About
The Regulation introduces comprehensive requirements for batteries in the EU market, covering their entire lifecycle. A key provision of the Regulation mandates that any product incorporating portable batteries must be designed to ensure these batteries are readily removable and replaceable by the end-user throughout the product's lifetime. This obligation applies to entire batteries, not to individual cells or components.
The Regulation also establishes sustainability and safety standards for battery production, including carbon footprint declarations and minimum recycled content requirements for certain battery types. It introduces a digital battery passport for specific batteries, providing essential information about their composition and lifecycle.
Economic operators must conduct due diligence assessments to ensure compliance with these standards. The Regulation sets ambitious targets for battery collection and recycling efficiency, aiming to enhance resource utilization and reduce environmental impact.
Member States are required to implement penalties for non-compliance. This Regulation replaces the previous Battery Directive, aligning with the EU's broader sustainability and circular economy objectives.
Who does it impact?
The Regulation applies to a wide range of "economic operators" involved in the battery supply chain within the EU market. Specifically, it encompasses manufacturers, authorized representatives, importers, distributors, and fulfillment service providers. These entities are responsible for placing batteries or products containing batteries on the market or putting them into service in the EU.
The definition of "economic operators" is broad and includes any natural or legal person who has obligations related to the manufacture, preparation for reuse, repurposing, or remanufacturing of batteries. This means that not only those directly producing batteries are affected but also those involved in various stages of the battery lifecycle, including preparation and distribution.
Additionally, the Regulation imposes specific requirements on public authorities when they procure batteries or products that incorporate batteries. This aspect emphasizes the need for sustainability and compliance throughout the entire supply chain.
The Regulation covers all types of batteries, including portable batteries, automotive batteries, electric vehicle batteries, and industrial batteries. It also applies to batteries manufactured outside the EU that are made available for sale within the EU market.
In summary, the Regulation establishes clear roles and responsibilities for various economic operators at different stages of a battery's lifecycle, from production to market entry and eventual recycling. This comprehensive approach aims to enhance sustainability and accountability within the battery industry while promoting a circular economy.
Status: In force
The obligations under the Regulation is being implemented gradually rather than coming into force all at once. As of 18 August 2025 it has fully replaced the2006 Directive, which has been phased out over time replacing its provisions with those outlined in the Regulation. Additionally, by 18 February 2027, companies must ensure that portable batteries and batteries for light means of transport are designed for easy removability and replaceability. The obligation to implement due diligence policies enters into force on 18 August 2027.
Implementation in Norway
As of November 2025, the Regulation has not been incorporated into the EEA Agreement.The Regulation will be implemented into Norwegian law through a new national batteries regulation, which will be established under the legal framework of the Sustainable Products Act. The consultation process for this battery regulation has already been completed. The next step involves reviewing and assessing the feedback received during the consultation, which may lead to amendments in the regulation based on stakeholder input.
It is anticipated that the battery regulation will come into effect in Norway soon after the Regulation has been incorporated into the EEA Agreement. The exact timeline for incorporation cannot be precisely determined at this stage, but it is anticipated that the battery regulation will enter into force sometime in 2026.
Thommessen's comments
The Regulation is a crucial component of the EU's broader strategy to promote sustainability and circular economy principles in the battery industry. It aligns with and builds upon key EU initiatives such as the European Green Deal, the Circular Economy Action Plan, and the European Industrial Strategy.
By imposing comprehensive requirements on battery manufacturers, importers, and distributors throughout the entire battery lifecycle, the EU is significantly enhancing sustainability and due diligence obligations within its market. This approach complements other EU regulations, such as the Eco-design Directive and the Waste Framework Directive.
The Regulation's focus on carbon footprint reduction, recycled content, and the introduction of a digital battery passport demonstrates the EU's commitment to technological innovation and environmental protection in the battery sector. These measures are expected to drive advancements in battery technology while simultaneously reducing the industry's environmental impact.