The EU Battery Regulation 2023/1542 imposes specific deadlines and requirements that need to be fulfilled by economic operators handling batteries. The Commission will publish guidelines, as well as delegated and implementing acts. Additionally, the Commission will assess specific aspects related to the regulation to ensure effective implementation.
These regulations introduce stringent measures aimed at sustainability, safety, and efficiency in the battery industry. Various stakeholders, including manufacturers, importers, distributors, recyclers, and fulfillment service providers, must comply with these rules. A detailed breakdown of the key timelines and their implications is provided below.
1st January 2025: Harmonised Standards for Common Chargers
The European Commission shall assess how best to introduce harmonised standards for a common charger for (Article 94):
Rechargeable batteries designed for light means of transport.
Rechargeable batteries incorporated into specific categories of electrical and electronic equipment covered by Directive 2012/19/EU.
18th February 2025: Carbon footprint, Due diligence, Recycling & recovery rates
Carbon Footprint (CF) Declaration: EV battery manufacturers must declare the carbon footprint of their batteries. (Article 7, Annex II)
There are concerns over the delay in finalising the CF calculation methodology for EV batteries, as outlined in the draft delegated act. Stakeholders highlight issues, such as unclear methodology, potential biases, and gaps in system boundaries, including the exclusion of battery transport emissions. Additionally, concerns about data security and the lack of incentives for providing company-specific data have been raised.
CF Performance Class Requirements: The Commission shall adopt delegated and implemented acts for CF performance class requirements for EV batteries. (Article 7, Annex II)
CF Declaration for Industrial Batteries: The Commission shall adopt delegated and implemented acts for CF declarations for rechargeable industrial batteries, except those with external storage. (Article 7, Annex II)
Due Diligence Guidelines: The Commission shall publish guidelines for due diligence requirements. (Article 48, Annex X)
Recycling Efficiency & Recovery Rates: A delegated act shall establish the methodology for calculating and verifying recycling efficiency and material recovery rates. (Article 71)
30th June 2025: Collection Rate Data Transmission
Obligations under Directive 2006/66/EC related to monitoring and reporting the collection rate of portable batteries shall remain in force until 31 December 2023. However, the related obligations for the transmission of data to the Commission shall remain in force until 30 June 2025. By this date, stakeholders must comply with obligations related to the transmission of data to the Commission regarding the collection rate of portable batteries.
18th August 2025: Labelling, Due Diligence Compliance, and Battery Waste Management
Battery Due Diligence Obligations: Compliance with due diligence regulations for ethical sourcing and sustainability is required. (Article 48, Annex X)
Battery Labelling: Batteries shall be marked with a separate collection symbol. (Article 13, Annex VI)
Harmonised Specifications for Labelling: Implementing acts shall establish harmonised specifications for labelling requirements. (Article 13)
Waste Battery Management: Implementation of waste battery management rules. (Chapter VIII)
Collection and Treatment of Waste Batteries: Implementing acts shall define assessment methods and operational conditions. (Article 76)
Extended Producer Responsibility (EPR) Compliance: Member States shall ensure that EPR schemes established before 4 July 2018 comply with Article 8a(7) of Directive 2008/98/EC. (Article 92)
Repeal of Directive 2006/66/EC: The older directive shall be officially repealed, except for a few articles remain active until 2027 (Article 95)
Penalties for Non-Compliance: Member States shall lay down rules on penalties for infringements of this regulation. (Article 93)
18th November 2025: Notification of Competent Authorities
Member States will notify names and addresses of competent authorities for waste management of batteries and report to the Commission (Article 54)
31st December 2025: Recycling Efficiency Targets and Reporting
First Phase of Recycling Efficiency Targets: The first phase of recycling efficiency targets shall be implemented. (Article 71, Annex XII)
Recycling must achieve at least the following targets for recycling efficiency:
(a) 75 % by average weight of lead-acid batteries
(b) 65 % by average weight of lithium-based batteries
(c) 80 % by average weight of nickel-cadmium batteries
(d) 50 % by average weight of other waste batteries.
Monitoring & Reporting Obligations: The obligations under Directive 2006/66/EC for monitoring and reporting recycling efficiencies of recycling processes shall remain in force until 31 December 2025.
All economic operators must comply with these regulations and actively contribute to a sustainable future by planning ahead and implementing best practices in sustainability, transparency, and end-of-life. The regulation places significant importance on shifting to a circular economy, by promoting resource efficiency and enforcing stringent ethical and environmental guidelines for battery manufacturing and disposal. To secure their position in a more competitive and sustainable market, businesses must remain aware of these changing requirements and modify their plans to ensure compliance.
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.
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