The new EU Battery Regulation

3D Darstellung Batterieproduktion
The EU Parliament adopted the new EU Battery Regulation on June 14, 2023, which will gradually replace Directive 2006/66/EC. Now, only the approval of the states is needed for the new regulation to enter into force.
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In this blog you will learn everything about the changes and novelties in a nutshell!

This new battery regulation has implications for all stakeholders: Manufacturers, importers, distributors, retailers, disposers, recyclers, service providers, online platforms and consumers.

The objectives of the regulation are to promote technological progress in the battery sector and to minimize the impact of their fabrication on the environment. To achieve these goals, it will introduce a series of requirements, measures and specific instruments that operators placing batteries on the market within the EU will have to comply with.

This Regulation applies to all categories of batteries placed on the market or put into service in the EU, regardless of whether they are manufactured in the EU.

For the first time, the new requirements will cover the entire life cycle of lithium batteries (from extraction of raw material to collection, recycling and reuse).

Going forward, batteries will be categorized into the following groups depending on their intended use

  • Portable batteries and sealed batteries weighing 5 kg or less
  • Device batteries for general use, rechargeable and non-rechargeable
  • LMT (light transport) batteries, encapsulated and weighing 25 kg or less.
  • SLI batteries (start, light and ignition) for motor vehicles
  • EV batteries intended for the propulsion of hybrid or electric vehicles
  • Industrial batteries and all other batteries weighing more than 5 kg that are not intended for use in vehicles or light transport equipment

BMS: Information about the health status (State of Health) and the expected lifetime of the batteries.

Moving forward, all stationary battery storage systems, LMT batteries, and electric vehicle batteries must be equipped with a BMS (battery management system) so that the battery passport can display current information about the condition of the batteries and the expected life of each battery system. The BMS determines the cell balance, state of charge (SOC) and state of health (SOH) of the battery from the voltage and current values of the battery.

Carbon footprint statement

The carbon footprint statement for rechargeable industrial batteries with a capacity greater than 2 kWh, LMT batteries and EV batteries is mandatory and must accompany the product until it becomes accessible via a QR code.

Carbon footprint analysis is an essential component of the EU Battery Regulation and critical to the development of a circular economy. The carbon footprint is calculated through the life cycle analysis (LCA) of the product. A set of rules and methods for quantifying the carbon footprint is used to evaluate and identify potential for improvement.

The declaration must contain the following information for each battery model:

  • Information about the manufacturer
  • Information about the batterie modell
  • Information about the geographical location of the battery production site
  • Information on the carbon footprint of the battery, calculated in kg CO2 equivalent per 1 kWh of the total energy delivered by the battery over its expected lifetime.
  • Information on the carbon footprint of the battery, differentiated by life cycle phases.
  • ID number of the associated EU declaration of conformity
  • Web link to the online version of the document that proves the carbon footprint values

Due Diligence Policy

Entities placing batteries on the EU market must develop and implement a Due Diligence Policy based on international standards. SMEs are an exception.

Manufacturers must outline what strategies and measures they currently employ to assess and address the social and environmental risks associated with the supply, processing, and trade of primary and secondary raw materials used in battery manufacturing.

Each battery manufacturer will be required to fulfill its due diligence obligations by developing and implementing a control process for its suppliers. The aim is to avoid purchasing policies that promote organizations that deny human rights, finance armed conflicts or support the exploitation of cobalt mines.

Recycling and recovery of spent batteries

The regulation sets binding targets for recycling efficiency and recovery of materials.

No later than December 31, 2025

  • (a) Recycling 75% of the average weight of lead-acid batteries.
  • (b) Recycling 65% of the average weight of lithium-based batteries.
  • (c) Recycling of 80% of the average weight of nickel-cadmium batteries.
  • (d) Recycling of 50% of the average weight of other spent batteries.

No later than December 31, 2030.

  • (a) Recycling of 80% of the average weight of lead-acid batteries
  • (b) Recycling of 70% of the average weight of lithium-based batteries.

No later than December 31, 2027

all recyclers must achieve the following material recovery targets:

  • (a) 90 % for cobalt
  • (b) 90 % for copper
  • (c) 90 % for lead
  • (d) 50 % for lithium
  • (e) 90 % for nickle

No later than December 31, 2031

all recycling processes must achieve at least the following material recovery targets:

  • (a) 95 % for cobalt
  • (b) 95 % for copper
  • (c) 95 % for lead
  • (d) 80 % for lithium
  • (e) 95 % for nickle

The European Battery Passport

In the future, all LMT batteries, industrial batteries with a capacity of more than 2kWh and electric vehicle batteries placed on the EU market must be registered electronically. This will be in the form of a battery passport that includes a QR code and CE marking to ensure compliance with safety and traceability requirements.

Other batteries are subject to the declaration of conformity and the CE marking obligation.

The battery passport is basically a digital document that streamlines communication between manufacturers, end users and recyclers and provides important information.

The battery passport must contain the following information

  • Name of the manufacturer and the brand of the battery
  • Battery type and batch or serial number or any other element that allows unique identification of the battery
  • Battery model designation
  • Date of manufacturing
  • Date of first placing on the market
  • Chemical composition
  • Potentially harmful substances contained in the battery
  • Recycled materials contained in the battery
  • Information and activities related to repair, reuse and disassembly
  • Treatment, recycling and recovery processes to which the battery may be subjected at the end of its service life

QR code on each battery

To allow consumers, economic operators and other stakeholders easy access to the information and traceability requirements contained in the battery passport, the information will be available via a QR code that:

  • is clearly visible printed or engraved,
  • is large enough to be read by commercially available QR code readers,
  • permanently attached to each battery.

If this is not possible due to the type and size of the battery, the QR code must be placed on the packaging and accompanying documents of the battery.

Both the battery passport and the associated QR code will no longer exist when the battery is recycled, as these documents follow the life cycle of the associated battery.

CE mark on the batteries

In addition to the battery passport, each type of battery placed on the market must bear the CE mark. This marking is awarded by a notified certification body and indicates that the product complies with EU requirements for safety, health and environmental protection. The marking must be applied to the battery before it is placed on the market and must be visible, legible and indelible (if this is not possible, it must be applied to the packaging and accompanying documents).

In addition, the CE marking must show the identification number of the certifying body and, if applicable, be accompanied by hazard pictograms or other markings related to the use, storage, transport and handling of batteries.


The innovations and changes are particularly extensive and complex. It is therefore important that the parties concerned deal with this issue intensively and at an early stage.

We are very happy to answer any questions or talk to you about the scope and upcoming tasks, and will keep you updated through our blog and newsletter.

Do not hesitate to contact us. We look forward to your call or e-mail!

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