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The new EU Batteries Regulation (EU) 2023/1542, implemented on August 18, 2023, signifies a shift from the Battery Directive to the Batteries Regulation. The earlier Battery Directive (2006/66/EC) primarily focused on waste management and restricting hazardous substances; the new regulation adopts a comprehensive life-cycle approach.
The Batteries Regulation now adheres to all stages of the value chain, including extraction, manufacturing, market placement, use, repurposing, recycling, and disposal, within a unified legal framework. This reflects a broader perspective, viewing batteries as essential for the EU green deal, supply chain independence, and circular economy objectives, rather than just waste.
The battery passport requirement under Article 77 will take effect for many batteries by February 2027 (and earlier in some cases), making a digital record a condition for market placement. Manufacturing sites and battery batches now need to report and verify their environmental footprint. This process requires third-party verification and public disclosure, ensuring transparency and accountability.
We're seeing a steady increase in collection and recycling targets for various battery types, including portable, LMT, and industrial batteries, with these goals progressively rising through 2030.
Companies are also facing new supply chain due diligence obligations. This means conducting environmental and human rights risk assessments. Under Article 69, there are liabilities for harm even if due diligence was performed.
Finally, conformity assessments and labelling are now mandatory for both new and repurposed batteries, following Module A requirements. A significant development is the battery passport requirement, which will come into effect for many batteries by February 2027 (and some even earlier), making a digital record a prerequisite for market placement.
The EU's concept of "battery passports" goes beyond mere documentation. It's about assigning each battery a unique identity that remains with it throughout its entire lifecycle, from manufacturing to recycling. Inside that digital passport are more than just statistics: where the materials were sourced, how much of it comes from recycling, its environmental impact, and even how well it has held up during use.
The idea is simple but powerful; instead of a black box, a battery becomes traceable and accountable. A manufacturer can see whether their supply chain holds up to scrutiny. Regulators can measure progress on a circular economy action plan. And consumers, often left in the dark, finally get a clear view of the condition and lifespan of the battery that powers their car or home system.
This record also unfolds new life for old batteries. Once an EV battery stops serving the road, the passport helps determine whether it belongs in a second vehicle, a solar storage system, or the recycling stream. It transforms what was once a waste problem into a map for reuse, repair, and recovery.
Under the EU regulation, the battery passport helps achieve multiple objectives:
The EU Regulation assigns explicit responsibility for creating and maintaining the battery passport:
The gateways for batteries translate the manufacturer’s responsibility of transparency, promoting sustainability.
Supply Chain Transparency and Ethical Sourcing
The battery passport makes sourcing data visible, identifying mined raw materials, levels of recycled content, refining and component suppliers, and carbon emissions, helping to enforce supply chain due diligence and ethical sourcing standards. This visibility can reduce risk, improve stakeholder trust, and enforce environmental and social commitments.
Circular Economy, Reuse, and Recycling
By documenting how a battery was manufactured, used, repaired, and recycled, the passport supports decisions on whether a battery should be reused, remanufactured, or recycled. It can also feed into reuse and recycling pathways, improving recovery rates and reducing waste.
Consumer Trust, Resale Value, and Second-Life Markets
Access to verified data on battery performance and history can significantly improve consumer confidence and help buyers assess the health and remaining life of used batteries or EVs. This can help strengthen resale markets and secondary applications.
Compliance and Risk Mitigation
Battery passports help manufacturers, importers, and other stakeholders demonstrate compliance with EU regulations, reduce regulatory risk, and prepare for liability arising from supply chain or environmental issues. They can also streamline conformity assessments, audits, and market surveillance.
Data Collection, Quality, and Interoperability
Battery passports must pull data from diverse sources: raw material extraction, manufacturing, logistics, use-phase telemetry, repair histories, and recycling events. Ensuring data quality, consistency, format standardisation, and easy interoperability across systems, particularly for stakeholders operating globally or sourcing from multiple suppliers.
Privacy, Verification, and Confidentiality
Not all data in a battery passport is public: some supply chain details may be commercially sensitive or proprietary, and data privacy concerns arise for usage profiles or condition monitoring. Balancing supply chain transparency with confidentiality and verifying that data is accurate and not tampered with are key challenges.
Costs and Impact on SMEs
Developing, maintaining, and updating battery passports involves costs: implementing data capture infrastructure, performing conformity assessments, storing and updating data over a battery’s life, and ensuring compliance. Small and medium-sized enterprises (SMEs) may face a significant burden unless support or streamlined pathways are offered.
Regulatory Uncertainty and Transition Risks
Although the EU regulation is in force, detailed implementing acts and standards are still being finalised. Companies may face risks if battery passport requirements evolve, or if national rules differ in interpretation during the transition period from the old Battery Directive to the new regulation.
Industry Pilots and Voluntary Early Adoption
Some manufacturers and vehicle makers are already piloting battery passports ahead of the regulatory deadline. For instance, Volvo intends to issue battery passports for its EVs in advance of the 2027 deadline, highlighting material provenance, recycled content, and carbon footprint. These pilots help test traceability methods, data sharing models, and serve as early compliance experiments.
Technical Guidance and Standards
Consortia like Battery Pass have issued Content Guidance for battery passport data attributes, while standardisation bodies such as DIN DKE SPEC 99100 are defining formal attribute lists for implementation. These efforts help clarify what data must be included, but adoption and harmonisation remain works in progress.
Certifications and Global Initiatives
The Global Battery Alliance (GBA) is developing a Battery Passport Framework that includes sustainability indicators, verification schemes, and supply chain transparency criteria. Such frameworks may support or complement EU regulatory requirements, particularly for companies operating globally.
The EU's new Battery Regulation (2023/1542) mandates "digital passports" for many EVs, light transport, and industrial batteries by February 2027. These passports will track a battery's entire lifecycle, detailing its composition, carbon footprint, origin, usage, repairs, and recyclability, promoting transparency.
Even with data, cost, and privacy hurdles, this regulation helps build a circular economy, ethical supply chains, and consumer trust. To gain a competitive advantage, we must implement second-life battery applications and ensure full compliance with all relevant regulations.
https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng
https://environment.ec.europa.eu/strategy/circular-economy-action-plan_en
https://commission.europa.eu/strategy-and-policy/priorities-2019-2024/european-green-deal_en
https://www.fiware.org/wp-content/uploads/DIN-DKE_DIN_DKE-SPEC-99100_Batteriepass_EN.pdf
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