The Battery Regulation is here – find out how to ensure compliance

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.

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.