Regulation (EU) 2023/1542 concerning batteries and waste batteries is the most far-reaching product sustainability regulation the EU has ever passed. It repeals the old Batteries Directive (2006/66/EC) and introduces a full lifecycle approach covering sustainability, safety, labelling, and end-of-life obligations — with the Digital Product Passport at its heart.
Who is affected?
The regulation applies to all batteries placed on the EU market, regardless of where they are manufactured. It covers four categories:
- Portable batteries — household batteries, power banks, tool batteries (≤5 kg)
- Light means of transport (LMT) batteries — e-bikes, e-scooters, e-mopeds
- Industrial batteries — stationary storage, forklift batteries (including non-EV large-format)
- Electric vehicle (EV) batteries — traction batteries in cars, buses, trucks
DPP Requirements
All industrial batteries ≥2 kWh, LMT batteries, and EV batteries must have a DPP from 18 February 2027. The DPP must be accessible via a QR code on the battery itself and must include:
- Battery model, batch, serial number
- Carbon footprint (kg CO₂e per kWh rated energy) — declared and independently verified
- Recycled content — cobalt, lithium, nickel, lead percentages from waste recovery
- Rated capacity (Wh), state of health (SoH) and state of charge (SoC)
- Chemistry: cathode, anode, electrolyte materials
- Hazardous substances above 0.1% w/w (threshold per substance)
- Extended producer responsibility (EPR) scheme registration
- Take-back and recycling instructions
Carbon Footprint Requirements
The regulation phases in carbon footprint obligations in stages. From February 2027, carbon footprint must be declared. From a later date (expected 2028), carbon footprint must fall within a performance class (A–E). From ~2030, a maximum threshold applies — batteries above it cannot be placed on the market.
Recycled Content Targets
By 2031: cobalt 16%, nickel 6%, lithium 6%, lead 85% must come from waste processing. By 2036 the targets rise further (cobalt 26%, lithium 12%). These must be declared in the DPP with supporting documentation.
Labelling Obligations
All batteries must display: the crossed-out wheelie bin symbol, the separate collection symbol, a QR code, the rated capacity, a hazard symbol if applicable, and the battery category (portable/LMT/industrial/EV). For portable batteries: removability rating and replacement instructions.
Penalties
Penalties are set by member states but the regulation requires them to be "effective, proportionate and dissuasive." Germany has already published draft implementing rules with fines up to €150,000 per infringement for missing DPPs on EV batteries.