BATTERIES & CHARGERS
Regulation. Electric vehicle batteries shall only be accompanied by a document informing about values for those parameters, but they will not be required to meet minimum values. By the end of 2030, the Commission shall consider either the adoption of measures to phase out non-rechargeable portable batteries of general use or the 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 requirement will be enforced from 18 February 2027. This means that operators placing on the market products incorporating portable batteries must ensure that by 2027 these are ‘readily removable’ (i.e., without requiring specialised tools, unless provided free of charge) and replaceable by the end-user at any time during the product’s lifetime. Likewise, operators shall ensure that LMT batteries as well as individual battery cells are readily removable and replaceable by an independent professional at any time. A portable or a LMT battery will be ‘readily replaceable’ if it can be substituted by another compatible battery without affecting the functioning, performance or safety of the appliance or light means of transport.
DUE DILIGENCE
The 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. The due diligence obligation will apply from 18 August 2027.
RECYCLING AND MATERIAL RECOVERY TARGETS
The regulation sets recycling efficiency targets and material recovery targets for specific elements in recycling and treatment facilities for batteries. These recycling efficiency targets will apply from 31 December 2025 for certain battery chemistries, while the material recovery targets will apply from 31 December 2027 for Cobalt, Copper, Lead, Lithium and Nickel. The Regulation aims to promote the recovery of critical raw materials. In doing so, the objective
UKManufacturing Autumn 2025
is to reduce the EU’s dependency on such materials. To attain this, the Regulation introduces the following requirements applicable to some industrial batteries, electric vehicle batteries, starting, lighting and ignition (SLI) and LMT batteries (for this last category, the requirements will be applicable at a later stage):
1. Disclosure of information on recycled content of cobalt, lead, lithium and nickel. Relevant batteries shall be accompanied by documentation informing about:
Percentage share of cobalt, lithium or nickel present in active materials and which has been recovered from battery manufacturing waste or post-consumer waste; and
Percentage share of lead present in the battery and recovered from waste, for each battery model per year and per manufacturing plant.
2. Mandatory recycled content targets for cobalt, lead, lithium and nickel; and
This will be applicable several months after the disclosure requirement. The percentage share of these raw materials shall be measured against a methodology adopted by the Commission through delegated acts.
This requirement is subject to third-party verification.
RESTRICTIONS ON HAZARDOUS SUBSTANCES
The Regulation restricts the use in batteries of certain substances listed in Annex I. This Annex can be amended by the Commission through delegated acts if there is an unacceptable risk to human health or the environment that is not adequately controlled and needs to be addressed on an EU-wide basis. This could overlap with the restriction of chemicals under the REACH Regulation.
INFORMATION AND LABELLING Requirements for information and labelling include a battery passport, specific labelling (chemistry, lifetime, charging capacity, collection, hazardous substances, safety risks), electronic databases, and second life data sets. These requirements aim to enhance information and traceability. By 2026, all batteries shall be labelled with some general information and marked with a separate collection symbol. At a later stage, by 2027, all batteries shall be marked with a QR code to access either: (a) a battery passport, for LMT batteries, some industrial batteries and electric vehicles batteries; or (b) the applicable information for other batteries. Furthermore, (i) rechargeable portable batteries, LMT batteries and SLI batteries shall bear a
label informing about charging capacity; (ii) non-rechargeable portable batteries shall bear a label informing about their minimum average duration when used in specific applications and say they are ‘non-rechargeable’; (iii) batteries containing a minimum heavy metal content of cadmium or lead shall be marked with a symbol; and (iv) SLI batteries shall be marked with a QR code informing about the amount of recovered cobalt, lead, lithium or nickel.
The Regulation introduces another information requirement for stationary battery energy storage systems, LMT batteries and electric vehicle 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 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 on 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.
REPORTING OBLIGATIONS
Reporting obligations are introduced, and there are specific deadlines for implementing various aspects of the regulation, with certain requirements coming into effect in different phases from 2024 to 2028. 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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