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Core Interpretation of the EU New Battery Regulation (EU) 2023/1542
Author.
LCS
Source:
Post time:
2026-03-10
The EU New Battery Regulation (EU) 2023/1542 is a new battery control regulation that replaces the old Directive 2006/66/EC. It was published in the EU Official Gazette on July 28, 2023 and officially came into effect on February 18, 2024. The old directive will be abolished on August 18, 2025 (some requirements will be used until 2027). This regulation is an important component of the EU Green Deal, with the core goal of creating a sustainable control system for the entire lifecycle of batteries, achieving low carbon footprint, low use of harmful substances, high recycling rate, while enhancing the security of EU raw material supply and industrial strategic autonomy, applicable to all types of batteries circulating in the EU market.
1 Scope of application
Covering all batteries and waste batteries within the European Union, with no category exemptions, the core includes:
1. Portable batteries (such as consumer electronics batteries);
2. Electric vehicle batteries;
3. Industrial batteries;
4. Starting, lighting, and ignition batteries (vehicle/machinery specific);
5. Light transportation vehicle batteries (electric bicycles, electric scooters, light motorcycles, etc.).
2 Core control requirements
（1） Limit control of harmful substances
On the basis of meeting Appendix XVII of the EU REACH regulation and the ELV directive, strict limits on mercury, cadmium, and lead are implemented, which is the basic requirement for the entry of batteries into the market:
1. Mercury: All batteries (whether or not installed in equipment/vehicles) have a mercury content of ≤ 0.0005%;
2. Cadmium: All portable batteries have a cadmium content of ≤ 0.002%;
3. Lead: Starting from August 18, 2024, all portable batteries must have a lead content of ≤ 0.01%; Portable zinc air button batteries are exempt until August 18, 2028.
（2） Full lifecycle identification and traceability requirements
Mandatory implementation from August 18, 2025, to achieve full traceability of batteries from production to recycling:
1. All batteries must be labeled with a separate battery collection symbol, a universal information label, and a unique QR code;
If the cadmium content of the battery exceeds 0.002% or the lead content exceeds 0.004%, the corresponding chemical symbol (Cd/Pb) must be marked on the label;
3. The QR code should include core data such as battery production, material, harmful substance content, and recycling information to achieve full traceability of the supply chain.
（3） Recycling and resource utilization goals
Set a tiered recycling target, forcing the battery industry to improve resource recycling efficiency, and implement core indicators in stages:
1. Portable batteries: The collection rate of waste batteries should be ≥ 63% by the end of 2027 and ≥ 73% by the end of 2030;
2. Light vehicle batteries: The collection rate of waste batteries should be ≥ 51% by the end of 2028 and ≥ 61% by the end of 2031;
3. Lithium resource recycling: The proportion of lithium recovered from waste batteries should be ≥ 50% by the end of 2027 and ≥ 80% by the end of 2031 (subject to dynamic adjustments based on market and technological development).
（4） Low carbon and raw material control
As a core requirement of regulations, focusing on the sustainability of battery production and raw materials:
1. Carbon footprint requirements: Set limits on the carbon emissions of batteries throughout their entire lifecycle, require companies to account for and declare their battery carbon footprint, and make low-carbon the core competitiveness of batteries in the EU market;
2. Raw material traceability: Reduce reliance on raw materials from outside the European Union, require clear traceability systems for key raw materials used in battery production (such as lithium, cobalt, nickel, etc.), and prioritize the use of recycled raw materials;
3. Minimization of harmful substances: In addition to clear limits on mercury, cadmium, and lead, companies are required to minimize the use of other harmful substances in battery production as much as possible.
3 Key time nodes for the implementation of regulations
On February 18, 2024, new regulations officially came into effect, and the EU market began to gradually implement control requirements;
On August 18, 2024, the limit of lead content ≤ 0.01% for portable batteries officially came into effect (exemption for zinc air button batteries);
3. August 18, 2025: The old directive 2006/66/EC is officially abolished, and battery labeling/traceability requirements are mandatory;
By the end of 2027, the targets of 63% collection rate for portable batteries and 50% lithium recovery rate will be achieved, and some of the old instructions will be terminated;
On August 18, 2028, the exemption period for lead content in portable zinc air button batteries will end, and the limit of ≤ 0.01% will be officially implemented;
By the end of 2028/2030/2031, the tiered recycling/resource utilization targets will be implemented in sequence.
4 Core compliance challenges for enterprises
1. It is necessary to establish a battery lifecycle data management system to meet the requirements of carbon footprint accounting, raw material traceability, and QR code information entry;
2. The production line needs to be upgraded and renovated to further reduce the content of heavy metals such as mercury, cadmium, and lead, and adapt to strict limit standards;
3. It is necessary to establish a waste battery recycling channel, connect with the local recycling system of the European Union, and meet the goal of tiered recycling;
4. Batteries exported to the EU must undergo compliance testing to ensure that hazardous substances, labeling, traceability, and other requirements are met, otherwise they will face market access restrictions.
5 Core differences fromold instructions
1. Expanding the scope of control: extending from traditional portable batteries to all categories such as electric vehicles, light transportation vehicles, and industrial batteries, achieving seamless control;
2. Full lifecycle supervision: Upgrade from single hazardous substance control to "production circulation use recycling regeneration" full chain control;
3. New low-carbon and traceability measures: For the first time, carbon footprint and raw material traceability have been included in battery control requirements, becoming an important component of the EU's green trade barriers;
4. Quantification of recycling targets: Set clear tiered recycling and resource utilization goals, linking corporate responsibility with sustainable industrial development.
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