What the 2015 decree changed
Royal Decree 710/2015 amended Royal Decree 106/2008 on batteries, accumulators and their waste. It entered into force on 26 July 2015 and addressed matters including producer responsibility, collection, information and recycling.
Use the BOE consolidated RD 106/2008 alongside applicable EU law. The 2015 amendment alone is not a complete statement of the framework checked on 12 October 2026.
The EU regulation now supplies the wider framework
Regulation (EU) 2023/1542, consolidated on 13 August 2026, generally applies from 18 February 2024. Its waste management chapter applies from 18 August 2025. It covers the battery life cycle and sets duties according to battery category and operator role.
MITECO’s 2026 Spanish adaptation consultation concerns a draft decree. A consultation document must be distinguished from an enacted rule.
Separate the dates for different obligations
- Waste duties: identify the applicable producer registration, extended responsibility, collection and treatment obligations under Chapter VIII.
- Information labels: Article 13(1)–(3) uses 18 August 2026 or 18 months after the relevant implementing act enters into force, whichever is later. Do not treat August 2026 as an unconditional deadline.
- Battery passports: Article 77 starts on 18 February 2027 for LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries placed on the market or put into service.
- Due diligence: Regulation (EU) 2025/1561 moved Article 48 duties to 18 August 2027, subject to the chapter’s scope and exclusions.
Prepare for the corrected waste-code date
Decision (EU) 2025/934 updates battery-related entries in the European List of Waste. Its official corrigendum sets application at 9 December 2026. That date remains ahead of this review. Assess the relevant entries and permit implications rather than copying an old waste-code list.
Keep the transport assessment separate
Environmental producer responsibility and waste documentation do not establish a battery consignment’s ADR transport classification or compliance. Product marking and a battery passport serve different purposes from transport documents.
For a review, gather the battery identity and category, business roles, market dates, producer registration, waste status, receiving facility and transport documentation. Resolve missing evidence before confirming an operation. DGSA advisory services can review the transport interface; contact DGSA with the actual consignment and route.