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The New EU Battery Regulation
The EU Battery Regulation (EU) 2023/1542 introduces strict rules and obligations for battery manufacturers, importers, and traders, starting August 18, 2024. The regulation aims to reduce environmental impact, improve battery sustainability, and ensure compliance across the EU.
The regulations for Extended Producer Responsibility remain largely unchanged, requiring companies that place batteries in the EU market to manage their collection and recycling. They must also report quantities to national authorities, often outsourcing these tasks to Producer Responsibility Organizations (PROs).
Key Obligations for Manufacturer Starting August 18, 2024
• CE Marking: The manufacturer must apply the CE marking to each battery.
• EU Declaration of Conformity: The manufacturer must prepare a declaration of conformity for each battery model.
• Technical Documentation: The manufacturer must create necessary technical documentation.
• Quality System: For certain types of batteries, the manufacturer must implement an approved quality system for production, inspection, and testing, and be subject to surveillance.
• Instructions and Safety Information: The manufacturer must ensure that the battery includes clear, understandable, and legible instructions and safety information.
• Manufacturer Identification: The manufacturer must indicate their name, registered trade name or trade mark, postal address with a single point of contact, and website and email address (if possible) on the battery.
• Model and Batch Identification: The manufacturer must ensure that batteries display a model identifier and a batch or serial number, product number, or other identifier.
Key requirement: label + markings
The current best practices for battery label compliance are:
• CE Mark,
• Makers mark,
• Assembly site
• Serial number,
• Model number,
• Warning/safety information,
• Battery chemistry
• Ah
• Wh (best practice, but also mandatory for Li-Ion batteries),
• Voltage (best practice, but also mandatory for Li-Ion batteries),
• Crossed-out waste bin symbol
• Lithium battery recycling symbol
• IEC series/chemistry/parallel coding
Conformity assessment
From August 18, 2024, batteries are required to undergo a conformity assessment procedure (Article 17). This conformity assessment will become the prerequisite for obtaining the EU declaration of conformity (Article 18) and affixing the CE marking of conformity (Articles 19, 20, and 38(3)), both of which will also be mandatory as of August 18, 2024. These steps will demonstrate compliance with the sustainability and safety requirements laid out in Chapter II.
The general rules on how to affix the CE marking to a product, including portable batteries, are available in the Commission’s Blue Guide on the implementation of EU Product Rules 2022.
Risk Assessment
To conduct a thorough risk assessment, the following steps should be followed:
Performance and Durability Requirements in the Batteries Regulation:
Download the this report sets a basis for the design of minimum requirements to ensure minimum battery durability on the European market.
1. Identify Potential Hazards: The first step is to identify all potential hazards associated with the use and handling of lithium-ion batteries. This includes hazards such as overcharging, over-discharging, short-circuiting, thermal abuse, mechanical abuse, and internal defects.
2. Assess the Likelihood and Severity of Risks: For each identified hazard, assess the likelihood of it occurring and the potential severity of the consequences. This will help prioritize the risks and focus the risk mitigation efforts.
3. Implement Safety Measures: Based on the risk assessment, implement appropriate safety measures to mitigate the identified risks according to General Product Safety Directive (GPSD) and battery safety standards and regulations. This may include:
1. Incorporating safety devices such as PTC, CID, and safety vents within the battery cells.
2. Designing an external electronic protection circuit to prevent overcharging, over-discharging, and overcurrent.
3. Ensuring proper voltage monitoring and balancing for cells connected in series.
4. Implementing robust mechanical and thermal abuse testing as per the requirements
5. Adhering to proper handling, storage, and transportation guidelines for lithium-ion batteries.
4. Conduct Verification and Validation Testing: Perform comprehensive testing as per the General Product Safety Directive (GPSD) and battery safety standards and regulations standard to verify the effectiveness of the implemented safety measures. This includes tests such as external short-circuit,thermal abuse, mechanical shock, and vibration.
5. Document the Risk Assessment Process: Thoroughly document the entire risk assessment process, including the identified hazards, risk analysis, implemented safety measures, and test results. This documentation can be used for regulatory compliance, quality assurance, and continuous improvement.
6. Continuously Monitor and Review: Regularly monitor the performance and safety of the lithium-ion batteries in use, and review the risk assessment process to identify any new or emerging risks. Update the risk assessment and safety measures as necessary.
CE Marking Requirements
Removability and replaceability
Products containing portable batteries must be designed to allow end-users to easily remove and replace the batteries using commercially available tools (or specialized tools if provided with the product). Manufacturers must provide instructions and safety information on battery removal and replacement, accessible online. Exceptions apply to devices intended for use in waterprone environments, certain medical devices, products requiring continuous power supply and permanent battery connection for safety, and devices primarily used for data collection and supply to ensure data security.
Performance and durability requirements
The regulation foresees the development of the performance and durability requirements for portable batteries of general use (Article 9 and Annex III). These standards are a practical means of improving the overall quality, sustainability, and safety of portable batteries sold in the EU. However, the Regulation does not foresee the lifecycle assessments of portable batteries before at least 2030. Restriction on Substances and Recycled Content. In addition to restrictions set out in previous directives, the new EU battery regulations mandate restrictions on substances in portable batteries, LMT, and other vehicle batteries, the regulation requires them to contain no more than 0.0005% mercury, 0.002% cadmium, and 0.01% lead.
Digital Battery Passport
The Battery Passport will become mandatory for LMT batteries, industrial batteries exceeding 2 kWh, and EV batteries placed on the market from 18 February 2027. The passport must include details about the battery model and specific information for each battery, accessible via a QR code. Maintained by economic operators, the passport will follow essential technical standards and contain information categorized for different audiences, i.e., the public, authorities (notified bodies, market surveillance authorities, and the Commission), and those with a legitimate interest.
Global battery safety standards and regulations
Evaluate, test and certify virtually every type of battery available — including lithium-ion battery cells
and packs, chargers and adapters — to UL Standards as well as key international, national and
regional regulations including:
• UL 1642 Lithium Cell
• UL 2054 Nickel Cell or Lithium/Nickel Packs
• UL 1989 Standby Batteries
• UL 4200A, the Standard for Products Incorporating Button Batteries or Coin Cell Batteries
• UL 2271, the Standard for Batteries for Use in Light Electric Vehicle Applications
• UL/CSA/IEC 60950 (may be evaluated in conjunction with UL 2054)
• UL/CSA/IEC 60065 (batteries used in audio and video equipment)
• IEC 60086-1 and IEC 60086-2 Non-rechargeable Performance
• IEC 60086-4 Non-rechargeable Lithium
• IEC 60086-5 Non-rechargeable Alkaline
• IEC 61951-2 and IEC 61951-2 Performance of Rechargeable Ni-Cd or Ni-MH
• IEC 61960 Performance of Rechargeable Lithium
• IEC/UL 62133-1 for nickel systems
• IEC/UL 62133-2 for lithium systems
• Japan’s DENAN Ordinance Article 1 Appendix 9
• CTIA—IEEE 1625 and 1725
• Taiwan’s BSMI standards
• IATA/UN DOT/UN 38.3 T1-T8 (or IEC 62281)