The European Union’s Regulation (EU) 2023/1542 on batteries and waste batteries, which entered into force on 17 August 2023, introduces a comprehensive and binding legal framework to govern the entire life cycle of batteriesacross all EU Member States. While many provisions have already begun to apply, several critical Extended Producer Responsibility (EPR) and labelling obligations will become enforceable starting 18 August 2025. This marks a major turning point in the EU's commitment to sustainability, circular economy, and environmental protection.

1. Overview of the Regulation

Replacing Directive 2006/66/EC, the new regulation applies directly across the EU and covers all battery types, including:

• Portable batteries

• SLI batteries (Starting, Lighting, Ignition)

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

• Industrial batteries

• Electric Vehicle (EV) batteries

The regulation aims to ensure that all batteries placed on the EU market are safe, sustainable, durable, and circular.

2. Enforcement Starting August 2025: Key EPR Obligations

The Extended Producer Responsibility (EPR) obligations that become legally enforceable from 18 August 2025 include:

• Producer registration in each EU Member State where batteries are placed on the market.

• Financial responsibility for the collection, treatment, and recycling of waste batteries.

• Labelling requirements including:

- A crossed-out wheeled bin symbol on all batteries.

- An indication of battery chemistry (e.g., “Li” for lithium).

- A QR code for digital product information.

• Separate collection symbol to support proper disposal by end-users.

These requirements are intended to increase collection rates, reduce environmental harm, and improve transparency for consumers and recyclers.

3. Other Major Requirements and Timelines

a) Carbon Footprint and Recycled Content

• From 2025, manufacturers must disclose the carbon footprint of EV, industrial, and LMT batteries.

• From 2031, minimum levels of recycled content will apply:

- 16% cobalt

- 6% lithium and nickel

- 85% lead

b) Battery Passport

By 2027, a digital battery passport will be mandatory for:

• EV batteries

• Industrial batteries >2 kWh

• LMT batteries

This passport must include information on battery performance, composition, and sourcing, and will be accessible via QR code.

c) Replaceability and Safety

• From 2027, portable batteries must be designed for easy replacement by end-users.

• LMT batteries must be replaceable by professionals.

4. Waste and Recycling Measures

To support circularity and reduce dependency on virgin raw materials, the regulation introduces:

• Minimum recycling efficiency rates for key materials like cobalt, lithium, nickel, copper, and lead.

• Updated EU Waste Codes, including new categories such as "black mass" from shredded batteries.

• From March 2025, restrictions on the export of hazardous battery waste to non-OECD countries will apply.

5. Strategic Impact for Stakeholders

Manufacturers, importers, and distributors must prepare for the following:

• National producer registration in each EU country of operation

• Implementation of compliant labelling systems

• Due diligence policies for raw material sourcing

• Internal systems to ensure take-back and recycling targets are met

Failure to comply with these obligations after 18 August 2025 may result in penalties, market access limitations, or enforcement actions by national authorities.

6. Conclusion

The EU Batteries Regulation (EU 2023/1542) reflects the Union’s commitment to environmental sustainability, circularity, and strategic autonomy in battery value chains. With critical Extended Producer Responsibility (EPR) and labelling provisions becoming enforceable in August 2025, stakeholders must act now to align their operations with the regulation's requirements.

Bay Area Compliance Laboratories Corp (BACL) can support your organization in navigating these changes by providing technical guidance and assistance with EPR registration, labelling compliance, and regulatory reportingacross the EU. Our team is equipped to help you ensure timely and effective compliance with the evolving battery legislation.

Source:

https://environment.ec.europa.eu/topics/waste-and-recycling/batteries_en

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