The first set of regulation requirements under the EU Battery Regulation 2023/1542 will come into effect on 18 August 2024. These include performance and durability requirements for industrial batteries, electric vehicle (EV) batteries, and light means of transport (LMT) batteries; safety standards for stationary battery energy storage systems (SBESS); and information requirements on SOH and expected lifetime. These regulations, which cover Articles 6 to 14, are designed to set strict guidelines for reliability and safety. Conformity assessments must be performed to verify compliance with these regulations, and the CE marking should be applied appropriately.
Restriction on substances (Article 6)
To increase sustainability and environmental safety, Article 6 places stringent regulations on materials used in batteries. Directive 2000/53/EC and Regulation (EC) No 1907/2006, which already place certain restrictions on hazardous materials in batteries and automobiles, are supplemented by these regulations. The additional restrictions include:Â
Mercury:Â Batteries must contain no more than 0.0005% mercury (as mercury metal) by weight, whether or not they are integrated into appliances, LMT, or other vehicles.
Cadmium: Portable batteries, regardless of integration, must not exceed 0.002% cadmium (as cadmium metal) by weight.
Lead:Â Starting from 18 August 2024, portable batteries must not exceed 0.01% lead (as lead metal) by weight. Zinc-air button cells are exempt from this restriction until 18 August 2028.
Performance and Durability Requirements (Article 10)
Article 10 of the regulation mandates that from 18 August 2024, rechargeable industrial batteries with a capacity exceeding 2 kWh, LMT batteries, and EV batteries must be accompanied by detailed technical documentation. The exact values for the durability and electrochemical performance parameters listed in Annex IV must be included in this documentation. Technical specifications, standards, and conditions needed to measure, compute, or estimate these parameters must be disclosed by manufacturers and economic operators. This obligation will not apply to batteries that are subjected to reuse, repurposing, or remanufacturing.
Safety of Stationary Battery Energy Storage Systems (Article 12)
Technical documentation demonstrating successful testing for the safety parameters listed in Annex V of the regulation must be submitted by 18 August 2024. It must also include an evaluation of any potential safety risks that are not addressed by the legislation, proof of successful mitigation strategies, and relevant testing. Mitigation instructions are required in case hazards, such as fires or explosions, occur. These measures ensure that SBESSs meet high safety standards before being placed on the market or in service.
Information on State of Health and Expected Lifetime of Batteries (Article 14)
Article 14 mandates that starting from 18 August 2024, battery management systems (BMS) for SBESS, LMT batteries, and electric vehicle batteries must contain up-to-date data on parameters determining the state of health and expected lifetime, as defined in Annex VII. Users legally purchasing these batteries are granted read-only access to this data through the BMS. This access facilitates various functions, including making batteries available for energy storage, assessing residual value, and preparing for reuse or repurposing. The BMS must also feature a software reset function to accommodate operational changes.
Conformity Assessment Procedures (Article 17 & Annex VIII)
A conformity assessment should be carried out to demonstrate that the product complies with all legislative requirements. Articles 17 and Annex VIII outline conformity assessment procedures for batteries covered under this regulation. Manufacturers must ensure compliance using one of the following procedures :
For batteries manufactured in series:
Module A - Internal production control (or)
Module D1 - Quality assurance of the production process
For batteries not manufactured in series:
Module A - Internal production control (or)
Module G - Conformity based on unit verification
Module A is a self-assessment module that allows manufacturers to confirm and declare their compliance with regulation requirements. Modules D1 and G involve notified bodies. Since the commission has not yet announced these notified bodies, enforcement will commence 12 months after the publication of the updated list of notified bodies. These procedures ensure that batteries meet EU standards before being marketed or put into service.
CE Marking (Articles 19 & 20)
Articles 19 and 20 specify requirements for the CE marking, which must be affixed visibly and indelibly on batteries or their packaging before they are placed on the market or put into service. The CE marking indicates compliance with EU regulations and must include the identification number of the notified body, where applicable. Additional pictograms or markings may indicate specific risks associated with the battery's use, storage, or transport. Member States are responsible for ensuring correct application of the CE marking and taking action against misuse.
EU Declaration of Conformity (Article 18)
Article 18 mandates that batteries be accompanied by an EU declaration of conformity confirming compliance with the regulations' requirements. The conformity assessment is followed by the EU declaration of conformity. This declaration must be translated into the language(s) required by the Member State where the battery is marketed or placed into service. To lessen the administrative burden on economic operators, a single EU declaration of conformity may consist of one or more separate EU declarations of conformity that have already been prepared in accordance with a different Union act or acts.
Obligations for Economic Operators (Chapter VI)
Economic operators, including manufacturers, importers, distributors, authorised representatives, and fulfilment service providers, must adhere to strict obligations under the EU battery regulation. Each economic operator is required to compile or verify specific requirements, including technical documentation, the EU declaration of conformity, CE marking, and ensuring compliance with labelling and identification standards. Economic operators must make technical documentation and declaration of conformity available to national authorities for 10 years after the battery is placed on the market.
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 offers tailored solutions and insights to navigate these requirements seamlessly. Reach out to us for detailed support and information on meeting compliance standards.
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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