EU Battery Regulation (EU 2023/1542)

The EU Battery Regulation (EU 2023/1542) has been in force since August 2023, completely replacing the previous Battery Directive. It is the first EU regulation to introduce a mandatory Digital Product Passport (DPP) for a specific product category—the Battery Passport. This makes it critical not only for battery manufacturers but for all companies producing, processing, or distributing battery-powered products in the EU.

Who is Affected?

The regulation applies to all battery categories placed on the EU market:

• Portable batteries (e.g., in consumer electronics)
• LMT batteries (Light Means of Transport, like e-bikes)
• SLI batteries (Starting, Lighting, and Ignition for vehicles)
• Industrial batteries
• EV batteries (Electric Vehicles)

While battery manufacturers are directly targeted, automotive suppliers and manufacturers of electronics or industrial machinery with integrated storage are indirectly affected. They must provide specific data to their customers to ensure downstream compliance.

The Battery Passport: Requirements and Timelines

The Battery Passport is a digital data set accessible via a QR code or Data Matrix code on the product. It must remain available throughout the battery's entire life cycle.

• Mandatory from August 2027: Required for EV batteries and industrial batteries with a capacity of more than 2 kWh.
• Core Content: Life cycle carbon footprint, material composition (lithium, cobalt, nickel, manganese), recycled content percentages, performance and durability parameters, and supply chain due diligence evidence.

Carbon Footprint: The Three-Stage Roadmap

The carbon footprint requirement is the most technically demanding part of the regulation, defined in three stages:

1. From 2025 (Declaration): Manufacturers must calculate and declare the CO2 footprint using a standardized EU methodology (based on ISO 14067).
2. From 2026 (Performance Classes): Batteries will be categorized into CO2 performance classes, communicated via a label (similar to energy labels for appliances).
3. From 2027 (Maximum Thresholds): Batteries exceeding a specific CO2 limit will be banned from the EU market.

To meet these requirements, companies need precise production data: energy consumption per step, material origin, and actual emission factors. Estimates will no longer be sufficient for the second and third stages.

Supply Chain Due Diligence

For raw materials such as cobalt, lithium, nickel, and natural graphite, the regulation mandates a supply chain due diligence policy. Following OECD guidelines, manufacturers must trace materials back to the mine or processing plant to ensure they are free from human rights violations or conflict-related issues.

The Role of MES in Compliance

The Battery Passport is not a static document; it is a "living" data set that requires batch-specific information. To scale this process, manual data collection is impossible. An MES (Manufacturing Execution System) that integrates the following is essential:

• Energy data per production batch.
• Material tracking with supplier and batch references.
• Quality parameters influencing durability.
• Serialization to link the physical battery to its digital twin.

Synergy with Other EU Regulations

The Battery Regulation serves as a blueprint for future product passports under the ESPR (Ecodesign for Sustainable Products Regulation). It also overlaps with the CSRD (Corporate Sustainability Reporting Directive) and the LkSG (German Supply Chain Act), meaning that building the data infrastructure for batteries simultaneously ensures compliance for multiple regulations.

FAQ

Does the regulation apply to small batteries in consumer goods? Yes, but requirements vary. Portable batteries are included but often have longer transition periods or simplified data requirements compared to large traction batteries.

What happens if a product lacks a Battery Passport? After the respective deadlines, non-compliant products cannot be sold in the EU. Market surveillance authorities can seize goods and impose significant fines. This applies to all manufacturers worldwide who wish to export to the EU.

How is the carbon footprint calculated? The EU uses a life cycle approach: raw material extraction, cell production, module assembly, use phase, and end-of-life are all audited separately according to the Product Environmental Footprint (PEF) framework.

How long must the passport be accessible? For at least ten years after the last unit of a battery model is placed on the market. Manufacturers must also ensure data availability in the event of insolvency.