Key Requirements and Impacts of the EU Battery Regulation 2023/1542

On August 18, 2025, the EU Battery and Waste Battery Regulation (EU) 2023/1542 became fully applicable across the European Union, replacing Directive 2006/66/EC. As a directly binding regulation, it introduces stricter and more harmonized compliance requirements for batteries placed on the EU market. While the regulation is now in force, many obligations are being implemented in phases, requiring manufacturers and suppliers to adapt to evolving, increasingly complex compliance expectations.

From directive to regulation

Regulation (EU) 2023/1542 entered into force on August 17, 2023, significantly strengthening regulatory oversight and eliminating inconsistencies in implementation across Member States. Unlike the previous directive, the regulation establishes a directly applicable and harmonized framework across the EU. It now governs the entire battery life cycle, from raw materials sourcing and design through use, reuse and end-of-life management.

This comprehensive life cycle-based approach marks a decisive shift toward embedding circular economy principles within EU legislation, substantially expanding the scope and depth of compliance obligations.

Key compliance areas include:

• Restricted and hazardous substances
• Carbon footprint calculation and declaration
• Minimum recycled content
• Conformity assessment and CE marking
• Supply chain due diligence
• Transparency for authorities and consumers

The new regulation introduces significantly more stringent requirements for technical testing, documentation and independent verification. Authorized Notified Bodies (NB) now play a more prominent and formalized role, conducting conformity assessments and verifying compliance where required. Their expanded involvement is intended to strengthen regulatory oversight, enhance credibility and ensure consistent application across the EU single market.

What is new?

In addition to becoming directly applicable law across all Member States, the regulation introduces deeper, more granular requirements across sustainability, safety and transparency. It also aligns more explicitly with broader EU Green Deal objectives and climate neutrality targets.

Key enhancements include:

• Sustainability and safety requirements, such as tighter substance restrictions, expanded carbon footprint rules and mandatory use of recycled materials
• Expanded information disclosure, including battery labeling, QR codes, battery management system data and upcoming battery passport requirements
• Stronger consistency mechanisms, such as presumption of conformity, EU declarations of conformity (DoC) and CE marking
• Broader stakeholder obligations, including due diligence, extended producer responsibility, waste battery management and green public procurement requirements

Industry impact

Batteries sit at the core of the energy transition and power a wide range of products across automotive, mobility, consumer electronics and energy storage industries. Rapid market expansion, increasing battery variety and emerging applications have significantly increased regulatory complexity and risk.

Regulation (EU) 2023/1542 introduces higher and more interconnected compliance thresholds for batteries and battery‑powered products entering the EU market. Manufacturers must now align technology, documentation and supply chains with more stringent and integrated regulatory expectations.

This shift requires closer collaboration across engineering, compliance and procurement functions, as well as more proactive life cycle management and robust data governance practices.

Battery categories

The Regulation introduces a structured five-category classification system based on design and intended use to ensure clear, consistent and proportionate regulatory oversight.

The five categories are:

• Electric vehicle (EV) batteries
• Light means of transport (LMT) batteries – e-bikes, e-scooters, etc.
• Industrial batteries, including stationary energy storage systems
• Starter, lighting and ignition (SLI) batteries
• Portable batteries

Each battery category is subject to specific and, in many cases, differentiated compliance requirements tailored to risk, performance and application context. These distinctions affect testing requirements, documentation scope and applicable conformity assessment procedures.

This more granular classification increases both the precision and complexity of compliance, creating heightened regulatory obligations for battery manufacturers, importers and suppliers across the value chain.

Compliance confidence

Meeting the EU’s new battery requirements demands more than isolated testing or standalone declarations, as compliance now extends across the full battery life cycle. An integrated, end‑to‑end compliance approach combining regulatory interpretation, testing, verification and conformity assessment enables manufacturers to reduce risk, optimize resources and maintain market access.

The regulation transforms compliance from a one‑time exercise to a continuous, life cycle obligation, making coordinated technical, documentation and supply chain management essential for sustained and scalable compliance.

SGS solution

We provide integrated, end‑to‑end support across regulatory interpretation, testing, verification and conformity assessment.

Utilizing our global network of industry‑leading experts and state‑of‑the‑art testing facilities, we offer a single, fully integrated compliance solution covering the entire battery life cycle. Our one‑stop approach helps manufacturers reduce risk, optimize resources and efficiently access the EU market, delivering clarity, consistency and confidence while preparing for both current and future regulatory requirements.

One-stop solution