From production to recycling: a comprehensive guide to the new European Battery Regulation 2023/1542
14 May 2025
In line with the objectives of the European Green Deal, the EU is adopting increasingly stringent measures to ensure that the entire life cycle of batteries – from production to recycling – is sustainable, efficient and compliant with the most advanced environmental standards. Batteries play a crucial role in enabling the energy transition by reducing dependence on fossil fuels, promoting electric mobility and supporting the storage of energy from renewable sources.
To address these challenges in a systematic and effective way, it has become necessary to implement stringent regulations applicable to all economic operators in the European Union, with no differences in national implementation. To ensure a uniform and binding application of the new rules, the previous Directive 2006/66/EC was replaced with an actual regulation: European Regulation 2023/1542.
The new European Battery Regulation
Who the EU Battery Regulation applies to: categories and obligations
Regulation (EU) 2023/1542 applies to all new batteries placed on the market or put into service within the European Union from the date the Regulation entered into force, regardless of their origin or place of production. The only exceptions are batteries specifically designed for military or aerospace uses.
The regulation covers all types of batteries, whether sold as individual units or incorporated into devices or vehicles. Specifically, the document provides a classification defining five distinct categories:
- Portable batteries (under 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 e-bikes, electric scooters, hoverboards
- Electric vehicle (EV) batteries
- Industrial batteries – used in industrial settings or large plants
The regulation involves all economic operators in the supply chain: manufacturers, importers, distributors and retailers. Each will have specific responsibilities depending on their role, from the design phase to end-of-life management.
One of the most innovative aspects introduced by European Regulation 2023/1542 concerns the environmental requirements applied to battery production. The objective is clear: to reduce the environmental impact of batteries throughout their entire life cycle by promoting more responsible design and efficient resource management. This approach is based on two key pillars: the carbon footprint and the minimum content of recycled materials.
Declaration of batteries’ carbon footprint
The regulation requires manufacturers to calculate and declare the carbon footprint generated during the entire battery production process. This is a fundamental measure to encourage the reduction of greenhouse gas emissions throughout the entire value chain.
The measure will come into force gradually:
- From 18 February 2025 or 12 months after the entry into force of the delegated/implementing act for electric vehicle (EV) batteries
- From 18 February 2026 or 18 months after the entry into force of the delegated/implementing act for industrial rechargeable batteries with a capacity greater than 2 kWh
- From 18 August 2028 or 18 months after the entry into force of the delegated/implementing act for light means of transport (LMT) batteries, such as bicycles and electric scooters
- From 18 August 2030 or 18 months after the entry into force of the delegated/implementing act for stationary energy storage systems (with a capacity greater than 2 kWh)
The applicability of the obligation depends on the publication of the delegated act on the methodology for calculating and verifying the carbon footprint and the implementing act setting out the format of the declaration, both adopted by the European Commission. Without such acts the dates will be deferred.
Until the carbon footprint information is accessible via QR code (18 February 2027), the declaration must accompany the battery.
Minimum recycled material content required
From 18 August 2028 certain types of batteries must include a minimum percentage of recycled materials in the finished product. This measure applies to:
- Industrial rechargeable batteries with a capacity greater than 2 kWh
- Electric vehicle (EV) batteries
- SLI batteries (used for starting, lighting and ignition of vehicles)
The materials involved are cobalt, lead, lithium and nickel. Manufacturers must provide specific documentation attesting to the actual percentages of recycled materials present, whether derived from recycled inputs, manufacturing waste or post-consumer waste.
Performance and design: durability and disassembly of batteries
These requirements must be accompanied by increasing attention to battery durability and ease of disassembly. The aim is twofold: on the one hand to extend battery lifespan and reduce the need for frequent replacements, on the other to facilitate maintenance, reuse and recycling, in keeping with circular economy principles.
Starting from 18 August 2027, industrial rechargeable batteries must meet specific performance and durability requirements to ensure consistent efficiency over time. One year later, from 18 August 2028, portable batteries (excluding button cells) must also meet these minimum durability standards.
Regarding disassembly, the regulation stipulates that, from 18 February 2027:
- Portable batteries must be easily removable and replaceable by end users. Products containing them must come with clear instructions and safety information.
- Batteries for LMT, EVs and industrial use must be easily removable and replaceable by qualified professionals at any time during the product’s lifespan.
To ensure greater transparency and traceability throughout the entire life cycle of batteries, the new Regulation introduces strict labelling and marking requirements. All batteries placed on the market must bear clear, legible and easily accessible information to allow consumers, operators and competent authorities to be aware of and informed about proper use, end-of-life management and product traceability.
Already from 18 August 2024, all manufacturers are required to affix the CE marking on batteries, certifying compliance with EU safety, health and environmental protection requirements.
But that’s not all. By 2026 batteries must be accompanied by readable, visible labels, not only on the battery itself but also on the entire device they are used in. These labels must include essential information such as capacity, expected lifespan, performance, chemical composition and proper disposal methods. Starting in 2027 much of this information must also be accessible in digital format via QR code to ensure more complete, up-to-date communication that can be easily consulted by users and industry professionals.
Regulation (EU) 2023/1542 introduces important social responsibility obligations for battery manufacturers and economic operators involved along the supply chain. The aim is to ensure that critical raw materials such as cobalt, lithium, nickel and graphite are extracted and traded in compliance with human rights and international environmental and social standards.
From 18 August 2025, all manufacturers and organisations responsible for battery collection and management (PRO – Producer Responsibility Organizations) will be required to:
- Adopt and publicly communicate a clear due diligence policy consistent with major international standards such as the OECD Guidelines and the UN Guiding Principles on Business and Human Rights.
- Implement an internal management system to support due diligence, identifying and assessing environmental and social risks in their supply chains.
- Develop targeted strategies to prevent, mitigate or address identified risks.
- Undergo an independent audit by a notified body to certify compliance.
Recycling targets: minimum efficiency and recovery of critical materials
The Regulation also introduces minimum targets for recycling efficiency and the recovery of the most critical materials. These requirements will come into force from 31 December 2027 and will apply to authorised treatment and recycling facilities. The minimum recycling efficiency will be:
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- At least 90% for cobalt, copper, nickel and lead
- At least 50% for lithium
The recovered materials must then be reused with priority in the production of new industrial, electric vehicle and SLI batteries. These targets are an integral part of the strategy to promote a circular economy and reduce the European Union’s dependence on virgin raw materials, often extracted in socially and environmentally critical regions.
