Batteries
Ensuring safety and sustainability with the new EU Batteries Regulation
By Grant Gibbs, senior manager for energy storage at TÜV SÜD, a global product testing and certification organisation.
F
rom 18 August 2025, the new EU Batteries Regulation (2023/1542) replaces the previous Batteries Directive. In contrast to a directive, a regulation is a legal act which applies automatically and uniformly in all EU countries, without the need for transposition into national law. UK-based operators who place or put into service batteries and battery- powered products must also comply. The regulation covers the entire life cycle of a battery, including raw materials procurement, battery production, and battery reuse and recycling. It also introduces new categories of batteries according to their use and design. New provisions for calculating the carbon footprint of batteries and setting recycled content targets for various elements have also been introduced (cobalt, lead, lithium, nickel).
Carbon footprint
The Batteries Regulation proposal currently includes 96 articles and 15 annexes (as of January 2025), establishing rules on sustainability parameters, performance, safety, collection, recycling, and the second life of batteries, as well as outlining information requirements related to batteries. As the regulation enforces stricter sustainability requirements compared to the previous directive on batteries, it directly influences efforts to lower the carbon footprint of the battery (CFB), encouraging the use of low-carbon materials and technologies, and supporting the transition towards a circular economy.
Performance and durability Portable batteries of general use (excluding button cells), rechargeable industrial batteries, and light means of transport (LMT) batteries must comply with electrochemical performance and durability parameters set out in the Batteries Regulation’s annexes. Electric vehicle (EV) batteries must be accompanied by a document informing about values for those parameters, but they will not be required to
16 April 2025
some general information and marked with a separate collection symbol. At a later stage, by 2027, all batteries must be marked with a QR code to access either: A battery passport, for LMT batteries, some industrial batteries and EV batteries; or
The applicable information for other batteries.
meet minimum values. By the end of 2030, the European Commission will consider either the adoption of measures to phase out non- rechargeable portable batteries of general use, or setting of eco-design requirements.
Removability and replaceability The regulation mandates that portable batteries should be easily removable and replaceable by end-users, while LMT, EV, and industrial batteries should be easily removable and replaceable by independent professionals. This will be enforced from 18 February 2027.
Due diligence
The Batteries Regulation introduces an obligation for large economic operators placing batteries on the market or putting them into service to have a battery due diligence policy on responsible raw material sourcing, processing and trading, and to have it verified by a notified body and periodically audited. Producers and producer responsibility organisations (PROs) must therefore adopt and communicate a due diligence policy for batteries. They are also required to establish management systems to support due diligence policies, identify and assess risks in the supply chain, and design strategies to address identified risks. Third-party verification by a notified body is necessary.
Components in Electronics
The due diligence obligation comes into effect from 18 August 2025.
Recycling and recovery
Recycling efficiency targets and material recovery targets for specific elements in recycling and treatment facilities for batteries will apply from 31 December 2027. By promoting the recovery of critical raw materials, the regulation aims to reduce the EU’s dependency on such materials. This requirement is subject to third-party verification.
Restrictions on hazardous substances
The use of certain substances listed in Annex I to the Batteries Regulation are restricted. Annex I can be amended by the Commission through delegated acts if there is an unacceptable risk to human health or the environment, which could overlap with the restriction of chemicals under the REACH Regulation.
Information and labelling To enhance information and traceability, requirements for information and labelling include a battery passport, specific labelling, electronic databases, and second life data sets. By 2026, all batteries must be labelled with
The Batteries Regulation introduces another information requirement for stationary battery energy storage systems, LMT batteries, and EV batteries using a battery management system. The end-user or any third party on their behalf shall be able to check the data stored in that system to determine the state of health and expected lifetime of their batteries, for purposes of evaluating the capability for further use, etc.
Batteries waste management The Batteries Regulation foresees end-of-life provisions on the basis that collection should be separate and maximised, and recycling should be efficient. Notably, it lays down provisions for a register of producers to be created at national level; extended producer responsibility; collection targets (the target for waste portable batteries is increased and a specific target is set for waste LMT batteries); take-back obligations; targets for recycling efficiency and for recovery of materials; shipment of waste batteries; reporting to the authorities, etc. The regulation also addresses the shipment of waste batteries outside the EU.
Stakeholder responsibility The applicability of these provisions varies depending on the battery type, and the regulation seeks to promote transparency, sustainability, and responsibility throughout the battery supply chain. Manufacturers, importers, and other stakeholders will need to comply with these new requirements and deadlines, with some aspects requiring third- party verification and delegated acts to specify methodologies and calculations.
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