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Obligation Check — Methodology

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Obligation Check — Methodology

Version 0.2.0 · 27 September 2026

What this tool does

Obligation Check matches your project inputs (country, role, capacity, commissioning date) against a maintained national rule set and returns a structured list of compliance and end-of-life obligations, each with a deadline or trigger, a primary source, and a retrieval date.

What it does not do

  • It does not read market data or rank any vendor.
  • It does not give legal advice.
  • It does not estimate facts it cannot verify — those are marked Not yet certain.
  • Source policy

    Every entry cites a primary source only:

    CategoryPrimary source used

    Vendor pages are not used as sources. Where a fact is genuinely still open (for example, the exact form of the Belgian financial guarantee above 16 MWh, or when the Dutch industrial-battery collective system becomes operational), it is recorded under Not yet certain rather than asserted.

    Uncertainty handling

    Three of the four “Not yet certain” items are structural, not data gaps:

    1. The amount and form of the Belgian financial guarantee above 16 MWh is not specified in the cited source.

    2. Belgium’s supplementary regional rules are still being finalised (expected autumn 2026).

    3. The Dutch UPV Industrial Batteries Foundation has no operational date yet, and what an individual plan must contain is not specified.

    4. The specific terms for German industrial storage batteries under the OfH scheme are not detailed in the cited sources.

    Pending legislation we disclose

    A Commission proposal COM(2025) 982 would suspend the authorised-representative obligation (Article 56(3) of Regulation (EU) 2023/1542) until 1 January 2035. It is pending and not adopted as of 27 September 2026. The suspension targets EU-established producers selling cross-border; the obligation for third-country producers remains in force.

    Coverage

  • Covered today: Belgium, the Netherlands, Germany.
  • Planned: France, Poland, Romania (then the remaining European markets).
  • Versioning

    The rule set is versioned. When a rule changes, the version number increments and the retrieval dates on affected entries are refreshed. The version shown on the tool page must match the version here.

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    *This methodology is part of BessCare’s “methodology is public” commitment. It does not constitute legal advice.*

    ——
    EU battery passport & registryEUR-Lex — Regulation (EU) 2023/1542, Implementing Regulation (EU) 2026/1778
    BelgiumBebat (official national scheme)
    Netherlandsbusiness.gov.nl / Rijkswaterstaat (official government portal)
    GermanyUmweltbundesamt (official federal agency)
    ADR transportUNECE — ADR 2025 official text