The European Union has implemented Battery Regulation 2023/1542, marking a significant transformation in the battery sector. While the regulation came into effect in February 2024, a critical deadline is set for August 18, 2025 - when it will fully replace the existing Battery Directive. Sellers must submit their new batteries regulation registration numbers to the Amazon Compliance Portal by this deadline to maintain compliance and avoid potential product delisting penalties.

The regulation aims to establish a comprehensive framework for sustainable batteries throughout their entire life cycle, from ethical sourcing of raw materials to end-of-life recycling. Its core purpose is to minimize the environmental impact of batteries while strengthening the EU's strategic autonomy in the battery value chain and promoting a circular economy.

This regulation applies to all battery types - whether you're selling standalone batteries or batteries contained within products.

The new regulation introduces 5 Battery Categories:

Electric vehicle (EV) batteries

Light means of transport (LMT) such as e-bikes, e-scooters

Portable batteries (<5kg)

Industrial batteries

Starting, lighting and ignition (SLI) batteries

The key new changes include:

General Compliance Requirements

• Mandatory CE marking compliance for all battery products
• Mandatory appointment of an EU Authorized Representative for non-EU producer

Battery Passport (Digital Battery Passport)

Battery Passport, physically represented by a QR code placed on each battery, is a digital tracking system that monitors crucial data throughout a battery's life cycle. This digital record contains comprehensive information about each battery's composition, capacity, performance history, and recyclability, enabling effective management from production to disposal.

The system requires individual electronic records for industrial batteries (>2kWh capacity), EV batteries, and Light Means of Transport (LMT) batteries. Each passport includes essential information such as manufacturer details, production facility location, and technical specifications. Through a QR code physically placed on each battery, stakeholders can easily access this digital information to assess battery quality, origin, and ensure proper recycling.

This digital passport system, which will be implemented from February 18, 2027, promotes data-driven decision-making and supports the circular economy by facilitating effective recycling pathways and material recovery.

Physical Labelling Requirements

The regulation introduces new labelling requirements to provide consumers the core information of batteries.

• Mandatory requirements for all batteries:

CE marking

Manufacturer info (name, trademark) and Manufacturing date

Battery type and chemistry

Capacity

Separate collection symbol

Hazardous substance markings

Chemical symbols for heavy metals (if above threshold)

• Additional/Supplementary requirements by battery type:

Portable batteries: Heavy metal content

SLI batteries: Voltage

LMT batteries: Range and Charging time

Industrial & EV batteries: Performance parameters and Durability parameters

Due Diligence Requirements

Economic operators placing rechargeable industrial batteries and electric vehicle batteries (with capacity > 2kWh) on the EU market must establish and implement supply chain due diligence policies. This includes:

• Identifying and assessing risks in their raw material supply chain (focusing on cobalt, natural graphite, lithium, nickel and other specified materials).
• Implementing risk mitigation measures, verified by third-party notified bodies and documented through public disclosure and annual reporting.

These requirements applicable from August 2025, aim to ensure responsible sourcing of raw materials and address social and environmental risks in the battery supply chain.

Carbon Footprint Declaration (phased implementation from July 2024)

For rechargeable industrial batteries and electric vehicle (EV) batteries with capacity > 2kWh, producers must provide:

• A carbon footprint declaration with calculated carbon intensity value
• Assignment to carbon footprint performance classes (from January 2026)
• Compliance with maximum carbon thresholds (from July 2027)

Collection and Recycling Targets

• Enhanced collection rates for portable batteries
• Specific recycling efficiency targets for different battery materials

Extended Producer Responsibility (EPR) Requirements

If you're considered a 'producer' under the EU Batteries Regulation, you must comply with these core EPR obligations:

Producer Registration: Register in each EU member state where you will make batteries available on the market.

Reporting: Report to relevant authorities on battery quantities made available, collection rates, recycling operations and export data.

Financial Responsibility: Pay fees to Producer Responsibility Organizations (PROs) or authorized schemes to cover waste collection, treatment, recycling and public information costs.

Who is considered as battery producers?

Battery producers are economic operators that meet at least one of the following conditions:

Places batteries on EU market under their own brand (including manufacturers and rebranders).

Professionally imports batteries into EU member states.

Distance sellers (including both EU and non-EU based) supplying directly to end-users in EU member states.

What Amazon sellers need to do before 18 August 2025?

1. Register Now

Begin the registration process, and obtain registration numbers in EU member states where battery products will be sold. Amazon currently provides registration access in eight EU member states: France, Germany, Italy, Spain, Sweden, Poland, Netherlands and Belgium. Keep monitoring notifications for when additional member states open registration.

2. Provide registration numbers to Amazon

Submit your registration numbers to marketplace for compliance, through Amazon's Compliance Portal for each country. Including these numbers in your product listings.

3. Annual reporting and eco-fees payment

Annually report your battery sales and pay eco-fees to the relevant EU authorities.

Note:

The EU Batteries Regulation does not apply to Great Britain (England, Scotland, and Wales) but does apply to Northern Ireland under the Northern Ireland Protocol.

As we enter this new era of battery regulation in the EU, companies need to adapt swiftly to the changing requirements. Early preparation and understanding of the new compliance framework will be key to maintaining market access and building long-term success in the EU battery market.

With professional support and efficient services, you will be able to easily meet EPR compliance requirements, avoid potential legal risks, and focus on business growth. Reach out to VATAi today for a free consultation!