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The Battery Regulation is here – find out how to ensure compliance
Do you manufacture or sell products containing batteries on the European market? If so, the EU Battery Regulation affects you. These regulations are more comprehensive than previous legislation, setting requirements that cover the entire battery life cycle. Three experts explain the rules.
Over the past decade, the global battery sector has grown significantly in terms of both volume and economic value. In order to ensure that this growth continues in a sustainable and responsible manner, the EU has updated the rules for all organisations that place batteries on the European market.
What is the purpose of the EU Battery Regulation?
The Battery Regulation came into force in February 2024, fully replacing the previous Battery Directive by August 2025. The aim of the Regulation is to reduce the climate impact of battery production, create a more level playing field, and strengthen the European battery industry.
– There has been a lot of activity in the battery market in recent years. Today, there are far more types of batteries than when the old directive was originally drafted. The aim of the regulation is to incorporate these new developments while ensuring that the same rules apply across the EU,' says Cecilia Wästerlid, project manager for circular material flows at RISE.
While the previous directive adopted a clear waste management approach with rules on the collection, recycling and producer responsibility of used batteries, as well as restrictions on hazardous substances, the Battery Regulation instead takes a life-cycle approach. The new requirements relate to material recycling, traceability, and reducing the carbon footprint of production.
What are the key elements of the battery regulation?
To cover all types of batteries, the EU has shifted from three categories under the directive to five categories under the regulation. The definition of a battery producer has also been clarified. Both the main categories of batteries and the definition of a producer can be found in a fact box further down in this article.
Having trouble understanding the battery regulation?
RISE can guide you through the regulations and help you understand the requirements that apply to your business. Contact us by filling in the form:
In order to be sold on the European market, batteries and products containing batteries must display the CE marking. This certification confirms that all applicable EU requirements, including those set out in the Battery Regulation, have been met.
– CE marking involves product testing requirements. The Battery Regulation contains three articles relating to performance and safety testing. Although harmonised standards are not yet in place, they are expected to be developed in the future. In the meantime, we apply internationally recognised battery standards as best practice for performance and safety testing in our laboratories, explains Vedran Kovacevic, RISE's project manager and business developer for safety-critical battery testing.
The quality management systems of manufacturers of "high-risk products" must be audited.
Companies that manufacture or supply certain types of large battery, primarily for industrial and electric vehicles, to the market will also need to certify their quality management systems. This is because these products are classified as high-risk. The products must not only be safe, but also be manufactured under controlled conditions.
– While many of the rules in the Battery Regulation are not new to companies, they may not realise that they have to send samples to a laboratory for testing. The test results must then be reviewed by the notified body that certifies the organisation’s quality management system. Some companies will also be required to carry out due diligence, explains Martin Tillander, unit manager within Certification at RISE.
The due diligence requirement is one of the new provisions in the regulation. In short, this means that companies placing large industrial or electric vehicle batteries on the market must map their supply chains and ensure that the raw materials have been extracted and produced in a sustainable and ethical manner.
– From 2027 onwards, larger batteries will require a battery passport in the form of a QR code linking to digital information about the battery in question. This passport must contain details of the battery's material composition, capacity, and climate impact, explains Cecilia Wästerlid.
What responsibilities and requirements do producers have in relation to recycled materials?
All producers must register with the Swedish Environmental Protection Agency and ensure that their batteries are collected and recycled correctly. One way to do so is to join a Producer Responsibility Organisation (PRO), such as El-Kretsen, which has an existing nationwide infrastructure for collection and recycling.
Another new feature of the regulation is that the EU has set recycling targets for lithium, cobalt, nickel, copper and lead. From 2027 onwards, at least 50 per cent of the lithium in waste batteries collected for recycling must be recycled. This figure will increase to 80 per cent from 2031.
The extensive circularity requirements set out in the Battery Regulation require a thorough understanding of the type of battery in question and its chemistry in order to be met. Furthermore, safety considerations relating to dismantling and the recycling process itself must be taken into account.
– At RISE, we address issues throughout the entire battery lifecycle, from design to material recycling. We provide the analysis, testing environments and expertise needed to develop effective battery recycling processes, says Cecilia Wästerlid.
At RISE, we address issues throughout the entire battery lifecycle, from design to material recycling. We provide the analysis, testing environments and expertise needed to develop effective battery recycling processes.
Are you struggling to see the bigger picture? You’re not alone
The Battery Regulation is one of the most comprehensive sets of rules for a single product category within the EU. It covers the entire battery lifecycle, from raw materials to recycling. Cecilia Wästerlid acknowledges that grasping the full scope of the regulation can be challenging.
This law is inherently complex. This is primarily due to the way it is drafted, with references to delegated acts intended to specify the details. These delegated acts are still being finalised, and I get the impression that there are more of them than usual in this regulation, she says, continuing:
– The recycling requirements stipulate that a certain percentage of each battery must be recycled and used in a new product, which sounds simple enough. However, questions arise when it comes to putting this into practice. What exactly is the percentage? And how should it be measured? These questions can be particularly challenging for smaller businesses, so it is a good idea to seek help from an advisor who can clarify any uncertainties.
How to ensure compliance with the Battery Regulation
- Identify your batteries
Identify the batteries that you sell, import or use in products, and the requirements that apply to them. - Ensure that batteries meet the technical requirements.
Batteries must meet safety, performance and quality requirements before they can be placed on the EU market. RISE carries out accredited battery testing. - Prepare the correct documentation and supporting evidence
You need to be able to demonstrate that your batteries comply with the regulations. RISE can assist companies with preparing the required documentation. - Managing requirements relating to sustainability and climate impact
For certain batteries, it is a requirement to report the carbon footprint and present a life-cycle assessment. RISE carries out life-cycle assessments and calculates the carbon footprint of batteries in accordance with EU methodology. - Ensure traceability
The Battery Regulation sets out traceability requirements that must be documented via digital battery passports. RISE can assist with the development of these passports.
Five battery categories
BB (Portable Batteries): Portable batteries weighing up to 5 kg which are not intended for industrial use and which do not fall into any other category.
SLI (starting, lighting, ignition): Starter batteries. These are the batteries for the lighting and ignition systems.
LMT (Light Means of Transport): batteries for light transport vehicles. Wheeled vehicles with batteries weighing up to 25 kg.
EV (electric vehicle): Batteries for electric or hybrid vehicles. Batteries weighing over 25 kg.
IND (Industrial): Industrial batteries designed for industrial use or energy storage. Batteries weighing over 5 kg that do not fit into any other category.
Who is the producer?
In practice, a manufacturer is an entity that places a battery on the EU market under its own name or brand. This definition covers any entity that:
- Manufactures and markets batteries under its own brand name.
- Have batteries manufactured and sell them under their own name/brand (private label); or
- Import batteries from a third country and place them on the EU market.
- Sell batteries via distance selling (e.g. e-commerce) directly to end users in a Member State in which they are not established.
Crucially, what matters is market access, not where the battery was physically manufactured.
