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EU Battery Regulation is coming

Source：pvmagazine

The new EU Battery Regulation will gradually impose expanded and, partly new, requirements on battery manufacturers, importers, distributors, and “service providers.” The legislation applies to all batteries, without exception. Legislative requirements vary according to battery type and differ depending on application, such as electromobility or power storage, mobile phone batteries, or small battery systems.

The regulation includes designation of product carbon footprints, mandatory recycled content, and product digital passports or an extended duty of care for the supply chain. The regulation defines battery service providers as installers, recycling companies, maintenance and repair businesses, testing and certification services, and logistics and disposal companies.

Although different battery types have different standards requirements, all batteries have had to meet European Union Conformite Europeenne (CE) requirements since August 2024. Manufacturers, dealers, and service providers have had to prove that their products meet the requirements of the regulation.

CE conformity
Companies have had to make preparations in advance, adapt their manufacturing processes and quality management systems accordingly, and have had their manufacturing facilities audited or inspected. It is particularly important that the necessary conformity documents are not only provided but also updated in order to avoid legal risks as part of CE assessment. The results of manufacturing inspections and audits are also taken into account. Manufacturing inspections are mandatory in some cases but not in others. The key point is that the manufacturing processes and quality assurance measures are important for the CE process. They do not necessarily help to meet product standards, however. Conversely, compliance with all technical product standards is not necessarily a guarantee of CE conformity.

When manufacturers assess their batteries for compliance with the regulation, under certain circumstances the involvement of a notified body to check the procedure is now mandatory for the first time. The need for involvement only arises for certain types of batteries but increased environmental requirements, such as the CO₂ footprint and the proportion of recycled materials, can also lead to this, as could new regulations such as the digital product passport or extended due diligence obligations in the supply chain.

Digital passport
The regulation requires the battery’s CO₂ footprint to be shown in a digital battery passport and made accessible via a QR code on the device. Many companies are still unclear about what data they need to provide and where they can get it from. Value chains are complex and increasingly globalized. The assessment of CO₂ footprint includes, among other things, the extraction of raw materials, all transport routes during the manufacturing process and also the recycling process expected to be used with the battery at the end of the product life cycle.

Recycled materials
In future, batteries will have to contain a minimum proportion of recycled materials. Specific quotas will apply to batteries in industrial and vehicle applications from 2031: These batteries must consist of at least 16% recycled cobalt and 6% recycled lithium and nickel. These requirements will also gradually apply to photovoltaic energy storage and other stationary batteries, from 2031. There are also requirements for labeling, return, and disposal of equipment. In many cases, companies do not yet have suitable processes for this.

Responsible supply chains
Another point concerns ensuring responsible supply chains for the minerals and rare earths used in batteries. Companies should help to ensure that their extraction does not have a negative impact on human rights, working conditions, or the environment. Implementing and documenting this transparency in practice is a challenge, especially for small- and medium-sized photovoltaic companies.

Quality and safety
In addition to the many new and, above all, sustainability-related requirements, the new battery regulation places great emphasis on the quality, safety, performance, and durability of batteries. Among other things, a quality management system must be established and demonstrated in production for electric vehicle batteries, e-bike devices and systems used for stationary power storage. Batteries are required to meet technical standards more than before.

Companies that manufacture, sell, or install batteries, such as those used to store solar energy, must meet staggered requirements depending on type of battery and application. There is already a need for concrete action. Companies should review their supply chains and document the proportion of recycled materials in their batteries from 2027 onwards. They must also prepare for CO₂ accounting, as disclosure of product carbon footprint will be mandatory from 2026. Installers should ensure that they observe the new labeling and take-back requirements when selecting and installing battery energy storage systems.

The new battery regulation is one of the first product-related regulations at EU level in which the basic intentions of the European Green Deal are implemented. The European Green Deal is a central anchor of European climate policy. It aims to make the European Union climate-neutral by 2050 and to transform the European economy towards sustainability, a circular economy, resource conservation, and greenhouse gas reduction. Further product-related regulations are already on the way.

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