EU Battery Regulation compliance is now mandatory

Regulation (EU) 2023/1542 is already in force and its obligations apply in phases.

We help you understand what applies to you, close compliance gaps and demonstrate conformity on time.

Talk to our EUBR experts
Solar Panels

    Applies from

    Phased: passport 2027, due diligence 2027, targets to 2036

    • 18 February 2024

    Who it affects

    Makers, imports, distributes, repairs or recycles batteries

    • The whole value chain

    Scope

    Portable, SLI, LMT, EV and industrial, including built-in

    • All batteries

    Penalties

    In Spain, up to €3.5M under the waste law

    • Set by each EU country

    What is the EU Battery Regulation?

    It is Regulation (EU) 2023/1542, known internationally as the Battery Regulation, which governs all batteries placed on the market in the European Union, from a household cell to an electric-vehicle battery.

    It replaces the old 2006 Directive and goes much further: it requires calculating and declaring each battery’s carbon footprint, introduces the digital battery passport and requires proof of the materials it is made of. It covers the entire life cycle, from raw-material extraction to second-life uses, recycling or final disposal.

    As a regulation and not a directive, it applies directly and is mandatory in every EU country from 2024, with phased implementation requirements.

    mine
    Sustainability
    Lower environmental impact and maximum resource recovery across the battery’s entire life.
    Security of supply
    Greater European autonomy in critical raw materials: lithium, cobalt, nickel and graphite.
    Transparency
    Visibility over origin, composition, carbon footprint and recycled content.

    Who does the Battery Regulation affect?

    If your company manufactures, distributes, repairs, remanufactures, recycles or uses batteries, the regulation affects you. The specific obligations depend on the battery type and your role in the value chain.

    Want to know how it affects your organisation?

    Produces or places the battery on the EU market for the first time.

    Makes batteries available and verifies their conformity before selling them.

    Repairs batteries to restore them to their original function and use.

    Reconditions or repurposes batteries to give them a second life.

    Manages treatment and material recovery at the end of the battery’s life.

    Companies and consumers that purchase and use the batteries.

    Financial penalties and withdrawal from the market, plus reputational damage with clients, partners and financiers.

    The six pillars of compliance

    Requirements are triggered by battery type and operator role. These are the six fronts you need to prepare in advance.

    A unique digital identity for each battery, accessible via QR code, bringing together its key information: material composition and origin, carbon footprint, recycled content, performance and end-of-life data.

    Calculation and declaration per battery model and manufacturing plant, across its life cycle.

    A process to identify, prevent and mitigate the social and environmental risks in sourcing critical raw materials (cobalt, graphite, lithium and nickel).

    Declare and, later, meet minimum thresholds of cobalt, lead, lithium and nickel.

    Conformity assessment, labelling, safety, performance and user removability.

    Registration, collection, recycling and financing of battery management at end of life.

    Key dates of the Battery Regulation

    A phased application calendar, with requirements entering progressively.

    Feb 2024
    Entry into force
    General application
    Aug 2024
    Substance restrictions
    and market surveillance
    Aug 202
    Extended producer responsibility
    2025 | 2030
    Carbon footprint
    Phased declaration
    Aug 2026
    Labelling
    and due diligence guidelines
    Feb 2027
    Digital Passport
    Removability and replaceability (critical date)
    Aug 2027
    Due diligence system (critical date)
    Feb 2028
    Recycled content reporting
    Aug 2028
    First due diligence report
    Jun 2031
    Regulation review by the EC
    Recycled % targets

    Which batteries it covers

    The regulation defines five battery categories. The specific obligations that apply to you depend on which one yours is.

    Portable

    Household devices and cells

    SLI

    Vehicle starting, lighting and ignition.

    LMT

    Light means of transport.

    EV

    Electric vehicle.

    Industrial

    Industrial use and BESS (stationary storage).

    How can Peterson Solutions help?

    We support you, step by step, to build a practical, traceable compliance system, backed by our experts and our technology.

    Talk to an expert

    Diagnosis

    We assess your exposure, your products and the gaps against the regulation.

    Design

    We define your tailored compliance plan, with the obligations that apply to you.

    Implementation

    We roll out the system and train your teams, side by side.

    Ongoing support

    Continuous follow-up as each new delegated act and deadline arrives.

    Where can we start?

    Book a no-obligation meeting

    Adapt and adjust your organisation’s internal procedures.

    Training and learning materials for your team.

    Battery profiles: volumes, suppliers, technology and countries of origin.

    Verification of collected data, non-compliance risk and mitigation strategies.

    Carbon footprint calculation and life-cycle assessment of the batteries.

    Guidance through the process and assurance of compliance.

    Development of a data-control and traceability platform.

    Real supply-chain experience. Results that matter.

    We combine up-to-date regulatory knowledge, on-the-ground operational experience and proprietary technology to turn the complexity of the Battery Regulation into a manageable process.

    • 100+ · Years in supply chains — A group with global presence in inspection, verification and commodity traceability.
    • EUBR · Dedicated team — Specialists continuously tracking the regulation and its delegated acts.
    • PTech · Integrated technology — Proprietary platform for data, traceability and audit-ready documentation.
    • Local · Trusted presence — Hands-on, close consultancy, from diagnosis to long-term support.

    Our expert in the EU Battery Regulation

    Rubén Martínez | Project lead · EUBR expert

    Energy Engineer and Environmental Engineer, specialised in sustainable raw-material sourcing, due diligence, strategic supply-chain management and the energy transition.

    He leads the service dedicated to the EU Battery Regulation, continuously monitoring the applicable rules. He collaborates with APPA (the Spanish Renewable Energy Association) to bring regulatory clarity to companies.

    Schedule a meeting
    Rubén Martínez

    FAQS’s

    It is Regulation (EU) 2023/1542, known internationally as the Battery Regulation, the rule that governs all batteries placed on the market in the European Union across their entire life cycle, from raw-material extraction to second-life uses, recycling or final disposal. It replaces the old Directive 2006/66/EC and, being a regulation, applies directly and is mandatory in every Member State without national transposition. It has been in force since 2024, with phased implementation requirements.

    It affects the entire battery value chain in the EU, regardless of where the battery was made: manufacturers, distributors, repairers, remanufacturers, recyclers and end users. The specific obligations depend on the battery type and each company’s role in the supply chain.

    It is an individual digital identity for each battery, accessible via a QR code. It contains the battery’s identification, its material composition, the carbon footprint, the recycled content, performance and durability data, and use and end-of-life instructions. It should not be confused with general labelling, which is static, model-level information and applies to all batteries.

    The regulation has been in force since 2024, but its obligations apply in phases: substance restrictions and market surveillance (2024), extended producer responsibility (2025), labelling and due diligence guidelines (2026), digital passport and due diligence system (2027), recycled content reporting (2028) and the review of the regulation with recycling targets (2031). Some dates depend on the publication of the European Commission’s delegated acts.

    The importer assumes much of the manufacturer’s obligations when the manufacturer is outside the EU. They must verify that the battery has CE marking and the EU declaration of conformity, check the labelling and technical documentation, and ensure the conformity assessment has been carried out. They must also guarantee traceability, keep the records and cooperate with the authorities in the event of any non-conformity before placing the product on the market.

    It is the amount of greenhouse gases emitted over the battery’s life, expressed in kg of CO2 equivalent per kWh of energy delivered and broken down by life-cycle stage. It is calculated per battery model and manufacturing plant. Important: the delegated act setting the official calculation methodology has not yet been published, so the exact date from which it must be declared is still to be confirmed.

    It is a process that requires companies to identify, prevent and mitigate the social and environmental risks linked to sourcing four critical raw materials: cobalt, natural graphite, lithium and nickel. It applies to operators above certain turnover thresholds, and its compliance must be verified by an independent notified body.

    Non-compliance can lead to financial and legal penalties, withdrawal of products from the market and loss of authorisation to trade in the EU, as well as reputational damage with clients, partners and financiers. That is why it pays to act early: map which obligations apply, verify supplier conformity and prepare the documentation with margin before each deadline.