Economic operators in the battery supply chain have just six months to comply with new EU regulations, warns TÜV SÜD. The new EU Batteries Regulation (2023/1542) will replace the previous Batteries Directive on 18 August 2025. From then on, manufacturers, importers and distributors must ensure that their batteries and battery-operated products meet new sustainability, labelling and safety requirements.
Non-compliance will lead to product removal from the market by enforcement authorities and potential financial penalties.
Any operator globally placing or putting such products into service within the EU must adhere to these new regulations, making compliance a crucial focus for businesses worldwide.
Comprehensive battery life cycle oversight
The updated EU Batteries Regulation covers all aspects of the battery life cycle, from raw material procurement and production to reuse and recycling. It introduces new battery categories based on their use and design and mandates third-party verification for specific compliance aspects.
Grant Gibbs, Senior Manager for Energy Storage at TÜV SÜD, highlights the urgency of compliance: “Companies throughout the supply chain have no time to waste if they want to continue selling their products in the EU market after 18 August. The EU Batteries Regulation introduces significant changes to enhance the sustainability and safety of batteries and battery-operated products. The regulation seeks to promote transparency and responsibility throughout the battery supply chain.” as outlined in the TÜV SÜD white paper,
“An Overview of the EU Battery Regulation”.
Key requirements of the new regulation
The EU Batteries Regulation (EU) 2023/1542, introduced on 12 July 2023, aims to enhance battery sustainability throughout its life cycle. Notable aspects of the regulation include:
The regulation applies to five categories of batteries: portable batteries, Starting, Lighting and Ignition (SLI) batteries, Light Means of Transport (LMT) batteries, EV batteries and industrial batteries. It promotes sustainability and a circular economy by encouraging a competitive and sustainable battery industry to support Europe’s clean energy transition while reducing dependence on fuel imports through improved battery efficiency.
The regulation enforces substance restrictions, maintaining existing bans on mercury and cadmium in batteries and introducing a new restriction on lead in portable batteries.
Additionally, it establishes Extended Producer Responsibility (EPR), requiring producers to take back waste batteries free of charge and ensure their separate collection and environmentally friendly recycling. Collection and recycling targets will gradually increase, with mandatory carbon footprint declarations and minimum recycled content requirements. To enhance digital traceability, starting on 18 February 2027, specific battery types must feature a battery passport with a QR code and CE marking for better monitoring and compliance.
Challenges for industry stakeholders
Implementing the new regulation presents significant challenges for manufacturers, suppliers and stakeholders. The high regulatory complexity and overlapping requirements may create confusion and make compliance difficult, particularly for niche or small-scale battery producers facing increased administrative and cost burdens.
Businesses must make substantial supply chain adjustments, implementing stringent policies for the responsible sourcing of materials like cobalt, lithium and nickel. Additionally, digital traceability through battery passports requires new IT systems and reporting mechanisms.
Manufacturers must modify their design and production processes to meet carbon footprint targets, recycled content requirements and hazardous substance restrictions.
Compliance with these new standards will demand significant investment in research and development. Furthermore, global compliance presents additional challenges, as battery components are sourced from multiple regions with varying standards, making it difficult to establish a unified compliance framework. Ensuring compliance for imported products will require significant enforcement efforts at the Member State level.
Impact on Battery Manufacturers
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Sustainable design: Products must meet stricter performance, durability and labelling standards.
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Expanded product categories: EV and LMT batteries are included, forcing manufacturers to adjust product lines.
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Recycling efficiency: Strict material recovery goals push manufacturers toward improved battery end-of-life management.
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Extended producer responsibility (EPR): Manufacturers are accountable for battery waste collection and disposal.
Supply chain implications
For battery component suppliers, the regulation imposes significant operational changes:
- Transparency and due diligence: Mandatory policies for sourcing key materials and annual environmental and social risk reports.
- Traceability requirements: Implementing a digital battery passport to track metrics across the supply chain.
- Increased costs: Compliance with new rules may lead to higher operational and production expenses.
Preparing for the August 2025 deadline
As the 18 August 2025 deadline approaches, businesses must act swiftly to ensure compliance.
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Conducting comprehensive supply chain audits to meet due diligence requirements.
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Investing in technology to support battery traceability and carbon footprint reporting.
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Collaborating with regulatory experts to ensure adherence to evolving compliance standards.
The new EU Battery Regulation 2023/1542 represents a landmark battery sustainability and accountability shift. Economic operators must proactively adapt to these requirements to secure market access and contribute to a more sustainable and transparent battery industry.