• Strengthen the EU’s internal market by promoting fair competition and facilitating the free movement of batteries within the Union.
• Promote a circular economy by encouraging the sustainable design, production and end-of-life management of batteries.
• Minimize the environmental and social impacts of batteries throughout their life cycle, from the extraction of raw materials to their disposal at the end of their life.

The Regulation covers all types of batteries, including portable, starting, lighting, electric vehicle and industrial batteries, with the exception of those used in military, space and nuclear applications.

Key features of the EU Battery Regulation

– Increased producer responsibility:

• Producers will have greater responsibility for the collection and recycling of the batteries they place on the market.
  Collection and recycling targets have been significantly increased.

– Material recovery targets:

• Mandatory targets will be set for the recovery of critical raw materials such as cobalt, copper, lead, lithium and nickel from recycled batteries by 31 December 2027.

– Recycling efficiency targets:

• Phased implementation of recycling efficiency targets for different battery types, including lead-acid, lithium-ion and nickel-cadmium batteries, starting in 2025.

– Minimum recycled content:

• Setting minimum levels for the use of recycled materials in the production of new batteries for cobalt, lead, lithium and nickel.

– Due diligence obligations:

• Mandates due diligence procedures for critical raw materials, focusing on environmental, social and governance (ESG) risks.
• Due diligence guidelines are expected from the European Commission in 2025.
• Third-party verification of due diligence will be required for battery manufacturers and suppliers from August 2025.

– Battery swap ability:

• Encourages the design of products with easily replaceable batteries.
• By 2027, portable batteries in devices must be easily removable and replaceable by the user.
• Light Means of Transport (LMT) batteries must be designed for easy removal and replacement by professionals.

– Battery Passport:

• Introduces a digital passport system to track and trace industrial batteries and EV batteries with a capacity of more than 2 kWh.

– Carbon footprint declaration:

• Requires carbon footprint declarations for EV batteries, industrial batteries above 2 kWh and LMT batteries.
• The regulation will gradually introduce performance classes and carbon footprint limits for EVs and LMTs, and rechargeable industrial batteries starting in 2025.

Requirements and commitments

– Sustainability and safety: Mandatory requirements for all batteries placed on the EU market.

– Labelling, marking and information: Labelling requirements to increase user awareness and facilitate proper disposal.

– Management of spent batteries: Rules for the management of spent batteries.

– Conformity assessment: Sets out procedures for conformity assessment.

– Market surveillance: Sets out requirements for market surveillance.

Restrictions on hazardous substances

The EU Battery Regulation imposes strict limits on the use of certain hazardous substances in batteries:

• Cadmium: Batteries containing more than 0.2% by weight of cadmium must be clearly labelled with the chemical symbol for cadmium.
• Lead: Batteries containing more than 0.4% lead by weight must be labelled with the chemical symbol for lead.
• Mercury: The use of mercury in batteries is strictly prohibited, with limited exceptions.
• These restrictions aim to minimize the environmental and health risks associated with these hazardous substances.

Impact on stakeholders

This Regulation will have a significant impact on a wide range of stakeholders, including:

• Battery manufacturers: Companies involved in the production of battery cells, modules, packs, energy storage systems and batteries for electric vehicles.
• Importers and distributors: Companies that import and distribute batteries and products containing batteries within the EU.
• Vehicle manufacturers: Undertakings involved in the manufacture, maintenance, repair and modification of battery-powered vehicles.

Deadlines and transition period

• The regulation will enter into force on 18 February 2024.
• CE marking compliance: From 18 August 2024, all batteries must bear the CE marking6.
• The supply chain due diligence obligation will apply from 18 August 2025.
• Extended producer responsibility and registration requirements will apply from 18 August 2025.
• Material recovery targets will apply from 31 December 2027.
• From 2027/2028, depending on the type of battery, minimum durability and performance levels will have to be met.

The EU Battery Regulation is of paramount importance for sustainable development, promoting a circular economy and reducing environmental impact. Battery manufacturers and importers need to understand and comply with the new requirements.