The EU Battery Regulation

The regulation differentiates between the following battery categories:

• Portable batteries
• General purpose portable batteries
• Batteries for light vehicles (LV)
• Starter batteries (SLI)
• Industrial batteries
• Electric vehicle batteries
• Stationary battery energy storage systems

The EU wants to become the first climate-neutral continent by 2030. For this reason, the CO2 footprint of batteries is also to be documented first and ultimately CO2 emissions reduced. This is to take place in three steps. And different deadlines apply depending on the battery type.

The first step: declaration of the CO2 footprint

For electric vehicle batteries, a declaration on CO2 emissions must be submitted from February 18, 2025. From February 18, 2026, this will apply to rechargeable industrial batteries without external storage. From August 18, 2028, this will also apply to LV batteries and finally from August 18, 2030, to rechargeable industrial batteries with external storage.

The second step: Labeling the CO2 intensity in certain categories or performance classes

The third step: Complying with defined maximum values for the CO2 footprint

The recycling rate of batteries is to be increased. Manufacturers are therefore obliged to set up take-back and collection systems.

The collection rates for waste portable batteries are to be gradually increased from the current 45% to 63% by the end of 2027 and 73% by the end of 2030. For waste portable batteries, collection rates of 51% by the end of 2028 and 61% by the end of 2031 apply.

In addition, the recycled content of cobalt, lead, nickel and lithium must be declared from August 18, 2028 (for LV batteries this applies from August 18, 2033). And from August 18, 2031, minimum quantities for recycled content will apply, which will be increased from August 18, 2036.

Batteries also require a CE marking in the EU. This indicates that the product complies with the applicable EU regulations and has undergone the necessary conformity assessment procedures. The conformity obligations that apply to manufacturers, EU importers and dealers differ.

According to Annex I of the EU Battery Regulation, the following restrictions apply to substances:

• Mercury: The mass fraction of mercury must not exceed 0.0005% (regardless of whether the batteries are installed in appliances, light means of transport or other vehicles).
• Cadmium: The mass fraction of cadmium in portable batteries must not exceed 0.002% (regardless of whether the batteries are installed in appliances, light means of transport or other vehicles).
• Lead: The mass fraction of lead in portable batteries must not exceed 0.01% (regardless of whether the batteries are installed in appliances). Zinc-air portable batteries in the form of button cells are exempt until August 18, 2028.

From February 18, 2027, a digital battery passport will be mandatory for LV batteries, industrial batteries with a capacity of more than 2 kWh and electric vehicle batteries. This is intended to provide information on the origin, composition, repair and recycling processes of the batteries.

Manufacturers, operators and waste managers will have to provide additional information in their reporting from August 18, 2025. In addition, initial distributors of batteries are obliged to fulfill due diligence obligations along their supply chain. This applies to companies with an annual turnover of at least 40 million euros.

The Excel template Extended Minerals Reporting Template (EMRT), which has been expanded to include the four minerals copper, graphite (natural), lithium and nickel, can be used for this purpose.