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EU Battery Regulation (BattVO)

The EU Battery Regulation (BattVO) replaces the previous Battery Directive 2006/66/EC. It entered into force in 2023, but most of its core requirements have applied only since February 18, 2024, and it covers nearly all battery categories placed on the EU market, including portable, automotive, industrial, electric vehicle, and light means of transport batteries. Individual requirements take effect on a staggered timeline. In Germany, the regulation has been flanked since October 2025 by the Battery Law Implementation Act (BattDG), which replaced the previous Battery Act (BattG).

Key requirements include the obligation to declare the carbon footprint per battery model and production site across its entire life cycle; binding minimum shares of recycled materials such as cobalt, lead, lithium, and nickel, which increase in stages; due diligence obligations regarding the origin of raw materials used; binding collection and recycling targets; and requirements on removability, replaceability, and labeling of batteries, for example via a QR code.

Another central element is the digital battery passport, which becomes mandatory from February 2027 for electric vehicle, industrial, and light means of transport batteries with a capacity above 2 kWh. It bundles information on carbon footprint, material composition, recycled content, battery state of health, and due diligence data, making it a sector-specific counterpart to the more general concept of the Digital Product Passport.

For battery manufacturers, importers, and companies that integrate batteries into their own products, for example in electromobility, electronics, or mechanical engineering, the EU battery regulation entails considerable effort in collecting data along the supply chain. Given the long lead times before the 2027 deadlines, building robust processes for capturing origin, material, and emissions data early on is advisable.

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