netherlands
The applicable implementation regulations in the Netherlands are expected to come into effect on 1 October, 2025. These will also describe how the regulations will be enforced, and by whom. From then on, importers can register with Rijkswaterstaat (Netherlands Ministry of Infrastructure and Water Management) – either directly or through ARN.
From 1 January, 2026, battery-management fee
From 1 January, 2026, participating importers will have to pay a battery-management fee for used electric vehicles via ARN.
Mandatory registration with Rijkswaterstaat
Every professional importer of electric vehicles must register with Rijkswaterstaat Living Environment and demonstrate that it meets all legal requirements. This can be done in two ways.
1. Provided the company has entered into an agreement with ARN, ARN can assume responsibility for the registration.
2. A company can also register directly with Rijkswaterstaat. However, given the associated level of responsibility, this is only a realistic option for the largest importers.
If a company is not registered, it will not be permitted to place electric vehicles on the Dutch market, irrespective of the number of vehicles.
Applicable for used EVs too
Up until now, the battery-management fee applied only to the importers of new vehicles. However, from 2026, this fee will also be payable for used vehicles with a propulsion battery, such as (mild) hybrids, plug-in hybrids, and fully electric vehicles.
The Stichting Autobatterij Recycling (Car-Battery Recycling Foundation) sets the level of this fee every year, based on the expected collective costs spread over a period of at least five years.
Registration process
In consultation with BOVAG, ARN is currently developing a digital registration and payment process for importers.
More information on this will be available in the first half of August. Send a message to [email protected] and we will keep you informed.