EU Battery Regulation Report
Supporting the battery value chain in the European Union
Paving the way for electrification
Batteries are a key component of electric vehicles and renewable energy systems, making them essential to achieving climate neutrality by 2050. The European Union has consequently positioned batteries as a core feature of its industrial strategy and the European Green Deal.
The EU Battery Regulation (EUBR), adopted in 2023, aims to support the development of a sustainable value chain for the European battery industry. It covers the full battery lifecycle, from design to end-of-life, and it pays special attention to ensuring the environmental benefits of batteries. Tailored regulatory requirements lay out how batteries should be designed, manufactured, used and recycled sustainably.
As an independent third party, Bureau Veritas provides a suite of services to support regulatory compliance across the entire battery value chain. Our comprehensive service offer ranges from carbon footprint and supply chain due diligence assessments to solutions for digital traceability and data assurance to testing, inspection and certification.
Key figures
What is the EU Battery Regulation?
The EU Battery Regulation (Regulation (EU) 2023/1542), changes how batteries are designed, manufactured, commercialized, used and managed within the European Union.
The regulation introduces harmonized requirements across all EU countries. It imposes stricter requirements on battery producers, importers, original equipment manufacturers, industrial operators and recyclers. The EUBR’s goal is to guarantee that batteries on the EU market are safe, sustainable, circular and responsibly sourced.
The five components of EUBR compliance
There are five key components to EUBR compliance:
- CE marking requirements for product conformity
- CE marking conformity assessment
- Battery passport implementation
- Supply chain due diligence
- End-of-life, waste management and recycled content
Companies placing batteries or battery-containing products on the EU market must comply with complex obligations spanning these areas. Failure to comply may result in market access restrictions, product withdrawals, and financial penalties. Another risk is reputational damage, as authorities, customers and investors increasingly scrutinize battery sustainability claims.
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Batteries will help power the way to a net-zero future in Europe. Bureau Veritas supports our clients in meeting rigorous performance, safety and environmental standards for batteries across their entire lifecycle.
Carbon footprint declarations
The EUBR introduces a mandatory carbon footprint declaration and performance requirements. This carbon footprint declaration applies to specific battery categories, including electric vehicle batteries, certain rechargeable industrial batteries and LMT batteries. The declaration must be established per battery model and per manufacturing plant.
The aim of the EUBR requirements is to ensure comparability and transparency of carbon footprint information. This will help reduce greenhouse gas emissions across battery value chains, prevent carbon leakage, support informed purchasing decisions and create a level playing field for manufacturers worldwide.
Battery passport
Another major innovation in the EUBR is the battery passport, which is a digital record that accompanies an individual battery. The passport is designed to facilitate transparency and traceability across the battery value chain.
The battery passport consolidates regulatory and sustainability information, including on carbon intensity, material origin and composition, renewable content and repair and repurposing potential. It connects to EU-level data infrastructure and must be interoperable and allow third-party verification.
The battery passport facilitates transparent data exchange, which helps promote circularity and sustainability across the battery value chain.
Bureau Veritas Battery Services
Bureau Veritas supports compliance with the EU Battery Regulation across the full battery lifecycle. We offer:
- Carbon footprint verification as a notified body, supporting battery carbon footprint declarations, performance classes and maximum threshold requirements
- Verification of supply chain due diligence policies as a notified body
- Battery passport services, including support for passport creation and interoperability as well as data verification and digital trust services
- Supply chain due diligence audits and assessments, including risk identification
- Testing, inspection and certification through Bureau Veritas laboratories, covering safety, performance, durability and regulatory conformity
- End-of-life and recycled content verification, supporting recycled content declarations, material recovery thresholds and traceability of secondary raw materials
- Digital traceability and data assurance solutions, enabling secure and auditable regulatory data flows across the battery lifecycle
Frequently Asked Questions
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What is the EUBR’s implementation timeline?
The current timeline for EUBR implementation stretches to 2031, with intermediary steps between its 2023 publication and full applicability. The key dates for entry into force are:
- 2024 - Performance, durability and safety requirements
- 2025 - Waste battery management, carbon footprint of electric vehicle (EV) batteries, and CE marking and related conformity assessment procedures and general economic obligations
- 2026 - Carbon footprint of industrial batteries
- 2027 - Battery passport, due diligence policy checks
- 2028 - Enhancement of requirements for recycled materials and carbon footprint of batteries for light-duty vehicles
- 2030 - Carbon footprint of external energy storage of industrial batteries
- 2031 - Minimum requirements of recycled materials
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What batteries are included in the EUBR?
The EUBR applies to all categories of batteries. This includes:
- portable batteries
- starting, lighting and ignition batteries (SLI batteries)
- light means of transport batteries (LMT batteries)
- electric vehicle (EV) batteries
- industrial batteries
It also applies to batteries that are or can be incorporated into or added to other products.
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What performance and durability requirements does the EUBR include?
The EUBR introduces mandatory performance and durability requirements to help batteries on the EU market function reliably over their lifetime. As a result, batteries must now be accompanied by reliable and comparable technical declarations. The requirements also seek to promote downstream circular economy applications, including reuse and second life.
The requirements apply progressively to portable batteries of general use (excluding button batteries), rechargeable industrial batteries with a capacity greater than 2 kWh, LMT batteries and EV batteries.
The EUBR’s performance and durability requirements took effect on August 18, 2024 for the relevant battery categories, with further detail set out through delegated acts. Manufacturers and importers must adopt compliance strategies that proactively anticipate upcoming requirements. -
Does the EUBR feature supply chain due diligence requirements?
The EU Battery Regulation introduces a mandatory supply chain due diligence framework for battery manufacturers, importers and distributors. This framework aims to ensure that battery raw materials are sourced in a way that addresses and prevents environmental, climate, human health, social and human rights risks.
The regulation lays out the specific materials subject to due diligence obligations, namely cobalt, natural graphite, lithium, nickel and chemical compounds based on the aforementioned raw materials. Manufacturers, importers and distributors must identify and assess risks associated with these raw materials. They must base their risk identification on verifiable evidence and keep it up to date. -
What are the mandatory steps that economic operators must follow to meet due diligence obligations?
There are seven mandatory steps that economic operators must follow to meet due diligence obligations. Economic operators must:
- Adopt and communicate a battery due diligence policy
- Adopt internationally recognized due diligence standards
- Implement internal management systems and record-keeping
- Ensure top management oversight
- Ensure control, transparency and supply chain traceability
- Implement contractual integration with suppliers
- Set up a grievance mechanism
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How does the EUBR address batteries’ end-of-life phase?
The EUBR seeks to strengthen circularity and traceability across battery value chains, including the end-of-life phase. It establishes a comprehensive framework governing the collection, treatment, recycling and material recovery of waste batteries placed on the EU market.
The framework sets rules to ensure the safe collection and treatment of batteries and minimize environmental and human health impacts at the end of a battery’s life. It also lays out guidance on securing strategic raw materials from end-of-life batteries through high-quality recycling.
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