EU Battery Regulation to Replace Battery Directive 2006/66/EC

The European Union's new Battery Regulation (EU) 2023/1542, which officially replaced the outdated Battery Directive 2006/66/EC, sets a unified legal framework for the sustainability, safety, and circularity of batteries across the EU. The regulation entered into force on August 17, 2023, and introduces binding requirements on carbon footprint, recycled content, supply chain due diligence, and the battery passport.

What's New Compared to the Battery Directive?

This regulation is no longer a directive—it is directly applicable across all EU Member States without needing national transposition. It covers all battery types—portable, industrial, automotive, LMT (Light Means of Transport), and EV (Electric Vehicle) batteries—and introduces specific rules for each based on their classification and use.

Key changes include:

• CE marking is now mandatory for most batteries.
• Due diligence obligations for critical raw materials.
• Carbon footprint disclosures and thresholds.
• Digital battery passports for traceability and transparency.
• Recycled content and material recovery mandates with set targets.
• Design requirements for replaceability, removability, and durability.

CE Marking and Conformity Requirements

All batteries placed on the EU market must undergo a conformity assessment procedure and bear the CE marking to indicate compliance. The assessment route depends on battery type:

• Portable and small industrial batteries (<2 kWh): Can self-declare via internal production control.
• EV batteries, LMT batteries, and large industrial batteries: Require notified body involvement.

The CE mark must be visible, legible, and indelible, along with the declaration of conformity, which must be kept for 10 years .

Battery Passport: Digital Traceability Starts 2027

From February 18, 2027, battery passports will be mandatory for:

• EV batteries
• LMT batteries
• Industrial batteries >2 kWh

The passport must be:

• Electronic and machine-readable
• Linked via QR code
• Include information such as manufacturer ID, material composition, carbon footprint data, and recycled content .

The passport will also link to the European Battery Passport Platform, ensuring traceability and compliance monitoring across the product lifecycle.

Recycled Content and Recovery Targets

The regulation sets minimum recycled content requirements for cobalt, lead, lithium, and nickel in batteries:

• By 2030:
  • 12% cobalt
  • 85% lead
  • 4% lithium
  • 4% nickel
• By 2035:
  • 20% cobalt
  • 85% lead
  • 10% lithium
  • 12% nickel

Additionally, by December 31, 2027, recovery targets in recycling facilities must meet:

• 90% for cobalt
• 95% for lead
• 70% for lithium
• 90% for copper and nickel .

Supply Chain Due Diligence (Article 48)

From August 18, 2025, manufacturers placing batteries on the EU market must conduct due diligence on the sourcing of:

• Cobalt
• Lithium
• Nickel
• Natural graphite

They must:

• Establish a due diligence policy
• Implement a risk management system
• Use third-party verification and reporting
• Publicly report on risks and mitigation steps

These steps align with the OECD Due Diligence Guidance and are mandatory for companies with annual turnover >€40 million .

Key EU Battery Regulation (EU) 2023/1542 Deadlines & Timeline

Why EU Battery Regulation Matters

• Global Impact: Non-EU manufacturers must comply if selling into the EU.
• Product Design Pressure: Replaceability, safety, and recycled content now influence market access.
• Compliance Complexity: Managing supply chain data, declarations, and battery passports requires dedicated infrastructure.
• Enforcement Risk: Non-compliance may lead to withdrawal from the EU market or administrative fines.

How Acquis Helps

With Acquis, your battery compliance operations are automated and audit-ready:

• Built-in EU Battery Regulation workflow
• Battery passport-ready architecture
• Automated due diligence tracking
• CE mark documentation control
• Recyclability and carbon data management

Schedule a demo to see how Acquis simplifies EU Battery Regulation compliance at scale. acquiscompliance.com/contact-us