The New EU Battery Regulation

The New EU Battery Regulation Brings Significant Changes for Manufacturers, Sellers, and Consumers Starting in 2026

Since 2024, the European Union’s new Battery Regulation (EU 2023/1542) has been in force, fundamentally changing the rules for the production, sale, use, and recycling of batteries and accumulators.

The regulation applies uniformly across all Member States and affects all stakeholders – manufacturers, importers, sellers, and consumers. The new requirements introduce stricter safety and environmental standards, extended producer responsibility, easier return options for consumers, and technical norms that increase durability and reusability of batteries. The deadlines stretch from 2024 to 2036, making timely preparation essential for all market participants.

The regulation covers batteries and accumulators as standalone products as well as when incorporated into devices or vehicles.

Since producers of electronic devices containing batteries or accumulators must also cover battery management costs, the costs related to extended producer responsibility should be displayed at the point of sale for products containing batteries.
EU Battery Regulation 2024–2036: A Practical Guide for Manufacturers, Importers, Sellers, and Consumers

In July 2023, the European Parliament adopted the new Battery Regulation, covering the entire life cycle of batteries – from raw materials to recycling. The regulation is directly applicable in all Member States and affects all stakeholders – manufacturers, distributors, importers, and consumers. Its purpose is to establish uniform standards, strengthen the circular economy, and reduce the environmental burden caused by batteries.

Objectives of the Battery Regulation: Why was it created?

The regulation arose from the need to comprehensively and sustainably regulate the rapidly growing battery market – from electric vehicles to mobile devices.

Key objectives:

• Uniform safety standards across the EU.
• A functioning market for raw materials returned to circulation.
• Reduction of environmental impacts in battery production, use, and waste management.

The regulation creates a structured, resource-efficient, and safe market – from resource extraction to the end of recycling.

Extended Producer Responsibility: New obligations for manufacturers

Manufacturers’ role no longer ends with the sale of products – they are now responsible for the entire life cycle.

Key obligations:

• Registration in the register of producers of problem products (company data, batteries placed on the market).
• Mandatory membership in a producer responsibility organization (portable batteries and accumulators, LMT, EV, industrial batteries – from 1 January 2026).
• Organizing the collection, handling, and recycling of batteries.
• Conducting information campaigns.
• Ensuring financial guarantees even in cases of business closure or insolvency (Article 58(7)).
• Product labels must include information on recycling and reuse (Articles 74–75).

Consumer obligations and rights

Consumers are no longer passive – they are expected to actively participate in the collection system.

Changes for consumers:

• Separate collection is mandatory to prevent damage and health risks.
• Portable batteries can be returned free of charge to stores, collection points, and recycling centers – purchase of a new product is not required.
• Online shops must provide information on collection points.
• From 18 February 2027, EV, LMT, and large industrial batteries must have an electronic battery passport (QR code) with sustainability and production information.

Consumers are given a clear responsibility: easy and convenient return options and transparent choices.

Sustainability and safety requirements

The regulation introduces technical standards that support both consumer rights and environmental safety.

Key requirements:

• Carbon footprint (QR code, local language): EV batteries from 18.02.2025, industrial batteries from 18.02.2026, LMT batteries from 18.02.2028, ESS batteries from 18.02.2030.
• Recycled material content: Documentation from 2028; minimums by 2031 (Co 16%, Pb 85%, Li 6%, Ni 6%) and 2036 (Co 26%, Pb 85%, Li 12%, Ni 15%).
• Performance and durability: Portable batteries (excluding button cells) from 18.08.2028; potential ban on non-rechargeable batteries by 2030. Industrial, EV, and LMT batteries >2 kWh require documentation from 18.08.2024 (nominal capacity, power, internal resistance, lifetime).
• Removability: Portable and LMT batteries must be easily removable by the user from 18.08.2027 (exceptions, e.g., waterproofing).
• ESS safety requirements: From 18.08.2024, documentation required on risks, tests, and instructions; safety declared by manufacturer, sustainability confirmed by an independent certifier.

Battery classification: clarity in categories

The regulation establishes clear categories to determine which requirements apply to which batteries.

New categories:

• Portable batteries and accumulators (≤5 kg, excl. EV/LMT/industrial) – e.g., AA, AAA.
• Vehicle batteries – lead-acid for starting, lighting.
• Industrial batteries (>5 kg; e.g., ESS, forklifts).
• Light means of transport (LMT) batteries (≤25 kg; e-bikes, scooters).
• Electric vehicle (EV) batteries (>25 kg; M/N/O category vehicles).

Conformity assessment, CE marking, and the role of importers

Environmental and safety compliance cannot be verified retroactively – the entire process must be documented in advance.

Requirements:

• CE marking mandatory for all batteries from 18.08.2024 — labels must include manufacturer information, pictograms, safety symbols.
• All batteries placed on the market must undergo conformity assessment: electrochemical and sustainability parameters, battery condition and lifetime, CO₂ emissions, share of recycled materials.
• Importers/distributors must check declarations of conformity (Annex VIII), technical documentation, instructions, and CE marking; importing non-compliant batteries is prohibited; they are also responsible for proper storage and transport.

Due diligence and supply chain transparency

From 18.08.2025 (excluding SMEs < €40M), manufacturers must implement:

• A management system (regulatory compliance, risk management, reporting).
• A risk management plan (risk identification, monitoring, auditing).
• Public disclosure on due diligence compliance — Article 52; public report (Art 45(5) + 10-year documentation).

Transparency builds trust and ensures a more ethical and environmentally friendly value chain.

Deadlines — plan necessary changes in time

Key dates:

• 18.02.2024 – Regulation enters into force.
• 18.08.2024 – CE marking, conformity assessment, due diligence.
• 18.08.2025 – New waste management requirements.
• 18.02.2027 – Battery passport and removability requirements.
• 18.08.2028 – Updated performance and CO₂ declaration requirements.
• 2031 & 2036 – New minimum recycled material obligations.

Reuse and second life of batteries

Extending battery life is crucial for resource conservation.

Updated requirements:

• Manufacturers must provide access to BMS data (State of Health).
• Handlers must follow testing, packaging, and transport standards.
• Batteries returned to circulation must comply with standards.
• Batteries placed on the market before new performance and CO₂ rules do not fall under retroactive requirements.
• Reused batteries are treated as new products and subject to EPR obligations.

Recycling targets and minimum levels

Targets:

• By 2031: recovery of Co/Cu/Pb/Ni ≥ 95%, Li ≥ 80%.
• By 2027: earlier targets – Co/Cu/Pb/Ni ≥ 90%, Li ≥ 50%.

Recycling rates (average weight percentage):

• By 31.12.2025: lead 75%, lithium 65%, Ni-Cd 80%, others 50%.
• By 31.12.2030: lead 80%, lithium 70%.

Processing outside the EU requires proof of compliance by the exporter, supported by documentation from a competent authority.

Conclusion

The EU’s new Battery Regulation (EU 2023/1542) is a comprehensive legal framework regulating the entire life cycle of batteries – from raw material extraction and production to collection, recycling, and reuse. Effective since 2024 in all Member States, including Estonia, it impacts all stakeholders: manufacturers, importers, sellers, and consumers.

Key objectives:

• Establish uniform safety and environmental standards across the EU.
• Support the circular economy by returning valuable materials to production.
• Reduce the environmental footprint of batteries during production, use, and disposal.

Manufacturers’ obligations:

• Extended responsibility covering the entire battery life cycle, including registration, membership in producer responsibility organizations, collection and recycling systems, financial guarantees, and proper labeling.

Consumers’ role:

• Separate collection and free return of batteries, obligation-free drop-off in stores, collection points, and recycling centers.
• Electronic battery passport (QR code) for large batteries from 2027.

Sustainability and technical standards:

• Carbon footprint requirements, recycled material minimums, performance and durability standards, removability, and ESS safety rules — phased in until 2036.

Battery categories:

• Five defined categories ensure tailored requirements: portable, vehicle, industrial, LMT, and EV batteries.

Conformity and CE marking:

• All batteries must pass conformity assessment and bear the CE mark. Importers/distributors are responsible for ensuring compliance.

Due diligence and transparency:

• Large manufacturers must establish risk management and reporting systems from 2025.

Deadlines:

• Implementation phased from 2024 through 2036 — early planning is essential.

Reuse and recycling:

• Reused batteries treated as new, EPR applies. Specific recycling targets (e.g., lithium 70% by 2030).

The new EU Battery Regulation is a far-reaching reform that raises environmental and safety standards across the entire battery value chain. Market participants who prepare early, invest in circular solutions, and ensure transparency and accountability will be best positioned to succeed.

Related materials:

Regulation (EU) 2023/1542 of the European Parliament and of the Council.

Ministry of Climate: In July 2023, the European Parliament adopted the regulation covering the entire life cycle of batteries from raw material extraction to recycling.

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Avoid sanctions and support sustainability by ensuring your business complies with these important obligations. If you have questions or require assistance, feel free to contact:

Kaur Kuurme
Managing Director, Eesti Elektroonikaromu
📞 +372 56 236 697
📧 info@elektroonikaromu.ee
info@elektroonikaromu.ee

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Frequently Asked Questions about the New European Union Battery Regulation