The European Union will impose stricter regulations on batteries in the future—with far-reaching consequences for businesses and consumers.
An invisible problem becomes visible
Batteries are everywhere. Smartphones, laptops, headphones, electric cars. Hardly anyone asks where the raw materials come from, how much CO2 is produced during manufacturing, or what happens to them afterwards. In 2023, the European Union decided to put an end to this ignorance. Regulation (EU) 2023/1542 of July 12, 2023, replaces the old Battery Directive of 2006 with a significantly more ambitious system. I have studied the details of this regulation intensively and have come across a veritable transformation of the European battery industry. It is not just about technical regulations. It is about sustainability, human rights, economic competitiveness, and how we will deal with valuable raw materials in the future.
The background: Why the EU had to act
The old Battery Directive from 2006 was outdated. The industry had changed radically. Lithium-ion batteries for electric vehicles represented a completely new product category. Dependence on raw materials was growing. Lithium, cobalt, and nickel in particular became strategic issues. At the same time, massive human rights problems were revealed in the supply chains, particularly in cobalt mining in the Democratic Republic of Congo. The EU recognized that a mere revision was not enough. A complete reorientation was necessary. The regulation was intended to establish a circular economy, promote European battery production, and raise consumer and human rights standards.
The scope: Who is affected?
The regulation applies to various battery categories with different requirements. There are device batteries for portable devices, car battery packs for electric vehicles, industrial batteries, and specialized batteries for aerospace applications. The regulation is aimed at manufacturers, importers, distributors, and retailers. It is particularly relevant to electronics retailers that sell battery products. This broad scope explains the massive impact. It affects large corporations as well as small and medium-sized enterprises and e-commerce platforms.
The digital battery passport: transparency as standard
One of the most spectacular elements is the digital battery passport. From 2027, this QR code-based product passport will be mandatory for batteries with an energy content of over 2 kWh. It documents the chemical composition, the origin of the raw materials, storage conditions, repair and recycling information, and safety data. The battery passport tracks its entire life cycle. For consumers, this means genuine transparency about the origin of their batteries for the first time. It is possible to trace the conditions under which the raw materials were extracted. This was previously impossible. For manufacturers, however, this poses considerable challenges: complete documentation from raw material extraction to recycling is required.
The carbon footprint: incentives for greener production
Regulation of the carbon footprint is another key element. From 2027, batteries with an energy content of 2 kWh or more will have to declare their carbon footprint. This has already been in place for large industrial batteries (over 7 kWh) since 2023. The calculation follows standardized methodologies. The EU's goal is clear: to create incentives for greener battery production. Batteries with a high carbon footprint will become less competitive, forcing manufacturers to invest in renewable energies. Carbon accounting takes into account the entire product life cycle. This is not easy to calculate. Companies with complex supply chains will have to invest heavily in data collection and life cycle assessment studies.
Recycling and raw materials: From electronic waste to the circular economy
A key concern of the regulation is the establishment of genuine recycling obligations. The old recycling rates from 2006 were too low. Under the new regulation, the requirements will increase gradually. For lithium-ion batteries, a recycling efficiency rate of 65 percent will apply from 2025, rising to 80 percent from 2031. Even more crucial are the minimum requirements for raw material recovery. Increasing recovery rates are planned for lithium, cobalt, and nickel. This is technically and economically challenging. Modern recycling processes must be developed and scaled up. Countries with established recycling structures, such as Germany, could become European pioneers. Other EU countries need massive investments in their infrastructure.
The idea of a European battery value chain is ambitious. Higher recycling rates would mean that raw materials would remain in Europe and be reused in production. In the long term, this could promote European independence from raw material imports from China or Africa. But that is still a long way off. Recycling technology is not yet sufficient everywhere.
The interchangeability requirement: Batteries become repairable again
From 2027, manufacturers of devices such as smartphones, tablets, and laptops will have to design them in such a way that users can replace the batteries themselves. This is a direct response to the frustrations of millions of consumers whose expensive devices have become electronic waste simply because the battery failed. This requirement could fundamentally change device design. Batteries must once again become replaceable components instead of being glued or welded in place. This could initially lead to thicker designs, but it would have a massive positive impact on the lifespan of devices and thus on waste volumes. Apple and other manufacturers who have long argued against repairable designs will have to rethink their approach. The cost of battery replacement could fall. Consumers would regain control over their devices.
Supply chain due diligence: A long overdue standard
The regulation obliges companies to ensure that no serious human rights violations occur in their supply chains. This applies in particular to cobalt, where child labor and hazardous working conditions have been documented. Enforcement will be extremely difficult. Many supply chains are opaque. Companies often do not know exactly where their raw materials come from. The original regulation stipulated that these due diligence obligations should take effect as early as 2025. This led to massive protests from industry. The deadline was postponed to 2027. Nevertheless, the requirement remains ambitious. Activists and NGOs see this as a major step forward. Experts warn of transitional problems. Smaller manufacturers may not be able to restructure their supply chains quickly enough.
The practical challenges for companies
The regulation poses massive challenges for companies. The data collection required for the digital battery passport is monumental. Complete documentation from raw material extraction to recycling is required. Many companies do not have such systems in place. Smaller manufacturers will have to make massive investments in IT infrastructure. Start-ups are facing existential questions. Tracking supply chains is also challenging. Companies with multiple suppliers in particular must review their due diligence obligations. This requires not only technology, but also human resources. Compliance teams must be set up. The technical implementation of interchangeability requirements means design revisions. These are long lead times. The costs of CO2 accounting are considerable. Life cycle assessment studies are expensive. Many medium-sized companies have to hire external service providers.
Enforcement and sanctions: The teeth of the regulation
A regulation is only as effective as its enforcement. National market surveillance authorities are being strengthened. They have the right to test batteries and check compliance. Violations are punishable by fines. In Germany, fines of up to €100,000 per violation are possible. In the case of repeated violations, the fines can be significantly higher. This acts as a deterrent. E-commerce platforms such as Amazon must be careful here. They are jointly responsible for ensuring that the products on their platform comply with the regulation. This leads to increased controls and product blockages.
The economic impact
The economic impact is mixed. There are winners and losers. European recycling companies are benefiting. Their services are in greater demand. New European battery factories are being built with EU funding, for example in Sweden, Germany, and Poland. Companies that invest in compliance systems can leverage a competitive advantage. Technology providers for digital battery tracking are experiencing a boom.
Small and medium-sized enterprises are disproportionately affected. Compliance requirements hit them hard. Some could be forced out of the market. Manufacturers of non-European batteries could also have difficulty proving compliance. This could lead to less competition in the European market, which would harm consumers in the long term. Whether the regulation will lead to higher consumer prices is controversial. In the short term, an increase is likely. In the long term, however, increased battery replacement could lead to lower overall costs because devices last longer.
The transitional arrangements: When does what apply?
Not all requirements will come into effect immediately. The interchangeability requirement for smartphones will not take effect until 2027. The same applies to the CO2 declaration for smaller batteries. This gives companies time to prepare. However, this time is limited. Batteries manufactured before the deadlines may still be sold. This gives companies the opportunity to reduce their inventories.
The international context: Europe going it alone?
Will the EU stand alone with its strict regulation, or will other regions follow suit? So far, there is little indication of this. The US also has battery standards in its Inflation Reduction Act, but they are less stringent. China, the largest battery producer, handles regulation differently. This could put the EU in a position where it sets high standards for its markets, while producers elsewhere have to meet less stringent requirements. In the long term, this could lead to a divergence in standards. That would have advantages and disadvantages. European companies could become more attractive as leaders in quality and sustainability. On the other hand, they could become more expensive and lose global markets to international competitors.
Unanswered questions remain
Several questions remain unanswered. How will the EU actually monitor supply chain due diligence? The requirements are ambitious, and monitoring will be difficult. Will national authorities be able to verify compliance? Will the interchangeability requirement actually lead to longer device lifespans, or will manufacturers find ways around it? What innovations will the CO2 accounting requirement trigger? Could completely new types of batteries with a low carbon footprint emerge? How will small businesses and developing countries implement the standards?
Conclusion: Ambitious, but full of challenges
Regulation (EU) 2023/1542 addresses real problems. The environmental impact of battery production, human rights issues in supply chains, and raw material efficiency are real. It provides incentives for innovation and a circular economy. However, implementation is a massive challenge. The EU is requiring companies to transform their business models in a relatively short period of time. This is difficult for large corporations and threatens the existence of small businesses. It will not happen without friction.
For consumers, this will mean longer device lifecycles. At some point, a smartphone will simply get a new battery instead of ending up in electronic waste. That's a positive development. But prices could rise in the short term. The digital battery passport provides transparency, but also collects more data.
The Battery Regulation is symbolic of the regulatory path the EU wants to take: setting strict standards, forcing innovation through restrictions, and enforcing sustainability through binding legislation rather than voluntary measures. Whether this path will lead to success remains to be seen in the coming years.
Primary sources and official documents
- Wikipedia – Regulation (EU) 2023/1542 on batteries and spent batteries
https://de.wikipedia.org/wiki/Verordnung_ (EU)_2023/1542_on_batteries_and_batteries_for_recycling - Federal Ministry for the Environment (BMUV) – Transitional provisions in conjunction with the EU Battery Regulation and the Battery Act
https://www.bundesumweltministerium.de/presse/fragen-und-antworten-faq/uebergangsregelungen-im-zusammenspiel-von-eu-battvo-verordnung-eu-2023/1542-und-batteriegesetz - Bavarian Environmental Pact – Regulation (EU) 2023/1542 on batteries and spent batteries
https://www.umweltpakt.bayern.de/abfall/recht/eu/481/verordnung-eu-20231542-ueber-batterien-altbatterien - European Commission – Circular economy: Rules for more sustainable and safer batteries come into force
https://germany.representation.ec.europa.eu/news/kreislaufwirtschaft-regeln-fur-nachhaltigere-und-sicherere-batterien-treten-kraft-2023-08-17_de - German Bundestag – Retention obligation under the EU Battery Regulation (Scientific Services)
https://www.bundestag.de/resource/blob/1014790/WD-5-079-24-pdf.pdf
Specialist sources and industry analyses
- Jauch Quartz – The new European Battery Regulation EU 2023/1542: What you need to know
https://www.jauch.com/blog/die-neue-europaeische-batterieverordnung-eu-2023-1542-was-sie-wissen-muessen/ - FlashBattery – EU Battery Regulation 2023/1542: Obligations and news
https://www.flashbattery.tech/de/blog/EU-Batterieverordnung-Pflichten-Neuigkeiten/ - German recycling – EU Battery Regulation: Prepare for changes now!
https://deutsche-recycling.de/blog/eu-batterieverordnung/ - IHK Product Development – Guide to the new EU Battery Regulation and digital battery passport
https://www.produktentwicklung.ihk.de/produktmarken/ce-kennzeichnung/neue-batterieverordnung-6778722 - iPoint Systems – EU Battery Regulation: Implications for businesses
https://go.ipoint-systems.com/de/blog/eu-batterieverordnung - ProductionNRW – Impact of the Battery Regulation on mechanical and plant engineering
https://produktionnrw.org/auswirkungen-der-batterieverordnung-auf-den-maschinen-und-anlagenbau/ - KIWA – Detailed impact of the new EU Battery Regulation on businesses
https://www.kiwa.com/de/de/serviceart/zertifizieren/auswirkungen-der-neuen-eu-batterieverordnung-auf-unternehmen-im-detail/
Carbon footprint and sustainability
- EURA AG – EU Battery Regulation: Guide to calculating the carbon footprint
https://www.eura-ag.com/blog/eu-batterieverordnung-leitfaden-zur-berechnung-des-co2-fussabdrucks - DEKRA – Review of the carbon footprint for the EU Battery Regulation (EU 2023/1542)
https://www.dekra.de/de/ueberpruefung-des-co2-fussabdrucks-fuer-die-eu-batterieverordnung-eu-2023-1542/ - EUWID Recycling – New EU requirements for calculating battery recycling quotas
https://www.euwid-recycling.de/news/politik/neue-eu-vorgaben-zur-berechnung-von-quoten-fuer-das-batterierecycling-150725/ - PEM RWTH Aachen University – The European Battery Regulation
https://www.pem.rwth-aachen.de/global/show_document.asp?id=aaaaaaaacoaunod
Digital battery passport and technology
- DIN – Clear the way for the battery passport
https://www.din.de/de/din-und-seine-partner/presse/mitteilungen/weg-frei-fuer-den-batteriepass-1197450 - merchant association – Digital battery passport – Changes under the EU Battery Regulation
https://www.haendlerbund.de/de/ratgeber/recht/digitaler-batteriepass - Fraunhofer IESE – Battery passport & carbon footprint: Implementation with Asset Administration Shell
https://www.iese.fraunhofer.de/blog/batteriepass-umsetzung-mit-asset-administration-shell/ - JH Professional Shop – Battery passport: Everything you need to know about the digital product passport
https://www.jh-profishop.de/profi-guide/batteriepass/ - JH Professional Shop – Battery Regulation: New developments, rules, and obligations
https://www.jh-profishop.de/profi-guide/batterieverordnung/
Supply chain due diligence and human rights
- PowerShift – For consistent protection of human rights and the environment – Further strengthening the Battery Directive
https://power-shift.de/eu_batterie_positionspapier/ - AK Raw Materials – For consistent protection of human rights and the environment (position paper on battery regulations)
https://ak-rohstoffe.de/wp-content/uploads/2021/10/Positionspapier-BatterienVO-1.pdf
Compliance, sanctions, and practical implementation
- gross vehicle weight – Product law: The EU Battery Regulation – a challenge for companies
https://www.fgvw.de/neues/archiv-2024/produktrecht-die-eu-batterieverordnung-eine-herausforderung-fuer-unternehmen - my-compliance.com – What does EU Regulation 2023/1542 on batteries regulate?
https://www.my-compliance.de/faq/eu-verordnung-batterien/ - Ecosistant – Battery Regulation BATT2 – Important for online retailers
https://www.ecosistant.eu/batterieverordnung-batt2-wichtig-fuer-den-online-handel/ - EY Law – New regulations for the battery industry
https://www.eylaw.de/de_de/news/2024/neue-regelungen-fuer-die-batteriewirtschaft - net pilots – The new EU Battery Regulation – what's changing
https://www.netzpiloten.de/die-neue-eu-batterieverordnung-das-aendert-sich/ - LicenseZero – EU postpones due diligence requirements for batteries until 2027
https://www.lizenzero.de/blog/eu-batterieverordnung-start-der-sorgfaltspflichten-soll-auf-2027-verschoben-werden/ - Tradavo Compliance – The new EU Battery Regulation (BATT2)
https://compliance.tradavo.eu/eu-batterieverordnung/
Further technical information
- Battery Law.com – The new Battery Act (BattG)
https://www.batteriegesetz.de - Battery Law.com – The new EU Battery Regulation 2023 (BATT2)
https://www.batteriegesetz.de/themen/die-neue-batterieverordnung-batt2-2023/ - VDE – An overview of the new EU battery regulation
https://www.vde.com/topics-de/energy/dienstleistungen - Daato – EU Battery Regulation and its implications
https://de.daato.net/articles/eu-commissions-proposed-battery-regulation-and-its-impact-on-businesses - Gunner Cooke – The new EU Battery Regulation: What you need to know
https://gunnercookede.com/die-neue-eu-batterieverordnung-was-sie-wissen-mussen/ - eco-compliance – New EU Battery Regulation – Overview and key changes
https://www.eco-compliance.de/blog/neue-eu-batterieverordnung-ueberblick-und-schluesselaenderungen/
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