Laws, rules & regulation

Battery Management Decree

All the statutory provisions relating to the processing of batteries are laid down in the Battery Management Decree 2008.

Since 2008, the Dutch government has complied with the European Batteries Directive in the form of the Dutch Battery Management Decree 2008 (Bbb). This Decree contains all the statutory provisions relating to the processing of batteries. The regulations apply to all batteries, including starter batteries and propulsion batteries from vehicles.

Batteries are covered by manufacturers’ responsibility. This means that the manufacturer or importer is (jointly) responsible for managing the waste from the products they place on the Dutch market.

The Activities Decree specifies the individual responsibilities of the operators in the chain. The Decree outlines all the environmental rules that apply in the Netherlands. In accordance with the Bbb, batteries from end-of-life vehicles are identified as waste, and must therefore be recycled. For use in second-life applications, the end-of-waste criteria must be complied with. Click here for more information about the end-of-waste rules.

Together with the Batteries Foundation (Stibat), ARN has developed a collective solution to meet the requirements of the Bbb. Click here for more information about Stibat and this cooperation.

National waste management plan LAP3

The National waste management plan LAP3 describes how various types of waste should be dealt with in the Netherlands. For example the minimum standards for waste processing. There is also a sector plan for propulsion batteries and starter batteries. In the sector plan, waste policy as described in LAP3 is translated for the various waste flows.


European legislation

The European Directive 2006/66/EC contains all the regulations governing propulsion batteries and starter batteries. This Directive is implemented in the Netherlands in the Bbb.


Laws, rules and regulations on storage, transport and disassembly

Various applications

Current regulations fail to provide sufficient clarity about the storage of propulsion batteries. To provide greater clarity, a handbook was issued as an interim measure. In 2020, as a follow-up to this handbook, a circular was published by the Ministry.

Since 2019, a working group has been compiling PGS37 which is due to be completed by the start of 2021. PGS37 describes the rules for the storage of batteries. Legislation will also refer to PGS37. Publication of PGS37 will provide clarity to the sector on the storage of batteries. The underlying principle for PGS37 is that wherever possible and desirable, it ties in with the requirements contained in the ADR.

For more details consult the Publication Series Hazardous Substances: PGS



The transport of batteries is subject to strict requirements as laid down in the ADR, the international agreement concerning the international carriage of dangerous goods by road.

This agreement among others provides a precise description of the requirements imposed on packaging for the transport of critical batteries. ARN works only with collection companies for batteries that comply with these ADR requirements. These companies supply packaging suitable for the safe transport of critical ‘non-transport-secure’ batteries.

A battery is described as non-transport-secure if under normal transport conditions, it could rapidly disintegrate, react dangerously or cause flame or dangerous heat development, or lead to the hazardous emission of toxic, corrosive or flammable gases or vapours.


The disassembly of a vehicle with a high-voltage battery demands specific knowledge. To do this safely and in recognition of the potential risks, in collaboration with Innovam, ARN has developed the training programme Safe dismantling of electric cars. ARN offers this training free of charge to 1 person at each of the car dismantling companies affiliated to ARN.

It is important that the dismantling companies make use of the International Dismantling Information System (IDIS). This system contains information essential for dismantling, for each brand and model. This information is vital for the safe dismantling of high-voltage batteries.

To continue to guarantee the safety of dismantling in the future, the Stichting KZD (Foundation for Quality Assurance in Dismantling) will be including a number of questions about the dismantling of propulsion batteries from end-of-life cars in its basic certificate.