The much-anticipated Batteries Regulation was unveiled earlier this summer and took effect on 17 August. The regulation applies to all batteries sold in the EU, regardless of their origin or the materials used, including portable batteries, electric vehicle batteries, and batteries for light means of transport (LMT).

The regulation covers all economic operators involved in placing batteries on the EU market, including manufacturers, importers, and distributors. It applies to all batteries within the EU, regardless of their country of origin or the materials used, encompassing portable batteries, electric vehicle batteries, and LMT batteries.

Raw Materials and Recycling

Recycled Content Targets

• By 2031, 16% of cobalt, 85% of lead, 6% of lithium, and 6% of nickel in batteries must come from recycled sources, either from battery manufacturing waste or post-consumer waste. These targets increase to 26% for cobalt, 12% for lithium, and 15% for nickel by 2036.
• Each battery must specify the percentage of recycled materials it contains.
• For LMT batteries, a collection rate of 45% must be reached by 2028, increasing to 61% by 2031.

Due Diligence Requirements

Economic operators are required to clearly communicate due diligence policies in line with international standards to mitigate social and environmental risks in the sourcing, trading, and production of battery raw materials. This includes materials like cobalt, graphite, lithium, and nickel, following OECD guidelines and the UN Guiding Principles on Business and Human Rights.

End-of-Life Management

• Batteries cannot be disposed of in landfills. Economic operators are responsible for collecting end-of-life batteries from consumers free of charge.

Advanced Materials and Manufacturing

Manufacturing Responsibility and Labelling

• Electric vehicle, LMT, and rechargeable industrial batteries with a capacity greater than 2 kWh must include a carbon footprint declaration and label, indicating the recycled content of cobalt, lead, lithium, and nickel used in production. By 2027, this information must also be accessible via a QR code.
• These batteries will also require a digital battery passport, containing details about the battery model, intended use, and specific information such as capacity, performance, durability, chemistry, and recycling symbols. Further details about the battery passport can be found in a dedicated article.

Safety Requirements

• Restrictions on hazardous substances:
  • Mercury: No more than 0.0005% by weight.
  • Cadmium: No more than 0.002% by weight.
  • Lead: No more than 0.01% by weight in portable batteries by 18 August 2024.
• A report will be submitted to the European Parliament and Council by 2027, with the potential to extend the list of restricted substances to include other materials deemed hazardous to human health or that hinder safe, high-quality battery recycling.

End Uses and Applications

End-User Responsibility

• By 2026, batteries must display the "CE" label, signifying compliance with EU health, safety, and environmental standards. This label must be placed visibly on the overall device, not just the battery, and be available via a QR code by 2027.
• End users must dispose of waste batteries separately from other waste streams.
• LMT batteries must be replaceable by independent professionals, with a 42-month timeframe for product designs to meet this requirement.
• Battery management systems (BMS) must have a software reset function to allow for the installation of a new BMS for reuse or end-of-life purposes, at which point the original manufacturer will no longer be liable for the battery.

Conclusion

The Batteries Regulation sets clear targets for recycled material content and outlines the information that must be made available for batteries sold within the EU. It also provides detailed guidance on due diligence and end-user responsibility throughout the battery lifecycle. Many of the requirements and targets are scheduled for the coming years, giving economic operators time to adapt their operations accordingly. However, some targets remain vague, with the promise of further requirements being introduced through delegated acts. Much will depend on these future developments. BatteryManufacturers is already actively engaged in research and innovation to address these challenges, with several projects focused on battery passports, recycling, life cycle assessments, and BMS functions. BatteryManufacturers will continue to monitor regulatory updates and support the battery R&I needs to meet the objectives of the Batteries Regulation and the European Green Deal.