The New EU Battery Regulation: What Every Brand Needs to Know

This guide breaks it down in plain English: what the rules say, why they matter, and what your business should do now.

Why this regulation matters

The EU Battery Regulation (2023/1542) officially came into force in August 2023. Unlike the old 2006 Battery Directive, which each country could interpret differently, this one applies uniformly across all EU member states.

The aim? Regulate the entire life cycle of batteries, from mining raw materials to end-of-life recycling. It’s about cutting toxins, improving safety, making batteries easier to replace, and pushing manufacturers toward greener supply chains.

For brands, this isn’t optional. From 2024 onwards, batteries without the CE mark can’t be sold in Europe. By 2025, companies must prove their sourcing is ethical. By 2027, major new requirements like the digital battery passport will kick in.

The EU is raising the bar, and if you don’t meet it, your products won’t make it to market.

Who’s covered?

Anyone selling batteries or products with batteries in the EU.

The law covers all five categories of batteries:

• Portable batteries (≤5 kg, e.g., phones, laptops, power tools)

• Light Means of Transport (LMT) batteries (≤25 kg, e.g., e-bikes, e-scooters)

• SLI batteries (starter, lighting, ignition car batteries)

• Industrial batteries (>5 kg not covered elsewhere, e.g., forklifts, energy storage)

• EV batteries (traction batteries in cars, trucks, buses)

Even if you don’t make batteries, if your product uses them, you’re in scope.

The key dates you can’t miss

Here’s the quick timeline of what’s coming:

Aug 2024: CE marking required on all batteries. No CE mark, no sales.

Aug 2025: Old Directive repealed. Mandatory supply chain due diligence begins (for lithium, cobalt, nickel, graphite). Producer responsibility rules updated.

Aug 2026: New labels: capacity, chemistry, and hazard info required. Disclosure of certain substances above 0.1%.

Feb 2027: Battery Passport for EV, LMT, and industrial >2kWh. Portable batteries must be user-replaceable; LMT/EV batteries must be replaceable by professionals.

Dec 2027: Higher recycling targets for lithium, cobalt, nickel, and lead.

Aug 2028: Performance & durability standards apply. Minimum recycled content starts for big batteries.

2030+: Stricter recycled content levels and recycling rates. Carbon footprint thresholds tighten.

What’s changing—and why it matters

1. Tighter substance restrictions

• Lead, cadmium, and mercury are basically out.

• Lead in portable batteries capped at 0.01% (phased in fully by 2028).

• Starting 2026, any “substance of very high concern” (SVHC) above 0.1% must be labelled.

What this means for you: Audit your suppliers now. Ask for material declarations. If they can’t prove compliance, you need new sources.

2. CE marking on every battery

From August 2024, every battery sold in the EU must carry the CE mark.

• Small batteries (portable, industrial <2 kWh) → self-certification.

• Larger/critical batteries (EV, industrial >2 kWh) → notified body may need to verify.

Why it matters: Without CE marking, your products can be blocked at customs.

3. The Digital Battery Passport

Starting February 2027, EV, LMT, and industrial >2 kWh batteries need a digital passport.

It’s a QR code linking to details like:

• Manufacturer & model

• Capacity, carbon footprint, recycled content

• Hazardous substances

• Safe removal and disposal instructions

For smaller batteries, QR codes with basic info will also be required.

Why it matters: You’ll need systems to collect and manage this data from suppliers. Start building that database now.

4. Replaceability

• By 2027, portable batteries must be user-removable.

• LMT, EV, and industrial batteries must be replaceable by professionals.

What this means for brands: No more glued-in smartphone batteries. You’ll need to design access points, instructions, and safe replacement methods.

5. Sustainability requirements

The EU wants cleaner, longer-lasting batteries.

• Carbon footprint reporting: EV batteries first (2025/26), then industrial and LMT.

• Recycled content: By 2028, certain batteries must declare recycled cobalt, nickel, lithium, and lead. By 2030, minimum percentages kick in.

• Performance & durability: From 2028, minimum cycle life and retention standards apply.

Why it matters: Your carbon footprint and recycled content will be visible to consumers and regulators. This can hurt—or boost—your brand story.

6. Supply chain due diligence

From August 2025, companies over €40m turnover must audit and report on their sourcing of cobalt, lithium, nickel, and graphite.

That means:

• Policy in place

• Risk assessments done

• Corrective actions if issues found

• Third-party audit and annual report

Exemptions: Smaller companies under €40m turnover are off the hook legally—but customers may still expect proof of ethical sourcing.

7. Producer responsibility

Extended producer responsibility rules tighten in 2025. If you place batteries on the EU market, you’re responsible for:

• Collection systems

• Recycling efficiencies (new higher targets by 2027/30)

• Reporting compliance in each country

Tip: Partner with local take-back and recycling schemes early.

What you should do now

1. Map your products. Which categories do your batteries fall under? Match them to the timeline.

2. Check your supply chain. Request material disclosures and CE plans from suppliers.

3. Plan for data. Set up systems for carbon footprint, recycled content, and passport info.

4. Rethink design. If your product has sealed-in batteries, redesign for replaceability.

5. Start due diligence. If you’re near or above €40m turnover, build your sourcing policy now.

6. Stay informed. Delegated acts and technical standards are still being finalized.

The bigger picture

The EU Battery Regulation is more than compliance, it’s a sign of where the market is headed.

• Transparency: Customers and regulators will see inside your battery’s supply chain.

• Sustainability: Longer life, more recycled content, lower carbon footprint.

• Accountability: Brands are responsible not just for their products, but for how materials are sourced and recycled.

The companies that adapt fastest won’t just avoid fines, they’ll build trust, strengthen their ESG story, and stay ahead of competitors stuck in old ways.

In short: The batteries powering your products just got a lot more regulated. But with the right steps, compliance can become an advantage.

Where to get support?

Navigating the EU Battery Regulation can feel overwhelming, but you don’t have to tackle it alone. At EdgeComply, we help growing consumer brands cut through the complexity, whether it’s clarifying which requirements apply to your products, gathering and validating supplier evidence, or guiding you step by step through implementation. We can even take care of extended producer responsibility (EPR) from start to finish, including registrations and waste submissions.

Book a call with our team today.