The new EU battery regulation ((EU) 2023/1542)

The new EU battery regulation ((EU) 2023/1542)

Bykarl

I. The legislative core of the new EU battery regulation: building the world’s most stringent battery regulatory framework

On August 18, 2025, the new EU Battery Regulation (EU) 2023/1542 came into full effect, officially replacing the 2006/66/EC Battery Directive, becoming the first mandatory regulation covering the full life cycle of batteries.135 Its three strategic objectives are:

1.Carbon emission reduction: require full life cycle carbon footprint declaration and hierarchical labeling for power batteries 

2.Circular economy: set the proportion of key metal recycled materials (lithium ≥ 12% and cobalt ≥ 26% by 2031) 

3.Extended Producer Responsibility: strengthen producer’s EPR (Extended Producer Responsibility) responsibility for recycling

Key timeline:

  • 2025.8.18: EPR registration mandatory, non-compliant products banned from sale in the EU 
  • 2027.2.18: Digital passport for EV batteries comes into force 
  • 2027.8.18: Raw material due diligence obligation kicks in (two-year extension)

II. Technical Compliance Matrix: Differentiated Requirements for Five Types of Batteries

▶ Battery Classification and Core Obligations

Battery typedefinitionKey compliance requirements
portable battery≤5kg sealed (mobile phone/tool battery)User-removable design (mandatory in 2027), restrictions on hazardous substances（Hg≤5ppm, Cd≤20ppm）
LMT battery≤25kg（Electric scooter/bicycle）Digital passport, carbon footprint statement (＞2kWh), recycled cobalt ≥16%
SLI batteryVehicle start-stop power supplyLead content ≤ 100 ppm, leak-proof design
electric vehicle battery＞25kg（power battery）Carbon footprint threshold (2028), third-party certification, recycled lithium ≥ 6%
industrial batteryStationary energy storage/backup power supplyDue diligence policy, cycle life ≥ 5000 times

▶ Three stages of carbon footprint management

  • Declaration phase (from 2025): disclosure of full life-cycle CO₂ emissions (from mining to assembly) 
  • Graduated labeling (from 2026): graded A-G according to carbon intensity, with a ban on sales below grade D 
  • Threshold limit (from 2028): power battery carbon intensity ≤ 60kg CO₂/kWh6
What are the EU battery regulations

III. EPR registration: the cornerstone of EU market access

From August 18, 2025, all EU battery sellers must complete:

1. Producer identification: 

  • Non-EU companies need to designate EU Authorized Representative (EU REP) 
  • Cross-border e-commerce sellers need to register EPR in the country of sale (e.g., Germany, Poland, France and other 9 countries)

2. BDO system registration: 

  • Poland and other member states require synchronized registration of battery law + packaging law 
  • Get a unique EPR registration number and upload it to Amazon/Temu and other platforms.

3. Payment of recycling fee: 

  • Eco-disposal fee per battery weight/type (e.g. industrial batteries: €2.5/kg).

Consequences of non-compliance:

  • Mandatory removal of goods from shelves (real-time monitoring by cross-border e-commerce platforms) 
  • Fines of up to €100,000 (Germany) or PLN 1 million (Poland) 
  • Supply chain disruption (Customs seizure of unregistered products)

IV.Technical Barriers: A Path for Chinese Enterprises to Attack

1. Carbon footprint optimization

  • Green Power Transformation: EU thermal power accounted for <20%, China >50% → need to purchase green power certification 
  • Material Innovation: Silicon carbon anode replaces graphite, reducing carbon emissions from roasting process by 40%.

2. Recycling technology breakthrough

  • Directional recycling process: 
    • Wet metallurgy lithium purity ≥99.9% (patented by Ningde Times) 
    • Recycled cobalt and nickel are directly supplied to anode materials, meeting the requirement of ≥16% recycling ratio.

3. Digital Passport System

  • Blockchain Traceability: Docking with IBM Food Trust or VeChain platform 
  • Data fields include: 
    • Raw Material Origin (Conflict-Free Mineral Certification) 
    • Carbon Footprint Certificate ID 
    • Recycled Material Proportion Verification Code
What are the EU battery regulations

V. Industry Impact and Strategic Recommendations

1. Rising Compliance Costs

  • Third-party authentication + digital passport added cost $15-20/kWh 
  • SMEs at risk of elimination (exemption threshold: turnover €150 million)

2. Supply Chain Reconfiguration

  • Localized production: Ningde Times Germany plant meets carbon footprint threshold 
  • Closed-loop recycling: Greenmax and ECOPRO build European recycling base (100,000 tons per year)

3. Technology Pre-Research Direction

  • Solid-state battery exemption advantage: sulfide electrolyte without heavy metal restriction 
  • Removable design: 
    • Snap-on battery compartment (glue bonding prohibited) 
    • Standardized tool removal (torque ≤ 0.5Nm)

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