TÜV SÜD: Scope 3 Compliance Challenge in Battery Regulation

The European Union's new Battery Regulation (EU) 2023/1542 is set to reshape the battery industry, with far-reaching implications for manufacturers, suppliers and stakeholders worldwide. As the 18 August 2025 deadline approaches, companies throughout the supply chain face urgent pressure to comply with stringent new sustainability, labelling and safety requirements.

Comprehensive battery life cycle oversight

The updated EU Batteries Regulation covers all aspects of the battery life cycle, from raw material procurement and production to reuse and recycling. It introduces new battery categories based on their use and design and mandates third-party verification for specific compliance aspects.

Grant Gibbs, Senior Manager for Energy Storage at TÜV SÜD, emphasises the urgency of compliance: "Companies throughout the supply chain have no time to waste if they want to continue selling their products in the EU market after 18 August. The EU Batteries Regulation introduces significant changes to enhance the sustainability and safety of batteries and battery-operated products. The regulation promotes transparency and responsibility throughout the battery supply chain."

Key requirements of the new regulation

The EU Batteries Regulation (EU) 2023/1542, introduced on 12 July 2023, aims to enhance battery sustainability throughout its life cycle. Notable aspects of the regulation include:

Battery categories and sustainability focus: The regulation applies to five categories of batteries: portable batteries, starting, lighting and ignition (SLI) batteries, light means of transport (LMT) batteries, electric vehicle (EV) batteries and industrial batteries.

It promotes sustainability and a circular economy by encouraging a competitive and sustainable battery industry to support Europe's clean energy transition.

Substance restrictions and extended producer responsibility: The regulation enforces substance restrictions, maintaining existing bans on mercury and cadmium in batteries and introducing a new restriction on lead in portable batteries.

Additionally, it establishes Extended Producer Responsibility (EPR), requiring producers to take back waste batteries free of charge and ensure their separate collection and environmentally friendly recycling.

Digital traceability and CE marking: Starting on 18 February 2027, specific battery types must feature a battery passport with a QR code and CE marking to enhance digital traceability and improve monitoring and compliance.

Challenges for industry stakeholders: Implementing the new regulation presents significant challenges for manufacturers, suppliers and stakeholders.

Regulatory complexity: The high regulatory complexity and overlapping requirements may create confusion and make compliance difficult, particularly for niche or small-scale battery producers facing increased administrative and cost burdens.

Supply chain adjustments: Businesses must make substantial supply chain adjustments, implementing stringent policies for the responsible sourcing of materials like cobalt, lithium and nickel..

Design and production modifications: Manufacturers must modify their design and production processes to meet carbon footprint targets, recycled content requirements and hazardous substance restrictions.

Impact on battery manufacturers: The new regulation introduces major shifts in battery manufacturing, including:

Sustainable design: Products must meet stricter performance, durability and labelling standards.

Expanded product categories: EV and LMT batteries are included, forcing manufacturers to adjust product lines

Recycling efficiency: Strict material recovery goals push manufacturers toward improved battery end-of-life management.

Supply chain implications: For battery component suppliers, the regulation imposes significant operational changes.

Transparency and due diligence: Mandatory policies for sourcing key materials and annual environmental and social risk reports are required.

Traceability requirements: Implementing a digital battery passport to track metrics across the supply chain becomes necessary.

Increased costs: Compliance with new rules may lead to higher operational and production expenses.

Preparing for the August 2025 deadline

As the 18 August 2025 deadline approaches, businesses must act swiftly to ensure compliance. Key steps for compliance include:

1. Conducting comprehensive supply chain audits to meet due diligence requirements.
2. Investing in technology to support battery traceability and carbon footprint reporting.
3. Collaborating with regulatory experts to ensure adherence to evolving compliance standards.

The new EU Battery Regulation 2023/1542 represents a landmark battery sustainability and accountability shift. Economic operators must proactively adapt to these requirements to secure market access and contribute to a more sustainable and transparent battery industry.

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