FEATURE MACHINE BUILDING, FRAMEWORKS & SAFETY
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EU BATTERY REGULATION 2023/1542: WHAT ARE THE IMPLICATIONS FOR MACHINE BUILDERS?
The EU BR does, however, have various
exclusions – such as batteries for use in defence or space applications.
BUYING BATTERIES There are a number of things to look out for when purchasing batteries to incorporate in machinery. For compliance with the new EU BR, batteries need to be CE marked and, space permitting, include certain information on the label (such as manufacturer, battery category, place and date of manufacture, capacity, chemistry, hazardous content, etc.). Batteries must also be accompanied by a
Declaration of Conformity (DoC) referring to Regulation 2023/1542. However, the labelling requirements do not come into force until 18 August 2025, with additional requirements from 18 August 2026. From 18 February 2027, industrial batteries
entered into force on 17 August 2023 and has been applied since 18 February 2024. The EU BR applies when batteries are
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placed on the market or put into service in the EU and other states that have adopted EU product regulations. However, it is possible that similar legislation could be enacted in the UK in the future. Although the EU BR repeals Battery
Directive 2006/66/EC, it does not do so until 18 August 2025. Furthermore, some parts of the old Directive remain in force until specific dates in 2025, 2026 and 2027. Directive 2006/66/EC has been credited with
improving the environmental performance of batteries. Building on this, the new EU BR aims to improve the green credentials of batteries throughout their entire lifecycle, which includes recycling. As well as preventing environmental pollution, recycling recovers scarce materials that would otherwise have to be imported from outside the EU.
BATTERY CATEGORIES The scope of the EU BR includes all categories of battery placed on the market or put into service within the EU, with various requirements and deadlines for each category. It is, however, largely ‘technology agnostic’, in that it does not set out different rules for each battery chemistry.
24 DESIGN SOLUTIONS APRIL 2025
The EU Battery Regulation 2023/1542 came into force on 17 August 2023. But what is this? Does it affect you? And what are the implications? As well as covering the supply of batteries on
achine builders and system integrators need to be aware of the new EU Battery Regulation 2023/1542 which
their own, the EU BR also covers batteries that are incorporated within other products, including machinery. For machine builders and system integrators (SIs), the main areas of interest in the EU BR will be those relating to ‘industrial batteries’ and ‘portable batteries’ including ‘general use’ types such as button cells, D, C, AA, AAA and PP3 batteries. For completeness, the other battery categories in the EU BR are EV (electric vehicle) batteries, vehicle SLI (starting, light and ignition) batteries, and LMT (light means of transport) batteries. Note that a ‘portable battery’ is defined as being sealed, weighing less than 5kg, not designed specifically for industrial use, and not an EV, SLI or LMT battery. If another type of battery has been repurposed for industrial usage, it becomes an ‘industrial battery’.
BATTERIES INCORPORATED IN MACHINERY In this article we are assuming that machine builders and SIs are incorporating industrial and/or portable batteries within their products. We are not considering the design, manufacture or processing of new or used batteries, just the incorporation of bought-in batteries within machinery. Although machine builders and SIs will most likely procure such batteries from manufacturers or distributors, because they incorporate them into their own products, the EU BR considers them to be ‘producers’.
with a capacity greater than 2kWh are required to display a QR code that provides access to the battery passport, which will be created by the original manufacturer (not the machine builder or SI incorporating the battery within their product). Responsibility for the battery’s passport lies with the economic operator placing the battery on the market, though it should be updated after it has been remanufactured or repurposed. Although a machine builder or SI might want to view the battery passport, it is unlikely that they will need to update or modify it. The passport includes the information displayed on the battery’s label, plus more detailed information relating to its manufacture and recycling. Not all parts of the passport are publicly accessible. Until the marking requirements come into
force, buyers of batteries should check for a Declaration of Conformity showing compliance with EU BR 2023/1542. Since 18 August 2024, rechargeable industrial batteries with a capacity greater than 2kWh must also be accompanied by a document containing values for the electrochemical performance and durability parameters.
PORTABLE BATTERIES Requirements relating to portable batteries for general use are, for the time being, less stringent. The Regulation’s main emphasis for these batteries is on removability, replaceability and recycling rates. From August 2026, rechargeable batteries shall be labelled with their capacity, while non-rechargeable batteries shall bear a label containing information on their minimum average duration when used in specific applications and be marked ‘non-rechargeable’. Minimum performance and durability requirements come into force in 2028. Much of Regulation 2023/1542 lays down rules for battery manufacturers and those who process
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