The “EU Battery Regulation,” which came into force in 2023, is a comprehensive framework centered on battery sustainability and resource circularity.
Covering the entire life cycle of batteries—from manufacturing and use to disposal and recycling—the regulation aims to reduce environmental impact and decrease reliance on strategic resources. At ICBR2025, held in early September, Rana Pant, an official from the European Commission’s Directorate-General for Environment (DG Environment), presented the latest progress and challenges in the regulation’s implementation.
Objectives of the Regulation
Pant first summarized the regulation’s broad objectives:
To establish a sustainable and high-quality internal market for batteries.
To ensure proper collection and recycling of used batteries, thereby creating a robust secondary raw materials market.
To mitigate environmental and social impacts across the entire battery life cycle and reduce the EU’s dependence on strategic raw materials.
Unlike traditional waste regulations that focused mainly on end-of-life stages, the Battery Regulation comprehensively covers raw material sourcing, performance metrics during use, and recycling efficiency and use of recovered materials at the disposal stage.
Phased Introduction of Carbon Footprint Requirements
One of the most globally watched provisions is Article 7, which sets carbon footprint requirements for batteries. The scope excludes small batteries but covers EV batteries, industrial batteries above 2 kWh, and light vehicle batteries. Calculations must be performed per model and production site, expressed as CO₂ equivalent per kWh.
Implementation will be phased: first disclosure obligations, then performance classification, and finally exclusion from the market for non-compliance. A delegated act detailing calculation methods is under development, with particular debate over how to account for renewable energy procurement contracts (PPAs) in production. Adoption of this delegated act is taking longer than expected, partly because Member States have not reached consensus on the treatment of PPAs.
Mandatory Recycled Content
Article 8 sets requirements for recycled content in cobalt, lithium, nickel, and lead contained in batteries. This too will be phased in: starting with disclosure, followed by mandatory targets beginning in 2031 and 2036. To address concerns about limited supply, not only end-of-life batteries but also process scrap and other post-consumer waste are recognized as valid sources of recycled material.
A technical report will be published by the end of 2025, and a delegated act establishing calculation methodologies is planned for mid-2026. Work is currently underway.
Ensuring Removability and Replaceability
Article 11 requires that portable and light vehicle batteries be removable and replaceable. From February 2027 onward, products must be designed so that consumers can remove or replace built-in batteries. Exceptions apply for safety-critical applications such as medical or underwater devices. For light vehicle batteries, replacement is expected to be carried out by professionals rather than end-users.
Delay in Due Diligence Obligations
Due diligence obligations for raw material sourcing (Article 48), initially planned for 2025, have been postponed to 2027 to give industry more preparation time. Consequently, the Commission’s guidelines will also be delayed to July 2026.
Waste Battery Management and EPR
Articles 55–58 establish Extended Producer Responsibility (EPR). Costs associated with EPR go beyond collection and treatment to include municipal-level waste composition studies and identifying improperly sorted waste batteries.
Articles 59–61 define collection obligations: large batteries (EV, industrial, and SLI) must be collected separately at a 100% rate. For small and light vehicle batteries, a new calculation method based on “Available for Collection” (AFC) will be introduced in 2027.
Consideration of a Deposit Scheme
Article 63 requires assessment of a possible deposit-return scheme for portable batteries by December 2037. The study will examine cost-effectiveness and feasibility for AAA, button, and similar batteries, with legislative proposals if deemed necessary.
Recycling Efficiency and Material Recovery
Targets for recycling efficiency and recovery rates are also set. For lithium, 65% recycling efficiency must be achieved by 2025, rising to 70% by 2030. Recovery rates require 50% lithium by 2025 and 80% by 2031. Rules for calculation and verification were published in July 2025, with a validity assessment scheduled by August 2026. Adaptation for new technologies such as solid-state and sodium-ion batteries will be considered in the future.
Impacts of the Waste Shipment Regulation
Article 72 allows shipment of waste batteries outside the EU, but only if equivalent environmental and health standards are met. The related Waste Shipment Regulation was revised in 2024 and is set to take effect in May 2026.
Key objectives include improving traceability, promoting shipments for recycling, and preventing illegal exports. An EU-wide digital “common system” will become mandatory from 2026, and from November 2026, waste battery classification codes will be standardized. Intermediate materials such as black mass will also be regulated as hazardous waste. Exports to non-OECD countries are expected to be prohibited.
Conclusion
Pant emphasized that the EU Battery Regulation is a pioneering framework covering the entire battery life cycle. It contributes to spreading sustainable, high-quality batteries, reducing environmental and social impacts, strengthening secondary raw material markets, and lessening dependence on strategic resources.
She also highlighted the regulation’s interconnection with other frameworks such as the WEEE Directive and the ELV Regulation, stressing the importance of coordination moving forward.
Reflecting on achievements during her two years in office, Pant expressed her intention to further enhance the regulation’s effectiveness through delegated and implementing acts. While stakeholder conflicts are inevitable, the regulation is already reshaping Europe’s battery industry and represents a crucial step toward a sustainable circular economy.
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SCHANZ, Yukari
Freelance writer based in Vienna, Austria. Currently active in Vienna and Paris, covering European culture, economy, industry, politics, and environmental recycling issues in the French- and English-speaking world. Specializes in international politics, military affairs, and languages.
Hobbies include calligraphy, painting, travel, French wine, karaoke, and dog keeping.
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