Loading…
Loading…
Regulation (EU) 2023/1542 ("EU Battery Regulation") replaces the 2006 Battery Directive with a substantially more demanding product-level framework organised around six interlocking obligations:
1. Supply-chain due diligence (mandatory since 18 August 2025) Economic operators with turnover > EUR 40 million must adopt a written supply-chain policy consistent with the OECD Due Diligence Guidance for Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights, covering the four critical materials: cobalt, lithium, nickel, and natural graphite. Required elements include risk-mapping, internal management systems, third-party audits, and public reporting. The scope covers all four battery categories except portable batteries.
2. Recycled-content thresholds (EV, industrial, SLI batteries) From 18 August 2031: ≥16% cobalt, ≥85% lead, ≥6% lithium, ≥6% nickel in new batteries. From 18 August 2036: ≥26% cobalt, ≥12% lithium, ≥15% nickel. These thresholds will structurally bid up demand for battery-grade recycled material.
3. Carbon-footprint declaration + performance-class labelling (from 18 February 2025) EV batteries and rechargeable industrial batteries > 2 kWh must carry a carbon-footprint declaration per kg of battery. Performance classes (A–E) will allow buyers to compare climate intensity across manufacturers; a mandatory threshold takes effect in a subsequent phase once the Commission establishes the class boundary.
4. Digital battery passport (from 18 February 2027) LMT, EV, and industrial batteries > 2 kWh must carry a QR-code-linked passport recording material composition, carbon footprint, supply-chain due-diligence status, and recycling instructions. Enables end-of-life routing, second-life assessment, and compliance audits by customs and market-surveillance authorities.
5. Collection and recycling efficiency targets Portable batteries: 63% collection by end-2027, 73% by end-2030. LMT batteries: 51% by end-2028, 61% by end-2031. Recovery efficiency (lead aside): 90% for Co/Cu/Ni from end-2027, 95% from end-2031; 50% lithium from end-2027, 80% from end-2031.
6. Removability and replaceability of portable batteries (by 2027) Portable batteries in appliances must be removable and replaceable by end users — a structural design mandate targeting consumer electronics. Aligns with the EU's broader Ecodesign for Sustainable Products Regulation (ESPR) direction.
must now track and disclose the carbon footprint of their battery pack, creating a competitive dimension around low-carbon cathode chemistry and green electricity in cell manufacturing.
due-diligence audits of their cobalt, lithium, nickel, and graphite sourcing — operationalising ESG supply-chain compliance into a legal obligation with market-access consequences.
industry (Umicore, Li-Cycle, Redwood Materials, Fortum) and will eventually require gigafactory designs to integrate recycled feedstock streams.
portable products to allow user battery removal by 2027 — a non-trivial design constraint for sealed form factors.
software and supply-chain traceability solutions are a direct beneficiary sector.
supply but does not impose product-level due-diligence or recycled-content thresholds. The Battery Regulation is downstream-product-focused; the two instruments are complementary.
strategic technology but does not impose product-level due-diligence or recycled content.
the Battery Regulation's due-diligence provision is a sector-specific lex specialis that co-exists with CSDDD for in-scope battery operators.
labour; the Battery Regulation's OECD/UNGP due-diligence covers forced labour as one element of a broader responsible-sourcing obligation.
(boundary between acceptable and non-acceptable class) not yet adopted as of 2025.
an open technical interoperability question.
thresholds or accelerate the due-diligence application dates remains to be seen.