What is the EU Battery Regulation?
On 28 July 2023, the European Commission published the European Battery Regulation (2023/1542), which entered into force on 18 February 2024. This represents a strategic alignment with environmental goals and key initiatives, such as the European Green Deal and the Circular Economy Action Plan. The EU Battery Regulation will supersede the Battery Directive 2006/66/EC by 18 August 2025, signifying a crucial advancement in regulatory enforcement. Unlike directives, which necessitate incorporation into national laws, regulations are directly enforceable across all member states.
Which Battery Types are Covered in the Battery Regulation?
EU Battery Regulation Overview
The EU battery regulation introduces updated requirements to enhance the sustainability and safety of batteries and battery-powered products across their lifecycle. Here are some of its major highlights:
Restriction on Substances and Recycled Content
In addition to restrictions set out in previous directives, the new EU battery regulations mandate restrictions on substances in portable batteries, LMT, and other vehicle batteries, the regulation requires them to contain no more than 0.0005% mercury, 0.002% cadmium, and 0.01% lead.
The Regulation mandates minimum recycled content requirements for industrial batteries with a capacity greater than 2 kWh, excluding those with exclusively external storage, EV batteries, and SLI batteries. The minimum percentage shares of the recycled content are as follows:
From 18 August 2031: 16% cobalt, 85% lead, 6% lithium, and 6% nickel
From 18 August 2036: 26% cobalt, 85% lead, 12% lithium, and 15% nickel.
Carbon Footprint
For electric vehicle batteries, LMT batteries, and rechargeable industrial batteries exceeding 2 kWh capacity, carbon footprint compliance involves the following steps (implementation dates vary by battery type), starting from 18 February 2025:
Carbon footprint declaration for each battery model per manufacturing plant
Classification into carbon footprint performance classes
Adherence to maximum threshold values for life cycle carbon footprint
By 31 December 2030, the Commission will assess extending these requirements to portable and rechargeable industrial batteries with a capacity of 2 kWh or less.
The Guideline documents published by the EU Commission Joint Research Centre (JRC) include:
Performance, Durability, and Safety Requirements
From 18 August 2028, general-use portable batteries (excluding button cells) must meet electrochemical performance and durability standards. The Commission will assess phasing out non-rechargeable portable batteries by 31 December 2030 to reduce environmental impact.
Starting on 18 August 2024, rechargeable industrial batteries exceeding 2 kWh capacity, LMT batteries, and electric vehicle batteries must include documentation with electrochemical performance and durability values. By the same date, Stationary Battery Energy Storage Systems (SBESS) placed on the market must provide evidence of successful safety parameter testing as outlined in the regulation.
The Guideline documents published by the EU Commission Joint Research Centre (JRC):
Removability and Replaceability of Portable and LMT Batteries
Portable batteries must be easily removable and replaceable by end-users throughout the product's lifetime. Instructions and safety information on battery use, removal, and replacement must accompany the product and be permanently available online in a user-friendly format. For LMT batteries, batteries and individual cells within the battery pack must be readily removable and replaceable by a professional at any time during the product's lifetime.
The Guideline document published by the EU Commission Joint Research Centre (JRC):
Digital Battery Passport
The Battery Passport will become mandatory for LMT batteries, industrial batteries exceeding 2 kWh, and EV batteries placed on the market from 18 February 2027. The passport must include details about the battery model and specific information for each battery, accessible via a QR code. Maintained by economic operators, the passport will follow essential technical standards and contain information categorized for different audiences, i.e., the public, authorities (notified bodies, market surveillance authorities, and the Commission), and those with a legitimate interest.
Labelling, CE Marking & Conformity Assessment
The Regulation lays down labelling and information requirements for batteries. These requirements include general information, duration, capacity, a separate collection symbol, indication of hazardous substances and a QR code.
The CE marking (“Conformité Européenne" meaning "European conformity”) signifies that the battery meets Union harmonization legislation requirements. Starting from 18 August 2024, manufacturers are responsible for conformity assessment, which involves obtaining an EU declaration of conformity and affixing the CE marking. The CE marking should be visibly, legibly, and indelibly affixed before the battery is placed on the market or put into service. It may be followed by the notified body's identification number, if required, and may also include any pictogram indicating specific risks or dangers associated with the battery.
The Commission's Blue Guide on the implementation of EU Product Rules 2022 contains the general guidelines for applying CE marking to a product.
Due Diligence
From 18 August 2025, producers and producer responsibility organizations must have due diligence policies for batteries, supported by management systems to identify and address supply chain risks. Economic operators with over EUR 40 million turnover must comply with due diligence obligations for new batteries, ensuring social and environmental risk management and transparency. Notified bodies will verify compliance and the policies must align with international standards for raw material sourcing.
Some Internationally recognized due diligence instruments applicable to the due diligence requirements:
Waste Batteries Collection Targets
Producers or producer responsibility organizations must ensure the collection of all waste portable and LMT batteries. The collection targets for waste batteries are:
Portable Batteries: 45% by 31 December 2023, 63% by 31 December 2027, and 73% by 31 December 2030.
LMT Batteries: 51% by 31 December 2028, and 61% by 31 December 2031.
Targets for recycling efficiency and recovery of materials
These targets promote circularity and resource efficiency by increasing the recycling and recovery of raw materials from batteries.
Recycling Efficiency Targets by Battery Weight Percentage:
By 31 December 2025: 75% lead-acid, 65% lithium-based, 80% Ni-Cd, and 50% other waste batteries.
By 31 December 2030: 80% lead-acid, 70% lithium-based.
Material Recovery Targets:
By 31 December 2027: 90% Cobalt, 90% Copper, 90% Lead, 50% Lithium, 90%Nickel
By 31 December 2031: 95% Cobalt, 95% Copper, 95% Lead, 80% Lithium, 95%Nickel
Stay tuned for our upcoming blogs where we'll delve into the detailed requirements discussed above and other key aspects of the EU battery regulation.
How to stay in compliant with the EU Battery Regulation?
How can we help you?
At Battery Associates (B.A), we offer comprehensive compliance solutions for European battery regulations, guiding you through the industry's evolving landscape. Our expert team ensures your adherence to the latest standards, positioning you as a leader in the field. With a global community spanning the battery value chain, we're here to support your needs. Contact us to discuss tailored solutions for your compliance requirements.
About the Author
Junior Analyst - Battery Associates
Gokul is currently a Junior Analyst at Battery Associates. He holds a master's degree in energy engineering from Politecnico di Milano and a bachelor's degree in mechanical engineering. His expertise lies in power generation, renewable energy, and energy storage. Gokul is passionate about battery technology and its ability to fulfill the changing needs of the energy sector. He is particularly interested in battery energy storage systems (BESS) , Electric vehicles (EV) , and promoting a circular economy throughout the battery value chain.
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