Last updated: 1 January 2026
On 17 August 2023, Regulation (EU) 2023/1542 concerning batteries and waste batteries (“Batteries Regulation”) entered into force. The Batteries Regulation repeals and replaces the existing Batteries Directive (2006/66/EC) and seeks to make all batteries placed on the EU market more durable, safe, sustainable and efficient by introducing new mandatory design, content and conformity assessment requirements.
The Batteries Regulation is a key initiative of the European Green Deal and is the first circular economy legislation covering the entire life cycle of a product to be adopted.
Scope
Under the Batteries Regulation, all categories of batteries that are placed on the EU market, or that are put into service within the EU, are regulated, irrespective of where they are manufactured. This includes the types of batteries found in ordinary consumer goods (i.e., “portable” batteries); electric vehicle (EV) batteries; industrial batteries; starting, lighting and ignition batteries; and batteries for electric bikes, mopeds and e-scooters (i.e., light means of transport (LMT) batteries). The Batteries Regulation applies to all these batteries, regardless of their shape, volume, weight, design, material composition, chemistry, use or purpose. Furthermore, the Batteries Regulation also applies to batteries that are incorporated into or added to products or that are specifically designed to be incorporated into or added to products.
Key features of the Batteries Regulation
- Due diligence obligations: From 18 August 2027 onward, companies placing batteries on the EU market will need to put battery due diligence policies in place and have them verified by a notified body and periodically audited.
- Removability and replaceability: From 18 February 2027 onward, batteries used in consumer goods will need to be designed in such a way that they can be easily removed and replaced by consumers.
- New labeling requirements: Batteries must be CE-marked. In addition, further labeling requirements either already apply (e.g., the “separate collection symbol”) or will become applicable in stages in the future (e.g., a QR code linking to mandatory information).
- Recycled content: Industrial, EV and certain automotive batteries will be subject to minimum recycled content requirements for cobalt, lead, lithium and nickel from August 2031.
- Digital passports and carbon footprint declarations: These will be required for certain rechargeable industrial batteries, EV batteries and LMT batteries.
- (More) harmonized EPR framework: Since 18 August 2025, a more harmonized extended producer responsibility (EPR) framework has been applicable, allowing for more consistent implementation across the EU.
Note: The above-cited EPR rules require, among other things, the appointment of an authorized representative for EPR for batteries. However, on 10 December 2025, the European Commission published a proposal calling for this requirement to be suspended until 1 January 2035. This proposal is currently being debated by the EU legislators.
- Targets: Stricter targets apply for waste collection, recycling efficiency and material recovery.
Why does this matter?
The Batteries Regulation introduces significant new requirements covering manufacturing, design, labeling, collection and recycling throughout the entire life cycle of batteries, with the provisions becoming applicable over the course of many years. Notably, certain provisions had relatively short implementation deadlines with, for example, CE marking required from August 2024. Batteries that do not meet the requirements that applied from August 2024 can no longer be imported or distributed in the EU. Upcoming deadlines include supply chain due diligence, which will be mandatory from 18 August 2027, and battery passports for EVs, which will be mandatory from 18 February 2027.
