The EU Battery Regulation (EU) 2023/1542 officially entered into force on August 17, 2023. This regulation fully replaces the original Battery Directive (2006/66/EC) and imposes more stringent mandatory requirements on all types of batteries entering the EU market. As a core component of the EU Green Deal, the new regulation aims to ensure batteries placed on the EU market are more sustainable, safe, and circular.

Unlike the previous Battery Directive, the EU Battery Regulation is directly enforceable as law across all member states without transposition into national legislation, significantly enhancing its uniformity and enforceability. This shift means the battery industry faces unprecedented compliance challenges, while also offering first-mover advantages to enterprises that adapt early.

Scope of Application & Battery Classification

The EU New Battery Regulation applies to almost all battery types placed on the EU market, excluding those for military, aerospace, nuclear energy, and other special uses. Batteries are classified into five categories:

• Portable batteries: Sealed batteries weighing <5kg and not falling into other categories.
• Light Mobility Batteries (LMT): Sealed batteries weighing <25kg, used to power L-category vehicles (e.g., e-bikes and other two-wheelers).
• Starting, Lighting, and Ignition (SLI) batteries: Used for vehicle ignition, lighting, or starting; or auxiliary/backup batteries for vehicles/transport equipment.
• Electric Vehicle (EV) batteries: Traction batteries for hybrid/battery electric vehicles, or batteries for L-category light vehicles weighing >25kg.
• Industrial batteries: Designed for industrial use (including repurposed industrial batteries), or other batteries >5kg not in the above categories.

Notably, the regulation covers cells, battery modules, and battery systems—with specific safety requirements for stationary battery energy storage systems (BESS).

Core Requirements & Implementation Timeline

The EU Battery Regulation introduces groundbreaking requirements phased in over time:

1. CE Marking & Conformity Assessment

From August 18, 2024, all batteries (whether integrated into products or supplied separately) must bear the CE mark per the new regulation. The CE mark is a legal prerequisite for EU market access, proving compliance with EU safety, health, and environmental standards.

2. Carbon Footprint Requirements

• February 18, 2025: EV batteries must include a carbon footprint declaration.
• February 18, 2026: Mandatory carbon footprint declarations for rechargeable industrial batteries (>2kWh).Declarations must be calculated per battery model/manufacturing plant and verified by an EU Notified Body.

3. Recycled Content Requirements

From August 18, 2028, rechargeable industrial batteries (>2kWh) and EV batteries must meet recycled material ratio targets for critical materials (cobalt, lead, lithium, nickel, etc.).

4. Battery Passport & Digital Information

From February 18, 2027, all LMT batteries, industrial batteries (>2kWh), and EV batteries placed on the EU market require a digital battery passport—an electronic record (accessible via QR code) containing battery model, material composition, carbon footprint, supply chain details, etc.

5. Due Diligence Requirements

Originally scheduled for August 18, 2025, supply chain due diligence rules are postponed to August 18, 2027. Applicable to economic operators with annual turnover >€40 million, it mandates due diligence on raw material supply chains to mitigate environmental and social risks.

6. Performance & Removability Requirements

From February 18, 2027, portable and LMT batteries must be easily removable/replaceable by users with common tools.

Table: Key Implementation Timeline of the EU Battery Regulation

Impacts & Challenges for Chinese Battery Enterprises

The regulation will reshape China’s battery export landscape:

1. Rising Compliance Costs

Enterprises face increased costs for carbon footprint accounting, battery passport system development, supply chain due diligence, and technical upgrades.

2. Stricter Supply Chain Transparency

Mandatory traceability for critical raw materials (cobalt, lithium, nickel, natural graphite) requires end-to-end supply chain tracking to verify legal and ethical sourcing.

3. Higher Technical Barriers

Carbon footprint, recycled content, and performance/durability rules drive the need for greener production processes and advanced battery technologies.

4. Reshuffled Market Competition

Early adopters of compliance measures will gain EU market share, while slow adapters risk losing access to this key market.

Our Professional Compliance Services

1. Carbon Footprint Accounting & Verification

• Calculate battery carbon footprints per EU methodologies.
• Prepare and validate carbon footprint declarations for Notified Body review.

2. Battery Testing & Certification

• Safety Testing: Compliance with BESS safety requirements under the regulation.
• Performance/Durability Testing: Verify electrochemical performance and durability against annex requirements.
• Hazardous Substance Testing: Detect restricted materials (mercury, cadmium, lead) in batteries.

3. Battery Passport Solutions

• Build digital battery passport systems to collect, manage, and display required data (model, materials, carbon footprint, etc.).

4. Supply Chain Due Diligence Support

• Identify and mitigate environmental/social risks in raw material supply chains.

5. CE Conformity Assessment

• Guide enterprises through the CE marking process to ensure full compliance with the new regulation.

The EU Battery Regulation (EU) 2023/1542 ushers in a new era of full-lifecycle battery management globally. For Chinese battery enterprises, it is both a challenge and an opportunity—proactive compliance will unlock long-term competitiveness in the EU and global markets.

Guangdong Energy Storage Testing Technology Co., Ltd. leverages its technical expertise and project experience to deliver one-stop compliance solutions for the EU Battery Regulation. We support your battery products in meeting all regulatory requirements, ensuring seamless EU market access and a competitive edge in the global green energy transition.

If you have questions about the EU Battery Regulation or need compliance support, contact Guangdong Energy Storage Testing Technology Co., Ltd. today! Our team provides tailored technical consulting and compliance solutions to navigate the new regulatory landscape.