Introduction

On August 18, 2025, the EU Battery Directive (2006/66/EC) was officially repealed, and the new EU Battery Regulation (EU) 2023/1542 has entered full mandatory enforcement.This regulation replaces the old framework and extends control from product-level compliance to full lifecycle management, imposing strict requirements on Chinese battery manufacturers regarding carbon footprint, supply chain due diligence, Battery Passport, and recycling responsibilities.

For exporters, compliance is no longer just about “obtaining test reports” —it is a systematic challenge involving data management, cost control, and end-to-end supply chain governance.As a professional testing and certification body, we provide a detailed analysis of core certification requirements and practical solutions based on the latest regulatory updates and industry best practices.

1. EU Battery Regulation: More Than Just a “Certificate Replacement”

Since August 18, 2024, multiple key provisions have become mandatory for industrial batteries, electric vehicle (EV) batteries, and energy storage systems (ESS).Unlike the old directive, the new regulation focuses on five critical areas:

① Safety & Sustainability

Stationary energy storage systems must pass strict safety tests such as EN IEC 62619 and UL 1973, including thermal runaway propagation testing.

② Carbon Footprint

Starting in 2025, EV batteries and industrial batteries above 2 kWh must disclose a carbon footprint declaration calculated according to the EU PEF (Product Environmental Footprint) methodology.

③ Battery Passport & Transparency

From February 18, 2027, the Battery Passport will be mandatory, disclosing material sources, carbon footprint, recycled content, and performance data.

④ Extended Producer Responsibility (EPR)

Producers are responsible for the collection, treatment, and recycling of waste batteries and must register in EU member states or join a Producer Responsibility Organization (PRO).

⑤ Supply Chain Due Diligence

For critical raw materials (cobalt, lithium, nickel, etc.), manufacturers must identify and manage human rights, environmental, and social risks in the supply chain.

2. Top 3 Compliance Challenges & Professional Solutions

While the regulatory framework is clear, manufacturers commonly face issues with unclear standards, unavailable data, and uncontrollable costs.Below are targeted solutions:

Challenge 1: Carbon Footprint Calculation Not Accepted by the EU

Many Chinese companies find that their domestic carbon calculation results fail EU data quality and database requirements (e.g., EF Database).

Solutions:

• Methodology Upgrade: Adopt ISO 14067 and EU PEF methodology instead of non-standard approaches.
• Data Traceability: Use LCA (Life Cycle Assessment) services to collect facility-level data on electricity mix, production parameters, and material consumption.
• Pre‑Audit: Identify data gaps before formal submission to ensure compliance with EU Commission implementing acts.

Challenge 2: Unclear Safety Standards for Stationary ESS

Article 12 requires state-of-the-art safety assessment, but no single standard is mandated.Different EU countries accept different standards, leading to “one test package not valid across markets.”

Solutions:

• Combined Test Strategy: Use a tailored package:EN IEC 62619 (cell/system safety)
  • UL 9540A (thermal runaway & fire testing)
  • IEC 63056 (energy storage battery safety).
• Technical File Pre‑Review: Prepare detailed documentation on thermal propagation protection and fire safety systems for market surveillance audits.

Challenge 3: Unlimited Supply Chain Due Diligence Liability

Due diligence applies upstream to mining operations, but downstream manufacturers often lack direct control —with penalties up to 4% of global turnover.Enforcement is delayed until August 18, 2027, with a threshold of €150 million annual turnover, but early preparation is critical.

Solutions:

• Compliance “Firewall”: Build a due diligence system based on OECD Due Diligence Guidance.
• Contractual Risk Allocation: Require upstream suppliers to provide compliance documents and define liability for non-compliance-related clearance failures.

3. Quick Reference: Key Compliance Requirements & Standards

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Conclusion

The EU Battery Regulation essentially reshapes the global battery industry’s green trade barrier.For Chinese manufacturers, it presents both a challenge and an opportunity to eliminate outdated capacity and enhance brand value.Early compliance with traceable, low‑emission, and high‑safety supply chain systems will be the key to success in Europe over the next five years.

Contact us for a tailored EU Battery Regulation compliance solution!