EU Regulation 2023/1542, in force since 17 August 2023, sets new standards for the entire battery market in the European Union. It covers the full product lifecycle – from design and manufacturing, through use, to recycling. The regulation emphasizes environmental aspects, product traceability, user safety, and the responsibilities of manufacturers and importers.
In this article, we outline the most important dates, obligations, and changes introduced by the regulation. Familiarity with these rules is now essential to remain compliant and operate smoothly within the EU market.
New battery classification
The regulation introduces a new six-part classification of batteries. Depending on the category, companies will face different obligations:
- portable batteries (up to 5 kg)
- batteries for light means of transport (LMT, up to 25 kg)
- batteries for electric vehicles (EV, over 25 kg)
- industrial batteries,
- starter, lighting, and ignition batteries (SLI)
- stationary battery energy storage systems (SBESS)
With this classification, manufacturers must precisely define the type of battery and adjust testing, documentation, and labeling accordingly. This is a key part of fulfilling the requirements for battery manufacturers.
Restricted substances and requirements for battery manufacturers
As of mid-2024, the use of cadmium, mercury, and lead is prohibited in all battery types, with very limited exceptions. Implementing this provision requires chemical analyses and compliance checks with RoHS standards – a crucial aspect of the regulatory requirements for battery manufacturers.
Carbon footprint reporting obligation – from 2025
The regulation introduces mandatory carbon footprint declarations at specific stages:
- from 18 February 2025 for LMT batteries
- from 18 February 2026 for industrial (rechargeable) batteries
- from 18 August 2028 for EV batteries
These obligations also include product lifecycle assessment (LCA) and documentation verification by notified bodies.
Recycling and raw material recovery – additional requirements for battery manufacturers
EV, LMT, industrial, and SLI batteries must contain minimum amounts of recycled metals, such as cobalt, lithium, nickel, and lead. The first stage of this requirement begins on 18 August 2028, with full implementation mandatory from 2033. This is a major part of the long-term sustainability requirements for battery manufacturers.
Durability and dismantlability
Starting in August 2024, performance and durability requirements will apply to EV, LMT, and industrial batteries. Portable batteries will be included in these requirements beginning August 2028.
Additionally, from February 2027, end users must be able to independently remove and replace batteries in portable devices and light means of transport.
SBESS safety – from 2024
Stationary battery energy storage systems will have to meet strict construction and fire safety standards. This applies to energy storage systems integrated into the power grid as well as standalone units.
New labeling rules and QR codes
From August 2025, all batteries must be labeled according to the new guidelines. Two years later, starting February 2027, QR codes will be mandatory. These codes must contain detailed product data such as chemical composition, material origin, carbon footprint, and lifespan.
State and lifespan information – from 2024
From August 2024, manufacturers must provide information on battery health, usage conditions, and expected lifespan.
Due diligence – obligation for large companies
Companies with annual net turnover above EUR 40 million will be required to implement a due diligence policy for raw material sourcing. This obligation comes into effect on 18 August 2025 and will be subject to external audits.
How does RCC support manufacturers in meeting the requirements?
At the RCC Research and Development Center, we have been supporting manufacturers and importers for years in ensuring product compliance with EU legislation. Our services include:
- RoHS, LVD, EMC, and durability testing
- Documentation and EPREL compliance verification
- LCA and carbon footprint analysis
- Dismantling, charging cycle, and safety tests
- Training and implementation consulting
- Audits and due diligence policy preparation
Thanks to our experience, technical resources, and tailored approach to each project, we help companies efficiently and timely implement the new battery manufacturer requirements under Regulation 2023/1542.
How to prepare for the new regulatory landscape
Regulation 2023/1542 is more than just a set of rules – it represents a systemic shift in how batteries are treated throughout their entire lifecycle. The requirements that have already come into force will continue to expand gradually until 2033.
For companies operating in the battery market, this means a need to revise design processes, documentation, sourcing strategies, and servicing approaches. The earlier preparatory steps are taken, the lower the risk of product market entry issues.
At RCC, we are ready to support your company at every stage of adapting to the new battery manufacturer requirements – from testing and analysis to documentation, audits, and training. The changes are inevitable, but with the right approach, they can become a driver for improved quality, sustainability, and increased competitive advantage.