EU Battery Regulation

Regulation (EU) 2023/1542

Scope and battery categories

Replaces the Battery Directive (2006/66/EC). Applies to all batteries placed on the EU market, structured into five categories with category-specific obligations and timelines.

In force

17 August 2023. Most operational obligations phase in from 18 August 2024 through 2036.

Categories

(1) Portable, (2) Light Means of Transport (LMT — e-bikes, e-scooters), (3) Starting/Lighting/Ignition (SLI), (4) Industrial, (5) Electric Vehicle (EV).

Replaces

Directive 2006/66/EC and amends Regulation (EU) 2019/1020.

Articles 47–53

Supply chain due diligence

Economic operators placing batteries on the EU market must establish, verify, and publicly disclose due-diligence policies covering specified raw materials and social/environmental risk categories.

Materials in scope

Cobalt, lithium, natural graphite, nickel — and their compounds, used in active battery materials.

Risk categories

Human rights (forced labour, child labour, indigenous rights), environment (water, biodiversity, hazardous emissions), and integrity (bribery, corruption, conflict).

Applies from

18 August 2025 (companies with annual net turnover below €40m have a longer phase-in).

Process

OECD-aligned five-step framework — management system, risk identification, mitigation, third-party verification, public reporting.

Verification

Independent third-party body, accredited under EU rules. Verification report covers methodology, findings, and remedial actions.

Material scope mirrors the upstream geography that the Critical Raw Materials Act treats as strategic — cobalt (DRC), nickel (Indonesia), lithium (Chile, Australia, Argentina), natural graphite (China). The same supplier countries appear under both regulations.

Article 7

Carbon footprint declaration

Mandatory cradle-to-gate carbon-footprint declaration for EV, LMT, industrial (>2 kWh) and rechargeable industrial batteries. Methodology set by delegated acts.

Declaration

Per battery model and manufacturing plant. Kg CO₂eq per kWh of total energy provided over expected service life.

EV batteries

From 18 February 2025 — declaration required. From 18 August 2026 — performance class. From 18 February 2028 — maximum lifecycle threshold.

Industrial >2 kWh

Phased on the same logic, ~12 months behind EV milestones.

Methodology

EU Product Environmental Footprint (PEF) family of methods, with battery-specific Category Rules. Cradle-to-gate (raw material acquisition → manufacturing gate).

Article 8

Recycled content thresholds

Industrial, EV, and LMT batteries must contain a minimum share of recycled cobalt, lithium, lead, and nickel — recovered from post-consumer or manufacturing scrap.

From 18 August 2031

Cobalt: 16%. Lead: 85%. Lithium: 6%. Nickel: 6%.

From 18 August 2036

Cobalt: 26%. Lead: 85%. Lithium: 12%. Nickel: 15%.

Documentation

Per battery model and manufacturing plant. Subject to third-party verification.

The recycled-content rule is the demand-side complement to the Critical Raw Materials Act benchmark of 25% EU annual consumption from recycling by 2030.

Articles 77–78

Battery passport

Digital record accessible via QR code, carrying static and dynamic data on origin, performance, carbon footprint, due diligence, and end-of-life.

Applies to

EV, LMT, and industrial batteries >2 kWh.

Live from

18 February 2027.

Data fields

Manufacturer, type, materials composition, carbon footprint, due-diligence report, recycled content, state-of-health, repair and dismantling instructions.

Access

Tiered — public, professional, and authority access depending on data class. Operates via the EU Battery Pass digital infrastructure.

Battery passport is the first operational deployment of the EU Digital Product Passport architecture under ESPR. Pattern likely to extend to other product categories.