EU Battery Regulation (EU) 2023/1542

May 22^nd, 2025, Update: EU Battery Regulation Due Diligence Timeline Might Be Extended to 2027

What Does This Mean?

Under the regulation, companies placing EV batteries, industrial batteries over 2 kWh, and LMT (Light Means of Transport) batteries on the EU market must implement a due diligence policy. This includes identifying, preventing, and mitigating environmental and human rights risks in the supply chains of key raw materials like cobalt, lithium, nickel, and natural graphite.

The delay allows companies additional time to:

• Establish and audit supply chain due diligence systems.
• Prepare public reporting and risk management plans.
• Align with evolving technical guidance from the European Commission.

Why the Change?

The Commission extended the deadline to give companies adequate time to build compliant due diligence frameworks, particularly in light of the complexity of mineral supply chains and the coordination needed with other regulations (e.g., Corporate Sustainability Due Diligence Directive – CSDDD).

What’s Next?

• Updated implementing acts and detailed guidance on due diligence processes are expected ahead of the new deadline.
• Companies are encouraged to continue investing in traceability systems, risk assessment tools, and partnerships to meet future requirements efficiently.

Scope and Key Provisions

The European Union’s new Battery Regulation (EU) 2023/1542 is a groundbreaking law replacing the 2006 Battery Directive and introducing a comprehensive framework for sustainable battery life cycle. In force since August 2023, this regulation aligns with the European Green Deal by addressing every stage of a battery’s life – from design and production to usage and recycling – under one unified set of rules. The overarching goal is to ensure batteries placed on the EU market are safer, more circular, and environmentally friendly, supporting Europe’s transition to climate neutrality and resource independence.

Broad Coverage: The regulation applies to virtually all batteries sold in the EU, regardless of origin. It defines five battery categories: portable batteries (small, under 5kg), SLI batteries (starter batteries for vehicles), light means of transport (LMT) batteries (e.g. e-bike and scooter batteries), electric vehicle (EV) batteries, and industrial batteries. Only military and space batteries are exempt. All economic operators – manufacturers, importers, distributors, and recyclers – have new obligations under the law.

Key Sustainability Measures: The regulation introduces many new requirements to improve sustainability and transparency across the battery supply chain. Notable measures include:

• Design and Performance: Limits on hazardous substances (strict caps on mercury, cadmium, lead) and minimum performance & durability standards to prolong battery life. By 2027, portable batteries in devices must be user-removable to extend product lifetime. Large batteries will also need safety and reliability documentation.
• Carbon Footprint & Recycled Content: Manufacturers of EV and industrial batteries must calculate the product’s carbon footprint and disclose it, using a standardized EU methodology. Starting in 2025, batteries will be classified by carbon footprint performance, and by 2027 the EU will set maximum allowable carbon footprint limits to drive down emissions. The regulation further establishes targets to use recycled materials – introducing minimum recycled content quotas for critical metals (like lithium, cobalt, nickel) by 2030, with reporting of recycled content from 2025 onward.
• Labelling and Traceability: Every battery must have a label with key information (capacity, chemistry, safe use symbols, etc.), plus a QR code that links to a digital battery passport. The battery passport is a novel digital record that will contain detailed data on each battery’s composition, origin, carbon footprint, and end-of-life handling, accessible to consumers and professionals via the QR code. This aims to enhance transparency and enable better recycling and reuse decisions.
• End-of-Life & Recycling: Ambitious collection and recycling targets are set to ensure batteries are collected and recycled at high rates. For example, collection rates for portable batteries must rise to 63% by 2027 and 73% by 2030, and for LMT batteries 51% by 2028. Recyclers must achieve high recovery efficiencies (e.g. recovering 90% of cobalt, nickel, copper by 2027) so that valuable materials re-enter the economy. Starting in 2025, new batteries must also come with documentation of how much recycled content they contain (growing into binding targets by 2030).
• Supply Chain Due Diligence: Large battery producers (revenues > €40M) will be required to conduct due diligence on their raw material supply chains by August 2025 (August 2027- Updated 22/05/2025). This means identifying and mitigating social and environmental risks associated with sourcing of cobalt, lithium, nickel, graphite and other key battery materials. Companies must implement risk management plans, undergo third-party audits, and publicly report on their sourcing practices, ensuring batteries are not built on unethical or unsustainable supply chains.

Developments in 2024–2025

The years 2024 and 2025 mark a transition period as the new regulation’s provisions begin to take effect. Member States will fully switch from the old Battery Directive to this regulation by August 18, 2025 (when the directive is formally repealed). In the meantime, significant progress has been made:

• Entry into Force & Guidance: The regulation took effect on 18 February 2024 after a six-month transition. To aid implementation, the European Commission has started issuing guidance documents. Notably, guidelines were published to clarify the rules on removability and replaceability of portable and LMT batteries, helping manufacturers design products compliant with the 2027 user-replaceability mandate. Additional guidance on due diligence obligations is expected by early 2025, ensuring companies understand how to meet the new responsible sourcing requirements.
• Carbon Footprint Rules Rolled Out: The Commission in early 2024 released detailed rules for calculating and reporting the carbon footprint of EV batteries. This delegated regulation established the official methodology (based on the Product Environmental Footprint life-cycle analysis approach) and a standardized format for carbon footprint declarations. By February 18, 2025, all new electric vehicle batteries placed on the EU market must be accompanied by a carbon footprint declaration verified through a conformity assessment. The first wave of these disclosures in 2025 will allow the EU to define performance benchmark classes by 2026 and set maximum carbon limits by 2027 – a dynamic process pushing industry toward lower-carbon batteries. Work on a similar carbon footprint methodology for industrial batteries is underway and due by end of 2024.
• Digital Battery Passport Preparations: Although the battery passport requirement doesn’t take effect until 2027, groundwork is being laid now. An industry consortium (Battery Pass) co-funded by Germany developed a comprehensive standard for battery passport data. In early 2025 they published DIN SPEC 99100, translating the regulation’s passport requirements into a structured list of data fields and implementation guidance. At the same time, global pilot projects have tested the concept: in late 2024 the Global Battery Alliance coordinated real-world pilots where major cell manufacturers and tech providers generated prototype digital passports for EV batteries. These pilots – involving over 80% of global EV battery production capacity – demonstrated how sustainability data (carbon footprint, material sourcing, etc.) can be collected and shared via a passport system. The lessons from these trials are feeding into EU policy. The European Commission is set to issue further regulatory guidance on the battery passport by August 2025, detailing how the passport platform and data access will work in practice.
• Upcoming Deadlines: By August 18, 2025, several other significant provisions kick in. Producers must have their supply chain due diligence programs up and running. That same date, the Battery Directive’s rules sunset, meaning all batteries on the market must fully comply with the new regulation’s requirements going forward. The industry is actively gearing up: many companies are investing in compliance systems, data collection processes, and collaborations to meet the new reporting and sustainability criteria. There is a generally positive outlook that these changes will not only ensure regulatory compliance but also enhance competitiveness by improving battery quality, performance, and public trust in battery technologies.

In summary, Regulation (EU) 2023/1542 represents a major positive leap for the battery industry. By mid-2025, its vision of sustainable, circular and transparent batteries is moving from paper to reality. Companies and regulators are working closely to clarify technical details and meet phased deadlines. The result will be batteries that carry digital passports, carbon ratings, and responsibly sourced materials – innovations that should boost consumer confidence and ecological outcomes. The EU’s battery legislation is poised to set a global example for marrying clean technology with circular economy principles.

Sources Consulted:
European Commission (2023), UL Solutions (2023), Reverse Logistics Group (2024), IBF Solutions (2024), IGARR (2024), VATAi (2025), Flash Battery Tech (2024)