MCM has received a great number of inquiries about the EU Batteries Regulation in recent months, and the following are some key questions excerpted from them.

What are the requirements of the New EU Batteries Regulation?

A：First of all, it is necessary to distinguish the type of batteries, such as portable batteries that less than 5kg, industrial batteries, EV batteries, LMT batteries or SLI batteries. After that, we can find the corresponding requirements and mandatory date from below table.

Q: As per the new EU Batteries Regulations, is it mandatory for cell, module and battery to meet the regulatory requirements? If the batteries are assembled into the equipment and imported, without saling seperately, in this case, should the betteries meet the regulatory requirments?

A: If cells or battery modules are already in circulation in the marketplace and will not further incorporated or assembled into lager packs or batteries, they shall be considered as batteries that sales in the markert, and thus it shall meet the concerned requirements. Similarly, the regulation applied to batteries those incorporated into or added to a product, or those specifically designed to be incorporated into or added to a product.

Q: Is there any corresponding test standard for the New EU Batteries Regulation?

A: The New EU Batteries Regulation entries into force in August 2023, while the earliest effective date for testing clause is August 2024. Up to now, the corresponding standards have not yet been published and are under development in the EU.

Q: Is there any removability requirement mentioned in the new EU Batteries Regulation? What is the meaning of “removability”?

A: Removability is defined as a battery that can be removed by the end user with a commercially available tool, which can refer to the tools listed in the appendix of EN 45554. if a special tool is needed to remove it, then the manufacturer needs to provide the special tool, hot melt adhesive as well as the solvent.

The requirement for replaceability should also be met, which means the product should be able to assemble another compatible battery after removing the original battery, without affecting its function, performance or safety.

Additionally, please note that the removability requirement will take into force from February 18, 2027, and before this, EU will issue guidelines to supervise and urge the implementation of this clause.

The related regulation is EU 2023/1670 – Ecological regulation for batteries used in cell phone and tablet, which mentions the exemption clauses for removability requirements.

Q: What are the requirements for label as per the new EU Batteries Regulation?

A: In addition to the following labeling requirements, the CE logo is also required after meeting the corresponding test requirements.

Q: What is the relationship between the new EU Batteries Regulation and the existing batteries regulation? Is it mandatory to meet the requirements of both?

A: As Regulation 2006/66/EC will expire on 2025.8.18 and there is a counterpart of trash can logo requirements in the labeling section of the new regulation, thus, both the regulations will be valid and need to be satisfied simultaneously before the old one expiring.

The new EU Batteries Regulation was originally designed to phase out Directive 2006/66/EC (Battery Directive). The EU believes that Directive 2006/66/EC, while improving the environmental performance of batteries and establishing some common rules and obligations for economic operators, has its limitations, for example, it does not address the environmental impact of batteries. The battery recycling market and the market for secondary raw materials from waste batteries does not address envisioned goals for the entire life cycle of batteries. Therefore, new regulations are proposed to replace Directive 2006/66/EC.

And the requirements of the old battery directive are reflected in Article 6 – Substance Restrictions of the New regulation as follows:

Q: What can I do now to comply with the New Battery Regulation?

A: There are no provisions in the new battery regulation that have been implemented yet, and the most

recent implementation is the Restricted Substances Requirement starting from 2024.2.18, for which you can test early.

In addition, requirements of Conformity of batteries in New Battery Regulation (the same as the current requirements for export products to the EU, a self-declaration and CE marking are required) will be implemented from 2024.8.18. Before that, only the technical requirements are needed to meet and the documentation requirements are not mandatory.

In the case of EV/ennergy storage batteries, carbon footprint requirements are also worth noticing. Though the regulations will not implement until 2025, you can operate the internal verification in advance as the certification research cycle for it is long.

If the above Q&A does not solve your problem, please feel free to consult MCM!