EU Battery Regulation (EU) 2023/1542

Regulation (EU) 2023/1542 replaces the EU Batteries Directive (2006/66/EC) with a directly applicable regulation covering the full battery lifecycle, from placing batteries on the EU market through end-of-life collection, recycling, and reporting. It introduces sustainability, safety, performance, labelling, information, and due diligence requirements with phased implementation dates.

Scope

The regulation applies to batteries placed on the EU market, with requirements varying by battery category and intended use. It introduces obligations for economic operators (manufacturer, authorised representative, importer, distributor) and defines responsibilities across the lifecycle.

• Lifecycle scope: placing on the market, use, collection, treatment, recycling, and reporting.
• Product scope: sustainability, performance and durability, safety (including stationary storage), and information/traceability.
• Governance scope: due diligence policies for certain supply-chain risks and market surveillance/conformity assessment where required.

Battery Categories Commonly Used

The regulation defines multiple battery categories. The list below reflects the typical categories companies map their products into for compliance planning.

Key Requirements

For most companies, the compliance effort is not a single checklist item. It is a system of requirements that touches design, procurement, supplier controls, documentation, testing, and end-of-life obligations.

• Carbon footprint rules (category-dependent) and supporting calculations/data governance.
• Recycled content requirements (phased; category-dependent) with validated chain-of-custody evidence.
• Performance and durability parameters (where applicable) and supporting test evidence.
• Safety requirements, including for stationary storage where applicable.
• Labelling, marking, and information requirements (including QR code / digital information elements).
• Battery passport and electronic registration requirements for specific categories (phased).
• Due diligence policies for certain supply-chain risks (scope and thresholds are defined in the regulation).
• Extended Producer Responsibility (EPR): collection, take-back, treatment, and reporting obligations.

Battery Passport

The battery passport is a digital record (typically associated with a QR code) intended to carry standardized information about certain batteries placed on the EU market. In practice, it forces disciplined data structures, traceability, and documentation readiness across suppliers and internal systems.

• Product identification and battery model information.
• Compliance and sustainability information (category-dependent).
• Evidence trails linking to declarations, test results, and due diligence artifacts.
• Lifecycle information to support end-of-life collection, treatment, and recycling workflows.

Due Diligence & Supply-Chain Controls

For impacted batteries and operators, the regulation introduces due diligence expectations that typically require a documented policy, supplier controls, and an auditable trail. Most implementations resemble an internal control system: define requirements, collect evidence, assess risk, and retain records.

• Supplier onboarding and compliance clauses (data, audit rights, traceability expectations).
• Material origin and chain-of-custody evidence governance.
• Risk screening and escalation workflows for nonconformities.
• Retention of evidence in a controlled documentation system.

Extended Producer Responsibility (EPR)

The regulation strengthens producer responsibility obligations for collection and treatment of waste batteries. In practice, this introduces operational and reporting workstreams that need to be integrated with commercial operations and ERP.

• Producer registration and reporting (country-specific implementation details apply).
• Take-back and collection arrangements (often via compliance schemes).
• Tracking of quantities placed on market versus collected and treated.
• Evidence packages for audits and regulator inquiries.

Phased Implementation Timeline

The regulation is implemented in phases, and some obligations depend on delegated acts and category-specific details. The table below is a practical planning view (not legal advice).

Practical Documentation Checklist

Most compliance programs succeed or fail on documentation discipline. The list below is a practical baseline of artifacts teams commonly build to support conformity, audits, and battery passport readiness.

Implementation Playbook (Fast Start)

If you are building an MVP compliance program for EU market access, start with a structured gap analysis and an evidence-first documentation system. Build toward battery passport readiness early, because it forces clean data and disciplined records.

• Step 1: Classify battery category and your operator role (manufacturer, importer, distributor).
• Step 2: Create a requirements matrix (articles/annexes) mapped to owners and evidence.
• Step 3: Establish document control (QMS) and retention rules.
• Step 4: Stand up traceability fields in PLM/ERP (materials, suppliers, batches, destinations).
• Step 5: Build the passport data model and QR workflow (even before it is mandatory).
• Step 6: Add audit readiness (internal checks, supplier audits, nonconformance handling).

Note: This page is a practical overview. For formal interpretation, consult the legal text of Regulation (EU) 2023/1542 and any applicable delegated/implementing acts.