The EU Battery Regulation represents a significant step in the European Union’s ongoing efforts to foster a sustainable, circular economy. As batteries play a crucial role in energy storage, electric vehicles, and various industries, the need to address their environmental and social impact has become increasingly pressing. The new regulation, which replaces the 2006 Battery Directive, is designed to manage the entire lifecycle of batteries—from design and manufacturing to recycling and disposal.
This regulation matters now more than ever as Europe accelerates its green transition, striving to reduce its carbon footprint and resource dependence. It impacts not only battery manufacturers but also sectors like automotive, electronics, and renewable energy. The regulation’s core focus is sustainability, with stricter rules on carbon footprint, material sourcing, recycling targets, and overall transparency throughout the supply chain.
In this article, we will explore key aspects of the new EU battery directive, including its categories, sustainability goals, due diligence requirements, and the critical changes businesses must adapt to as they navigate this evolving landscape. Understanding these new rules is essential for staying compliant and contributing to a greener future.
The battery regulation introduces several impactful changes that will reshape the industry, including:
New Battery Categories
The regulation expands battery categories to include electric vehicle (EV) batteries and light means of transport (LMT) batteries (e.g., e-bikes, e-scooters). These new categories are vital due to the global shift toward electric mobility, which is central to reducing carbon emissions in the transportation sector.
Electric Vehicle (EV) Batteries: With EV production skyrocketing, this category will play a key role in the decarbonisation of the transport sector.
Light Means of Transport (LMT) Batteries: As the popularity of micromobility solutions grows, LMT batteries are becoming more significant in urban transport.
By covering these growing sectors, the regulation ensures that EV and LMT batteries meet the same sustainability, safety, and transparency standards as traditional battery types.
Sustainability Requirements
The regulation imposes strict sustainability requirements on battery manufacturing and recycling to reduce the environmental impact of battery production. The key changes include:
- Carbon footprint reporting: Starting in 2025, manufacturers of EV, LMT, and industrial batteries must report the carbon footprint of their products. By 2027, these batteries must comply with maximum carbon footprint thresholds, which will tighten over time to push manufacturers toward more sustainable production processes.
- Recycled content targets: To encourage a circular economy, the regulation mandates specific minimum percentages of recycled materials in batteries:
These targets aim to reduce the need for mining raw materials and promote the use of recycled materials, minimising the environmental impact of battery production and disposal.
- Restrictions on hazardous substances: The battery regulation includes strict limits on harmful substances such as mercury, cadmium, and lead, to minimise environmental and health risks. This is in line with broader EU policies to reduce toxic chemicals in consumer products.
Due Diligence Requirements
A new aspect of the EU regulation is the introduction of due diligence requirements, which aim to ensure that companies address the environmental and social risks in their supply chains.
Responsible sourcing: Manufacturers of EV, LMT, and industrial batteries must implement policies to responsibly source key raw materials like cobalt, lithium, and nickel. These materials are often associated with unethical practices, including child labour and significant environmental degradation.
Supply chain audits: Companies must conduct supply chain audits and assess risks related to human rights violations and environmental harm. This helps to ensure transparency and ethical practices in the battery supply chain.This due diligence requirement aligns with a broader global movement towards responsible sourcing, reflected in frameworks like the OECD Due Diligence Guidance, ensuring that batteries are not only environmentally sustainable but also ethically sourced.
Information and Traceability Requirements
The EU Battery Regulation introduces robust measures to enhance transparency and traceability across the battery value chain. By implementing systems that make detailed battery information readily accessible, the regulation seeks to empower consumers, facilitate regulatory compliance, and ensure responsible production and recycling practices. Below are the key elements driving these changes:
Digital Battery Passport
A central innovation of the new regulation is the introduction of the digital battery passport. This digital tool will track important data throughout a battery’s lifecycle, ensuring greater transparency and enabling more effective management of batteries at every stage—from production to disposal.
What is a battery passport? The battery passport is a digital record that contains comprehensive information about each battery, including its chemical composition, capacity, performance history, and recyclability. It helps trace the battery from production through usage and, ultimately, to end-of-life disposal or recycling.
How it works: Each battery will have a QR code, which can be scanned to access detailed information stored in the digital passport. This allows consumers, recyclers, and regulators to easily assess the battery’s quality, origin, and sustainability credentials, ensuring that it meets regulatory standards and can be disposed of or recycled appropriately.
The battery passport also promotes data-driven decision-making by making it easier to identify efficient recycling pathways and ensure that valuable materials are recovered, boosting the circular economy.
Labelling and QR Codes
The regulation introduces new labelling requirements designed to provide consumers and regulators with critical information about batteries.
For example, all batteries must now be labelled with key information, such as:
- Chemical composition (e.g., lithium-ion, nickel-cadmium)
- Capacity and energy efficiency
- Durability and expected lifespan
- Recyclability potential and material content
This labelling will be coupled with QR codes, offering an easily accessible digital link to the battery passport. By scanning the QR code, users can access in-depth details about the battery’s origin, safety standards, and disposal instructions. This improves transparency, making it easier for consumers to make informed purchasing decisions and for regulators to ensure compliance with environmental and safety standards.
Removability and Replaceability
The EU Battery Regulation also emphasises the importance of making batteries more removable and replaceable, particularly for portable devices and light means of transport (LMT) like e-scooters and e-bikes.
- Why it matters:
Many batteries are currently designed to be non-removable, leading to more e-waste when devices are discarded as a whole rather than having the battery replaced. Under the new regulation, manufacturers must design batteries that can be easily removed and replaced by consumers or qualified technicians. - Impact on e-waste:
This focus on removability and replaceability extends battery life and reduces electronic waste, as users can replace ageing or damaged batteries instead of discarding entire devices. It also encourages better maintenance practices, ultimately contributing to a more sustainable battery market.
End-of-Life Management
The battery directive sets ambitious targets for end-of-life management, focusing on improved collection, recycling, and sustainable disposal of batteries. These measures are designed to minimise environmental impact, reduce electronic waste (e-waste), and promote the recovery of valuable raw materials, all in line with the EU’s circular economy goals.
Collection Rates
The regulation sets stringent collection targets for portable batteries, aiming to significantly improve how batteries are recovered for recycling.
- Targets:
- 45% collection by the end of 2023
- 63% by 2027
- 73% by 2030
These targets will increase the pressure of facilitating efficient battery collection systems. Consumers will also be encouraged to return used batteries rather than dispose of them in general waste. Collection points, public awareness campaigns, and incentives for proper disposal will play a crucial role in achieving these goals.
Recycling Efficiency
The regulation emphasises recycling efficiency and the recovery of valuable materials, setting clear benchmarks for how much material must be recovered from used batteries.
These goals are critical to reducing reliance on virgin raw materials, particularly those sourced from regions with questionable environmental and labour practices. Efficient recycling will help meet the demand for materials essential to industries like electric vehicles (EVs) and renewable energy storage, while also cutting down the environmental footprint of mining and processing.
Producer Responsibility
The regulation introduces extended producer responsibility (EPR), requiring battery manufacturers to take responsibility for the entire lifecycle of their products, including end-of-life management.
Waste collection responsibility: Under EPR, manufacturers must finance and manage battery waste collection systems free of charge to consumers. Landfill prohibition: The regulation reinforces the prohibition on landfilling batteries, effectively banning battery disposal in regular waste streams.
Timeline for Implementation
The battery regulation introduces a phased implementation schedule to help manufacturers and stakeholders adapt to new sustainability and transparency requirements.
2023-2024 Milestones
- February 2024:
The regulation officially comes into force, with initial obligations focusing on safety, performance, and labelling. All batteries on the EU market must meet stricter safety and durability standards. Economic operators, including manufacturers, importers, and distributors, will need to comply with these foundational requirements to ensure regulatory adherence.
2025-2026 Milestones
- February 2025:
Carbon footprint reporting becomes mandatory for EV batteries. Manufacturers must disclose the carbon footprint of their products, covering the entire lifecycle, from production to disposal. This transparency is a step toward future carbon limits. - August 2025:
Companies are required to implement supply chain due diligence, ensuring the responsible sourcing of materials like cobalt, lithium, and nickel. They must also establish systems for waste battery management, including collection and recycling, to support a circular economy.
2027-2028 Milestones
- February 2027:
The Digital Battery Passport becomes mandatory for EV, LMT (Light Means of Transport), and industrial batteries. This digital passport, accessible via a QR code, will provide detailed information about the battery’s composition, capacity, and recyclability, enhancing transparency and traceability. - 2028:
Recycled content requirements come into effect, requiring manufacturers to include minimum percentages of recycled materials in batteries, such as cobalt, lithium, lead, and nickel. These targets will increase by 2030 to further promote the use of secondary raw materials.
Source: EU Battery Regulation Timeline
Impact on Battery Manufacturers and Suppliers
The EU battery directive brings sweeping changes that will require battery manufacturers and suppliers to significantly adapt their practices to meet the new environmental, transparency, and ethical standards.
Design and Production Changes
One of the most immediate challenges for manufacturers will be adjusting design and production processes to meet the regulation’s carbon footprint and recycled content targets.
- Adoption of new technologies: To comply with carbon footprint limits (which come into effect in 2027), manufacturers will need to adopt cleaner production technologies. This could involve transitioning to renewable energy in manufacturing, improving energy efficiency, and optimising battery design to reduce the environmental impact during the production phase.
- Recycled content targets: By 2028, manufacturers must ensure that batteries contain a minimum percentage of recycled materials (such as cobalt, lithium, nickel, and lead), with targets set to rise by 2030. Achieving this will require significant investment in recycling infrastructure and partnerships with suppliers who can provide materials sourced from recycled batteries. Manufacturers will also need to refine their processes to integrate these secondary raw materials without compromising battery performance.
- Shift to eco-friendly materials: The regulation encourages the use of environmentally friendly and less hazardous materials in battery production. This includes reducing or eliminating toxic substances like mercury and cadmium. Manufacturers must innovate to find sustainable alternatives that meet safety and performance standards while reducing the overall environmental impact of battery production.
Compliance and Certification
Manufacturers will also face new compliance and certification challenges under the battery directive, including the need for CE marking and other certifications to demonstrate adherence to the regulation’s requirements.
- CE marking: Batteries must now carry the CE marking, indicating that they comply with EU safety, health, and environmental standards. To secure this certification, manufacturers will need to implement rigorous testing and certification processes, ensuring that their products meet the regulation’s carbon footprint, recycled content, and performance criteria.
- Third-party audits: In addition to self-certification, manufacturers may need to engage with third-party auditors to verify compliance with the regulation’s evolving standards. This will be especially important as new rules concerning carbon limits and recycled content take effect over the coming years.
Supply Chain Due Diligence
The regulation’s requirement for supply chain due diligence will be one of the most significant operational shifts for manufacturers and suppliers. This is especially relevant for critical raw materials like cobalt, lithium, and nickel, which are often associated with human rights abuses and environmental risks in mining regions.
- Ethical sourcing and traceability systems: Manufacturers must implement robust traceability systems to track the origin of raw materials and ensure that they are ethically sourced. This means engaging in detailed audits of suppliers and developing systems to monitor risks related to human rights, environmental degradation, and corruption. These traceability systems will need to be supported by digital tools, such as blockchain or the upcoming Digital Battery Passport, to ensure transparency.
- Collaboration with suppliers: To meet these traceability requirements, manufacturers will need to collaborate closely with their suppliers. This includes setting clear expectations for material sourcing and auditing supplier practices. Many suppliers may also need to upgrade their own practices to ensure they can provide materials that meet the EU’s new standards for ethical sourcing and sustainability.
Conclusion
The EU Battery Regulation marks a transformative shift toward sustainability and transparency in the battery industry, impacting every stage of the battery lifecycle. From new design and production standards to stringent recycling targets and ethical sourcing requirements, manufacturers and suppliers face significant changes. Compliance with these new rules is not just about meeting legal obligations—it’s about embracing the future of responsible production, reducing environmental impact, and ensuring ethical supply chains.
Adapting to these demands requires more than just technological adjustments; it calls for robust traceability systems and transparent supplier collaboration. This is where Prewave’s solution becomes invaluable. By offering powerful tools for supply chain due diligence and risk management, Prewave helps businesses ensure compliance with the regulation’s ethical sourcing and sustainability requirements. With Prewave, companies can navigate the complexities of the new regulatory landscape, mitigate risks, and position themselves as leaders in a rapidly evolving market.
In an industry undergoing profound change, staying ahead of the curve with reliable partners like Prewave will be key to long-term success.
