New EU Regulation on Batteries: key takeaways
New challenges
Battery use is growing rapidly across Europe, driven by the development of electronic devices, electric vehicles, and energy storage systems. Initially based on lead- or nickel-based technologies, batteries are now predominantly lithium-based, raising new environmental, economic, and ethical challenges.
In response to these technological developments and the strategic importance of the sector, the European Union has introduced a harmonised regulatory framework. The objective: to ensure safety, minimise environmental impacts, and regulate the entire battery life cycle at the European level.
European Batteries Regulation 2023/1542
Until recently, the European regulatory framework for batteries was based on Directive 2006/66/EC, which mainly focused on the collection and recycling of batteries to reduce their environmental impact. However, this directive allowed Member States significant flexibility in its implementation, resulting in a fragmented and inconsistent application across the EU.
To address these issues and harmonise battery legislation, the EU adopted the European Battery Regulation (EU) 2023/1542, published on 28 July 2023 and in effect since 18 February 2024. As part of the European Green Deal, this regulation aims to make the entire battery life cycle more sustainable, from production to end-of-life. The distribution of the regulation’s articles throughout the battery life cycle is illustrated in the diagram below.
The new regulation covers all types of batteries, whether sold individually or integrated into devices or vehicles, classified into five distinct categories:
- Portable batteries (weighing less than 5 kg, such as those used in electronic devices)
- SLI batteries (starting, lighting, and ignition – for vehicles)
- Batteries for light means of transport (LMT) – such as electric bikes, electric scooters, and hoverboards
- Batteries for electric vehicles (EV)
- Industrial batteries – used in industrial settings or large factories
It introduces detailed requirements on sustainability, labelling, and due diligence, with particular attention to lithium batteries, due to their widespread use in electric vehicles and portable electronic devices, and their content of critical raw materials.
While the provisions of the regulation will be gradually implemented until 2036, Directive 2006/66/EC will be fully repealed on 18 August 2025, after which the regulation will become the sole legal framework governing batteries in the EU.
Timeline of the European Battery Regulation (EU) 2023/1542
The regulation’s articles provide for different timelines depending on the type of battery. Below are the key initial deadlines for electric vehicle batteries and industrial batteries.
These timelines have experienced various delays depending on the articles. For example, the final format of the methodology relating to the carbon footprint of electric vehicle batteries, initially scheduled for early 2024, has yet to be published. In this article, we will take a closer look at the progress of the regulation’s implementation.
Methodology for the carbon footprint
The regulation requires manufacturers to calculate and declare the carbon footprint generated throughout the battery production process and at their end of life. This is a fundamental measure aimed at encouraging the reduction of greenhouse gas emissions across the entire value chain.
The measure will be implemented progressively:
| Battery type | Mandatory from |
|---|---|
| Batteries for electric vehicles (EV) | |
| Rechargeable industrial batteries (capacity > 2 kWh) | |
| Batteries for light means of transport (LMT) | 18 August 2028 or 18 months after the entry into force of the delegated act |
| Stationary energy storage systems (capacity > 2 kWh) | 18 August 2030 or 18 months after the entry into force of the delegated act |
What is the current status?
- Electric vehicle batteries: the draft Delegated Act was published on 30 April 2024, and the consultation period ended on 28 May 2024. There has been no update since. Its entry into force is already delayed by a year and a half.
- Industrial batteries: on 11 April 2025, the JRC published a report entitled Rules for the Calculation of the Carbon Footprint of Industrial Batteries without External Storage (CFB-IND). This report builds on the methodology developed for electric vehicles. Some ongoing harmonisation efforts, such as electricity modelling, are still pending the publication of the final version of the Delegated Act.
- Light means of transport (LMT) batteries: on 23 June 2025, the JRC published its first technical report, based on the methodology applicable to industrial batteries. As such, it is also on hold pending the publication of the final version of the Delegated Act for harmonisation.
WeLOOP responded to the call for comments for all three battery categories, focusing its feedback on recycling methodologies and the overall limitations of Life Cycle Assessment (LCA), drawing on its expertise in batteries, the Circular Footprint Formula, and battery recycling processes.
Recycling efficiency and material recovery
On 21 March 2025, the European Commission published the Delegated Act on the methodology for calculating and verifying the recycling efficiency rates of lead batteries, lithium-ion batteries (LIBs), nickel-cadmium batteries, and other waste batteries, as well as the recovery of materials such as cobalt, copper, lead, lithium, and nickel.
The targets for recycling efficiency and recycled content shown in the tables below were already set in the Battery Regulation and have not been updated in the present Delegated Act.
Due Diligence
Battery manufacturers are required to publicly disclose their due diligence practices to prevent or mitigate the harmful effects of batteries on the environment, including waste management.
The due diligence article refers to mandatory sustainability and ethical sourcing practices for key raw materials used in batteries. It aims to address environmental, social, and human rights risks throughout the supply chain, particularly in high-risk mining areas.
On 21 May 2025, the European Commission published an amendment extending the compliance deadline for battery manufacturers and exporters from 18 August 2025 to 18 August 2027. This will also allow more time for the establishment of third-party notified bodies.
Notified bodies
Within the framework of European regulation, a notified body is an independent organisation designated by a Member State to assess the conformity of products with European requirements.
For batteries, these bodies are particularly involved in:
- conformity assessment and CE marking (Art. 17),
- the calculation of the carbon footprint (Art. 7) and recycled content (Art. 8),
- the verification of due diligence (Arts. 48–52).
Their role is to ensure impartial certification, guaranteeing the compliance of batteries in terms of sustainability, safety, and performance. They also contribute to traceability, legal certainty, and consistency in the application of the regulation across the EU.
However, in the absence of publication of the official methodologies, Member States are not yet able to designate notified bodies for certain obligations, such as the carbon footprint.
Labelling
- Since 18 August 2024, all manufacturers are required to affix the CE marking on batteries, certifying their compliance with EU requirements on safety, health, and environmental protection.
- The Commission is expected to adopt an implementing act on the specifics of labelling requirements by 18 August 2025. Depending on the exact adoption date, it will come into effect between August 2026 and February 2027. These labels must include essential information such as capacity, expected lifespan, performance, chemical composition, appropriate disposal methods, recycled content, and carbon footprint.
- From February 2027, most of this information will also need to be accessible in the form of a Digital Product Passport (DPP) via a QR code to ensure more comprehensive and up-to-date communication.
Security
Regulation (EU) 2023/1542 also introduces targeted measures to enhance battery safety and reduce risks to human health and the environment, with a strong focus on limiting the use of hazardous substances.
Regarding substances of concern, the regulation sets strict thresholds for certain heavy metals present in batteries:
- Mercury (Hg): maximum 0.0005% by weight
- Cadmium (Cd): maximum 0.002% by weight
- Lead (Pb): in portable batteries, limited to 0.01% by weight from 18 August 2024
Furthermore, by 2027, the European Commission will present a report to the European Parliament and the Council assessing whether these restrictions should be extended to other substances that pose health risks or hinder safe recycling and the production of high-quality secondary raw materials.
Extended Producer Responsibility (EPR)
From 18 August 2025, all EU Member States will require manufacturers to register under the Extended Producer Responsibility (EPR) system for batteries, including those integrated into electronic devices. Under the EPR scheme, manufacturers are legally obliged to finance and manage the collection, treatment, and recycling of batteries they place on the EU market. In France, a decree has been published regarding the sanctions applied if they fail to comply with the EPR requirements.
Our support
WeLOOP benefits from technical expertise in battery production and recycling processes, whether conventional or innovative. Through numerous projects, we have established strong ties with industrial, academic, and scientific partners. This collaboration has enabled us to become a national and European reference in life cycle assessment (LCA) for the battery sector.
WeLOOP supports stakeholders in the sector to ensure their products comply with these new obligations:
- Réalisation d’études d’Analyse du Cycle de Vie de produits et procédés
- Criticality assessment
- On-demand sale of life cycle inventories (LCI) dedicated to the recycling processes of electric vehicle batteries to calculate the carbon footprint of batteries in compliance with regulations
- Development of Life Cycle Inventories (LCI)
- Support for eco-design and innovation
In this dynamic context, WeLOOP is also leading, together with Ailoop, the BATTERS project, which aims to continue structuring and energising the battery sector in Hauts-de-France, addressing environmental, economic, and societal challenges as well as those related to the criticality of raw materials.