Regulation (EU) 2023/1542 — new obligations for battery manufacturers from 18 August 2025

Shortcuts

Starting from 18 August 2025, new requirements will be imposed on manufacturers and importers of batteries entering the European Union market under Regulation (EU) 2023/1542. The new rules cover the entire life cycle of batteries — from design and production, through use, to recycling and resource recovery.

These regulations replace the previously applicable Directive 2006/66/EC and introduce many detailed requirements aimed at reducing the environmental impact of batteries and increasing the efficiency of material recovery.

Which products are covered by the regulation?

Regulation (EU) 2023/1542 applies to virtually all batteries and accumulators placed on the European Union market. It covers, among others:

  • portable batteries,
  • industrial batteries,
  • batteries for electric vehicles (EV),
  • batteries for light means of transport (LMT), such as electric bicycles and scooters,
  • batteries used in machinery, equipment, and electronic devices.

For many consumer electronics manufacturers, the requirements concerning portable and general-purpose portable batteries will be of particular importance.

Basic definitions

Portable battery — a sealed battery or accumulator weighing up to 5 kg, handheld, not intended for industrial, EV, or automotive applications.

General-purpose portable battery — standard battery formats such as AA, AAA, C, D, 9V, 4.5V (3R12), A23, and button cells.

What will change on 18 August 2025?

The most important new requirements effective from 18.08.2025 concern battery labeling:

  • It will be mandatory to mark batteries with the selective collection symbol (crossed-out wheeled bin).
  • The size of the symbol depends on the size and type of the battery:
    • Flat batteries — at least 3% of the lateral surface area, maximum 5 × 5 cm,
    • Cylindrical batteries — at least 1.5% of the lateral surface area, maximum 5 × 5 cm,
    • Very small batteries — if the marking would be smaller than 0.47 × 0.47 cm, the symbol must be placed on the packaging (minimum 1 × 1 cm).

In practice, many manufacturers will need to adjust the labeling on their product housings and packaging.

Used battery collection requirements

The new regulations specify concrete collection targets that manufacturers must achieve for used batteries:

Battery typeCollection target by 2027Collection target by 2030/2031
Portable batteries63%73% (2030)
LMT batteries (light means of transport)51% (2028)61% (2031)

Raw material recovery and recycling levels

The regulation also sets requirements for the recovery of valuable materials:

  • lithium: 50% by 2027, 80% by 2031,
  • cobalt: minimum 16% recycled material content,
  • lead: minimum 85% recycled material content
  • nickel: minimum 6% recycled material content.

New information obligations

The new rules also expand the scope of information that must be available to consumers and authorities:

  • Digital battery passport – containing data on the manufacturer, composition, production site, and recycling options.
  • QR codes on battery labels – enabling quick access to detailed product information.

What does this mean for manufacturers?

A manufacturer placing products containing batteries on the market should:

  • verify whether their products are covered by the new regulations,
  • adjust labeling and packaging to meet requirements,
  • complete and update technical documentation,
  • implement appropriate collection and recycling processes,
  • comply with requirements for recycled material content.

How does RCC support manufacturers?

At RCC Sp. z o.o., we continuously monitor regulatory changes and assist companies in adapting their products to new regulations. We offer:

  • labeling and marking audits,
  • preparation of technical documentation,
  • consultations on new legal obligations,
  • compliance testing for electrical and electronic devices.

Do you have questions? We are happy to help analyze your obligations and prepare your products to meet the requirements of Regulation (EU) 2023/1542.