How EU Battery Rules Will Reshape Product Design and Supply Chains
The European Union has introduced sweeping new rules to ensure batteries are more sustainable, safe, and circular.
The EU Battery Regulation (EU 2023/1542) came into force on 17 August 2023, replacing the 2006 Battery Directive. This regulation is directly applicable in all EU member states and covers virtually all types of batteries placed on the EU market, including:
Portable batteries
Automotive SLI batteries (Starting, Lighting, Ignition)
LMT batteries (e.g., e-bikes, e-scooters)
EV batteries (for electric vehicles)
Industrial batteries (e.g., energy storage)
Only a few specialised batteries (e.g., military, space, or nuclear) are exempt.
Below is an accessible overview of the current EU battery regulations, key upcoming changes, and what areas businesses need to focus on for compliance.
Why New Battery Rules?
Batteries are central to the clean energy transition, powering everything from smartphones to electric vehicles. The regulation takes a full life-cycle approach, aiming for:
Reduced carbon footprint
Safer battery chemistry
Responsible sourcing
Enhanced reuse and recycling
As battery demand is expected to grow 14-fold by 2030, these rules aim to minimise environmental and social impacts while supporting the EU internal market with CE conformity and innovation incentives.
Battery Categories and Scope - Which batteries are affected?
Essentially all batteries sold in the EU fall under the regulation’s scope, each with specific provisions. The regulation defines several categories:
Category | Description |
---|---|
Portable | Small, sealed batteries under 5 kg (e.g., AA, phone batteries) |
SLI | Starting, Lighting, Ignition batteries for vehicles |
LMT | Batteries ≤25 kg for light transport (e-bikes, scooters, etc.) |
EV | Batteries >25 kg used in electric vehicles |
Industrial | Batteries >5 kg not falling into the above, or designed for industrial use |
Each category has tailored requirements. However, the core principles of sustainability, safety, labeling, and end-of-life management apply across all batteries. Businesses from electronics manufacturers to electric car makers and industrial equipment suppliers all need to ensure the batteries they place on the EU market meet these new rules.
Sustainability Requirements
Limit on harmful substances: Mercury, cadmium, and lead are being restricted. Safer battery chemistry is now expected.
Carbon footprint disclosure: From Feb 2025, EV battery makers must disclose life-cycle carbon footprint. Industrial and LMT follow in 2026 and 2028.
Recycled materials reporting: Required from 2027–2028. Targets apply from 2031 (e.g., 16% cobalt, 6% lithium).
Ethical sourcing: Large producers must track raw materials to prove ethical and environmentally sound sourcing. Note: Due diligence obligations may be postponed to August 2027 pending July 2025 consultation.
Safety & Performance
Minimum durability standards: Rules will specify minimum capacity retention over time.
Stricter safety requirements: All batteries must carry CE marking from 18 August 2024.
Removable batteries: By Feb 2027, portable batteries in consumer products must be user-replaceable ([Art. 11]).
Second-life reuse: The Regulation supports second-life applications (e.g., using EV batteries in energy storage), but implementation details are still being shaped by delegated acts. Manufacturers will be required to share technical and performance data to enable safe and verifiable reuse. Detailed conditions (testing, data, safety) will be clarified in delegated acts by 2026–2027.
Labelling & Information
More info on the label: Batteries must show capacity, chemical makeup, and safe disposal instructions.
QR codes required: From 2027, each battery must have a QR code that links to a Digital Battery Passport, a detailed online profile with carbon footprint, material content, and compliance info.
Better user guidance: Instructions must explain safe use, storage, disposal, and how to remove or replace the battery
End-of-Life Management
Higher collection targets
Companies must meet phased collection targets for portable batteries:- 63% by 2027
– 73% by 2030
These targets are based on the average annual weight of portable batteries placed on the market in the three previous years.
No landfilling or incineration
All waste batteries must be collected and sent to recycling. Landfilling and incineration are prohibited across the EU.
Recycling Efficiency
By 2025:
– Lead-acid: 75%
– Lithium-based: 65%
– Nickel-cadmium: 80%
– Other batteries: 50%
By 2030:
– Lead-acid: 80%
– Lithium-based: 70%Material Recovery
By 2027:
– Cobalt, Copper, Nickel, Lead: 90%
– Lithium: 50%
By 2031:
– Cobalt, Copper, Nickel, Lead: 95%
– Lithium: 80%
Methodology confirmed by delegated act published 4 July 2025, entering into force 24 July 2025
Full traceability
Every battery’s journey, from use to recycling, must be tracked and documented.
Digital Battery Passport (By 2027)
Required for:
EV batteries
Industrial batteries >2kWh
LMT batteries
Must include:
Carbon footprint
Materials content
Date | Milestone |
---|---|
Aug 17, 2023 | Regulation entered into force. A six-month transition period began. |
Feb 18, 2024 | Core provisions applied, including heavy metal restrictions and documentation. The previous Batteries Directive remains partially in effect until August 2025. |
Aug 18, 2024 | CE marking and conformity assessment became mandatory for all batteries. |
Feb 18, 2025 | Carbon footprint declarations required for new EV batteries. |
4 July 2025 | New delegated act sets rules for calculating recycling efficiency and recovery rates. Enforceable from 24 July 2025. |
️ ⚠️ July 2025 | The European Commission is considering postponing due diligence obligations to August 2027 and raising SME exemption thresholds. Stakeholder consultation closes 31 July 2025. |
Aug 18, 2025 | Enforcement of collection targets and supply chain due diligence (unless delayed). Producer responsibility schemes must be operational. |
Feb 18, 2026 | Carbon footprint declarations apply to industrial batteries >2kWh. |
Early 2027 | Batteries in devices must be removable by the user. Digital Battery Passport system launches. |
Aug 18, 2027 | Carbon footprint labelling classes for EV batteries expected. |
Aug 18, 2028 | Recycled content reporting becomes mandatory for EV, SLI, and industrial batteries. |
Jan 1, 2031 | Recycled content targets (e.g., 16% cobalt, 6% lithium) must be met. |
2035–2036 | Second step of recycled content targets applies (e.g., 26% cobalt, 12% lithium). |
These timelines illustrate that the EU Battery Regulation is phased: immediate changes now, and more stringent requirements coming over the next 5–10 years. Companies in the battery supply chain should use this lead time to adjust designs, establish data collection systems, and improve recycling capabilities to meet each new milestone.
Non-compliance could result in products being barred from the EU market or other penalties, so early action is prudent.
Key Takeaways
The EU’s battery rules reshape how batteries are designed, sourced, tracked, and recycled. The changes affect battery makers, electronics brands, recyclers, automotive OEMs, and energy storage firms.
If your business works with batteries in any capacity, now is the time to:
Update product design for removability and durability.
Establish data systems for traceability and carbon accounting.
Prepare for digital passport, reporting, and verification requirements
Need help getting ready?
Noviqtech’s Carbon Central platform supports traceable carbon reporting, digital passport integration, and auditable supply chain data. Contact us to prepare for compliance, and lead with confidence in the world’s most advanced battery market.
Article by

Dipam Gandhi
Environmental Consultant
Published on
18 July 2025