Everything you need to know about the new EU battery regulation

Key requirements: traceability and due diligence

The digital passport will be mandatory for industrial batteries with a capacity above 2 kWh and for batteries used in electric vehicles and light means of transport (LMT). Through a QR code, it will provide access to essential information about the battery: composition, carbon footprint, recycled content, state of health, and recycling obligations. It is not only a transparency tool for consumers but also a traceability mechanism between economic operators.

This model will progressively extend to other products under the Ecodesign for Sustainable Products Regulation (ESPR), with batteries being the first area of application.

In addition, from August 2027, economic operators with an annual turnover exceeding €150 million (threshold currently under legislative discussion; the current text of the Regulation establishes €40 million) must implement and report due diligence systems to identify, prevent, and mitigate social and environmental risks associated with the entire battery life cycle.

This involves, among other processes, mapping the supply chain, evaluating suppliers, and establishing monitoring and corrective mechanisms for non-conformities.

A growing market and structural challenges

According to Eurostat, 231,000 tonnes of portable batteries were placed on the EU market in 2023, and 117,000 tonnes were collected as waste for treatment. With the electrification of transport and the expansion of energy storage, these flows will increase significantly in the coming years, creating new challenges for companies in the sector.

One of the main challenges will be data management. Traceability and due diligence require systems capable of continuously collecting, verifying, and updating technical and sustainability information. This implies not only greater operational complexity but also significant adaptation of ERP systems and the technological tools that support them.

Another key aspect is recycled content: the Regulation introduces reporting obligations and, progressively, minimum percentages for certain materials. The challenge is no longer only regulatory but also industrial, given the need for infrastructure and mature processes that guarantee a stable supply of secondary materials.

Sector developments

In 2025, the “Stop the Clock” mechanism was formally adopted, delaying the application of due diligence obligations until 18 August 2027. In addition, the Commission must publish technical guidelines before 26 July 2026, a document that will establish the specific operational criteria.

At the same time, associations such as EUROBAT have called for greater coherence between the EUBR and other European sustainability frameworks, particularly the CSDDD, in order to avoid overlaps and unnecessary burdens. They have also requested a review of the timeline and scope of the digital passport, especially regarding industrial batteries and the disclosure of certain sensitive technical data.

While new delegated acts are expected to clarify remaining technical aspects, the message is clear: the timeline has been adjusted, but the level of requirements remains firm. Preparation cannot be postponed.