EU Regulation
Battery Regulation (EU) 2023/1542
Background
Background
The Battery Regulation, formally Regulation (EU) 2023/1542, replaces the previous Battery Directive (2006/66/EC) and introduces a comprehensive framework for all batteries placed on the EU market.
The regulation addresses the entire battery lifecycle – from raw material extraction to manufacturing, use, collection and recycling. It is a central part of the EU's Green Deal and Critical Raw Materials strategy.
Unlike the old directive, the Battery Regulation applies directly in all EU member states without national transposition. It introduces requirements for a digital battery passport, supply chain due diligence and minimum performance and durability standards.
Scope
Who is affected?
The regulation affects all economic operators in the battery value chain:
- Manufacturers – responsible for ensuring batteries meet all requirements before placing on the market
- Importers – must verify that the manufacturer has fulfilled their obligations
- Distributors – must act with due diligence
- Authorised representatives – act on behalf of the manufacturer within the EU
- Second-life operators – new in the regulation
The regulation categorises batteries into five types with partly different requirement levels:
- Portable batteries
- Light means of transport (LMT) batteries
- Starting, lighting and ignition (SLI) batteries
- Industrial batteries
- Electric vehicle (EV) batteries
Requirements
Key requirements
Key requirements in the Battery Regulation:
- Digital battery passport: EV batteries, LMT batteries and industrial batteries with capacity >2 kWh must have a digital battery passport with QR code providing access to technical data, material content and performance. The >2 kWh threshold applies specifically to industrial batteries – EV and LMT batteries are covered regardless of capacity
- Carbon footprint: Declaration of the battery's carbon footprint throughout the lifecycle, with upcoming maximum limits
- Recycled content: Minimum requirements for the share of recycled materials (cobalt, lead, lithium, nickel) – tightened progressively
- Performance and durability: Minimum requirements for capacity, lifespan, charge cycles and capacity retention
- Due diligence: Manufacturers must conduct due diligence for the supply chain regarding raw material origins
- Collection and recycling: Quantitative targets for collection rates of end-of-life batteries and requirements for material recycling efficiency
- Labelling and information: Extended labelling requirements with capacity data, chemical composition and the symbol for separate collection
- CE marking: Batteries must be CE marked and accompanied by an EU declaration of conformity
Timeline
Timeline and milestones
The Battery Regulation is implemented in stages:
- 17 August 2023: The regulation entered into force
- 18 February 2024: Certain labelling requirements take effect
- 18 August 2025: Carbon footprint declaration requirements for EV and industrial batteries (subject to adoption of delegated acts)
- 18 February 2027: Digital battery passport becomes mandatory for EV batteries and industrial batteries >2 kWh; supply chain due diligence requirements; design requirements for removability and replaceability of portable batteries
- 18 August 2027: Maximum carbon footprint limits (subject to adoption of delegated acts)
- 18 August 2028: Digital battery passport becomes mandatory for LMT batteries; minimum recycled content requirements (first level)
- 18 August 2031: Tightened recycled content requirements (second level)
The regulation repeals Battery Directive 2006/66/EC on 18 August 2025, with the exception of certain collection provisions which are repealed on 18 August 2027.
Compliance
Consequences of non-compliance
Non-compliance with the Battery Regulation entails:
- Batteries that do not meet requirements cannot be CE marked and cannot legally be sold within the EU
- Market surveillance authorities can require withdrawal and recall of batteries
- Sanctions and fines are determined by member states – they must be effective, proportionate and dissuasive
- Batteries without a digital battery passport after the respective deadline do not meet the conditions for placing on the market and may not be made available
- Inadequate supply chain due diligence can lead to separate sanctions
- Trade barriers: Non-compliance can result in batteries being stopped at EU external borders
- Reputation risk: Deficiencies in sustainability reporting and supply chain transparency can impact brand and customer relationships
Action plan
What should you do now?
- Classify your batteries: Identify which battery category (portable, LMT, SLI, industrial, EV) your products belong to and which requirements apply
- Map the supply chain: Begin due diligence work for raw materials – identify the origin of cobalt, lithium, nickel and natural graphite
- Measure carbon footprint: Start calculating your batteries' carbon footprint according to the methodology specified by the regulation
- Prepare for digital battery passport: Investigate what product data needs to be collected and how it should be provided digitally
- Review performance: Ensure your batteries meet minimum requirements for capacity, lifespan and charge cycles
- Plan collection systems: Establish or join collection and recycling systems for end-of-life batteries
- Update CE documentation: Include the Battery Regulation's requirements in technical documentation and EU declaration of conformity
Verca
How Verca helps
Verca integrates the Battery Regulation's requirements into the unified CE workflow. The platform's classification engine identifies which battery categories your products belong to and which specific requirements apply.
Documentation support is extended with templates for carbon footprint declaration, due diligence reports and the data required for the digital battery passport. Since much battery data overlaps with existing CE documentation, you can build on what already exists in the platform.
Verca monitors the harmonised standards and implementing acts developed under the Battery Regulation and notifies you when new requirements take effect. By managing the Battery Regulation together with GPSR, the Machinery Regulation and ESPR in the same platform, you get a unified view of your regulatory status.