In August 2023, the EU's Batteries and Waste Batteries Regulations (EU 2023/1542) officially came into effect, replacing the long-standing Battery Directive 2006/66/EC. This regulation puts forward systematic new requirements for almost all battery categories entering the EU market, and is called "the most stringent battery regulation in history" in the industry. For export companies, this is not the future tense, but the ongoing tense.

1. Scope of application of regulations

The new regulations cover five major categories: portable batteries, starting lighting ignition batteries (SLI), light vehicle batteries (LMT, such as electric bicycles), electric vehicle batteries (EV) and industrial batteries (including energy storage). Compared with the old directive, supervision has been moved from "waste management" to "full life cycle".

2. Four core requirements that must be paid attention to

1. Carbon footprint declaration and classification.From 2025, EV batteries, LMT batteries and industrial batteries with a capacity greater than 2kWh will need to provide a carbon footprint statement; carbon footprint performance ratings and limits will be implemented subsequently. This means that companies must account for carbon emissions from raw materials to factory delivery and obtain third-party verification.

2. Proportion of recycled materials.Regulations stipulate minimum proportions of recycled materials for cobalt, lead, lithium and nickel in batteries (e.g. 16% cobalt, 6% lithium, 6% nickel from 2031) and require disclosure on labels or digital passports.

3. Digital Battery Passport.Starting from February 2027, EV batteries, LMT batteries and large industrial batteries must be equipped with digital passports. The manufacturer, material composition, carbon footprint, recycling information, performance and life data, etc. can be queried through the QR code.

4. Detachability and replaceability.From 2027, portable batteries will need to be designed to be easily removed and replaced by end users or independent operators, which poses new challenges to product structure design.

3. Other important obligations

  • due diligence: Battery operators need to conduct supply chain due diligence on the sourcing of raw materials (cobalt, lithium, nickel, graphite).
  • CE and Declaration of Conformity: Batteries need to be CE marked and accompanied by an EU Declaration of Conformity.
  • Labels and information: Capacity, chemical composition, recycling symbol, hazardous substance information, etc. need to be marked.
  • EPR Extended Producer Responsibility: Need to register in a member state and bear recycling and disposal costs.
  • Performance and durability: Some categories need to meet minimum requirements for electrochemical performance and durability.

4. Enterprise Response Checklist

First, start carbon footprint accounting as soon as possible, establish a data link from raw materials to finished products, and introduce LCA tools and third-party verification agencies when necessary. Second, confirm the source of recycled materials and the availability of certification documents with upstream suppliers. Third, evaluate whether the product structure meets the disassembly requirements and revise it in advance if necessary. Fourth, plan the data system and interface of the digital battery passport. Fifth, confirm the EPR registration requirements and fees in the target member state.

5. Conclusion

The new battery regulations are not a piece of paper, but a reshuffle of the industry chain. The earlier companies act, the more they can turn compliance costs into competitive barriers. For Chinese battery companies aiming to go overseas in the long term, this is both a challenge and an opportunity to build brand trust.