EU regulation 2023/1542: What are the new battery requirements?

EU regulation 2023/1542: What are the new battery requirements?

The battery sector is undergoing rapid transformation, driven in particular by the development of electric vehicles, energy storage and electricity grid flexibility. To regulate this development and reduce the environmental impacts associated with batteries, the European Union adopted Regulation (EU) 2023/1542 concerning batteries and waste batteries.

The objective is twofold: to reduce the environmental footprint of batteries while strengthening their durability, safety, traceability and circularity.

The new requirements are being introduced progressively, with deadlines extending until 2036. As an EU regulation, it is directly applicable throughout the European Union. The same regulatory requirements, criteria and thresholds therefore apply across the european market, regardless of the country in which the battery is manufactured or placed on the market.

Which batteries are covered?

The regulation applies to batteries placed on the market or put into service in the European Union, regardless of their origin or place of manufacture. It covers batteries sold separately as well as those integrated into appliances or vehicles.

The regulation distinguishes five categories:

    • Portable Batteries: These include batteries used in electronic devices, toys and small equipment.

    • SLI Batteries: Starting, Lighting and Ignition batteries are mainly used for starting, lighting and ignition in vehicles.

    • Light Means of Transport (LMT) Batteries: This category includes batteries used in electric bicycles, electric scooters and hoverboards.

    • Electric Vehicle (EV) Batteries: These are batteries intended to provide traction for electric or hybrid vehicles.

    • Industrial Batteries: This category includes batteries used in industrial applications and energy storage systems.

Carbon footprint: Measuring and reporting battery emissions

The regulation requires manufacturers to calculate the carbon footprint associated with a battery’s life cycle and report it according to a methodology defined at European level.

The carbon footprint is expressed in kgCO₂e per kWh of the total energy supplied by the battery over its expected lifetime. The declaration must specify the carbon footprint associated with the different stages of the life cycle and include information allowing the results to be verified.

What are the deadlines?

The regulation goes further: certain batteries will also have to be classified according to their carbon footprint performance.

For electric vehicle batteries, this carbon footprint performance class requirement is scheduled to apply from 18 August 2026, subject to the conditions relating to the adoption of the relevant European implementing acts. It will then be extended to other categories according to a progressive timetable.

In the longer term, maximum life-cycle carbon footprint thresholds will also be introduced:

    • EV batteries: from 18 February 2028
    • Rechargeable industrial batteries > 2 kWh: from 18 February 2029
    • LMT batteries: from 18 August 2031
    • Industrial batteries with external storage: from 18 August 2033

For manufacturers, the challenge is therefore to anticipate the collection of environmental data across the entire supply chain.

Dates
Entrepôt STEF à Nevian
batterie

Mandatory recycled materials

The regulation gradually introduces requirements regarding the amount of recycled raw materials used in certain batteries.

The materials concerned are:

    • Cobalt
    • Lead
    • Lithium
    • Nickel

A first step from 2028

From 18 August 2028, certain batteries will have to be accompanied by documentation indicating the share of materials recovered from manufacturing waste and post-consumer waste. This requirement applies in particular to:

    • Industrial batteries > 2 kWh, excluding batteries with exclusively external storage;
    • Electric vehicle batteries;
    • SLI batteries.

It will be extended to LMT batteries from 18 August 2033.

Minimum rates from 2031

From 18 August 2031, the relevant industrial batteries > 2 kWh, EV batteries and SLI batteries will have to comply with the following minimum recycled material content rates:

Recycle rates

From 2036, these strengthened targets will also apply to the relevant LMT batteries.

Note: 2028 therefore corresponds to the requirement to document recycled content, while minimum rates become mandatory from 2031 and are then increased in 2036.

Durability and performance: batteries designed to last

The regulation also introduces minimum requirements for electrochemical performance and durability.

Since 18 August 2024, rechargeable industrial batteries with a capacity above 2 kWh, light means of transport (LMT) batteries and electric vehicle batteries have been required to be accompanied by information relating to their performance and durability.

From 18 August 2027, rechargeable industrial batteries above 2 kWh, excluding batteries with exclusively external storage, will have to comply with minimum performance and durability values defined at European level.

General-purpose portable batteries will also be subject to minimum performance and durability requirements from 18 August 2028, excluding button cells.

The objective is to promote batteries with a longer service life and sustained performance over time, in order to limit premature replacement and waste generation.

Repairability: making batteries easier to remove and replace

The regulation also introduces important requirements concerning the design of products incorporating batteries.

Portable batteries

From 18 February 2027, portable batteries incorporated into products will, except where otherwise provided for by the regulation, have to be designed in such a way that they can be removed and replaced by the end-user throughout the entire lifetime of the product.

Instructions and safety information relating to the use, removal and replacement of the battery must also be made available.

LMT batteries

For products incorporating LMT batteries, the batteries and the cells within the battery pack must be removable and replaceable by an independent professional throughout the lifetime of the product.

This development therefore encourages a design approach focused more on:

repair → replacement → reuse → second life → recycling

rather than replacing the entire product.

    batterie
    Marquage batterie

    Safety: strengthened requirements

    The regulation also strengthens requirements relating to battery safety and the restriction of certain hazardous substances.

    Harmonised limits are notably provided for:

      • Mercury: 0.0005% maximum by mass
      • Cadmium: 0.002% maximum by mass
      • Lead in portable batteries: 0.01% maximum by mass from 18 August 2024

    The regulation also provides for specific safety testing requirements, particularly for stationary energy storage systems.

    The objective is to ensure that batteries remain safe during their manufacture, use, storage, transport, dismantling and recycling.

    Labelling, CE marking and traceability

    The regulation strengthens the amount of information available on batteries.

    Since 18 August 2024, batteries have been required to bear the CE marking, certifying their compliance with the applicable European requirements.

    More detailed labelling requirements are also being introduced progressively to provide information about the battery, including its capacity, performance, composition and end-of-life management.

    The battery passport: a new digital identity

    One of the most significant changes is the introduction of the digital battery passport.

    From 18 February 2027, every:

      • LMT battery;
      • industrial battery with a capacity above 2 kWh;
      • electric vehicle battery;

    placed on the market or put into service in the European Union will have to have a digital Battery Passport.

    The Battery Passport will be associated with the battery and provide access to various types of information, including:

      • Model identification;
      • Composition and origin of raw materials;
      • Carbon footprint;
      • Performance and lifetime;
      • Recycled material content;
      • Traceability information;
      • Information required for dismantling, repair and recycling.

    Some information will be publicly accessible, while other information will be reserved for authorities, notified bodies or actors with a legitimate interest.

    The Battery Passport will therefore become a key tool for traceability and transparency throughout the value chain.

    Passeport batterie

    End-of-Life management and extended producer responsibility

    Finally, the regulation does not stop at manufacturing.

    It also strengthens requirements relating to the collection, treatment and recycling of waste batteries.

    Collection targets are notably provided for portable batteries and LMT batteries:

    Illustration taux de recyclé

    The regulation also introduces material recovery targets:

      • Lithium: 50% by the end of 2027 and 80% by the end of 2031;
      • Cobalt, copper, lead and nickel: 90% by the end of 2027 and 95% by the end of 2031.

    This approach is based on the principle of Extended Producer Responsibility (EPR): producers and other relevant stakeholders must contribute to the management of batteries at the end of their life.

    Regulation (EU) 2023/1542 marks a major change in European battery regulation. It progressively transforms batteries into products whose compliance must be demonstrated throughout their entire life cycle, rather than only at the time they are placed on the market.

    Wa are here to support you

    Would you like to prepare your company for the requirements of Regulation (EU) 2023/1542 or develop an environmental approach tailored to your challenges? Contact our team of experts for personalised support: contact@pink-strategy.fr

    LCA of a storage project: How to assess its environmental benefits?

    LCA of a storage project: How to assess its environmental benefits?

    Energy storage has become an essential pillar of our energy transition and provides a solution to the challenge posed by the intermittency of renewable energy. However, assessing the carbon footprint of a storage facility over its entire life cycle (whether it is stand-alone, coupled with a power generation plant, or used for self-consumption) proves to be a real challenge. How can we demonstrate that an asset that does not produce energy (and even loses some) can be environmentally friendly?

    This is one of the main topics within energy storage. If we focus solely on the manufacturing of the system (lithium-ion cells for batteries, for instance) and its installation, the carbon footprint is inherently positive (meaning it emits greenhouse gases – GHG). Yet, if the project is properly scaled and intelligently managed, the environmental benefits over its entire lifespan more than offset this initial footprint.

    The challenge for project developers is therefore to evaluate this “carbon savings” through a Life Cycle Assessment (LCA) of their project. To do this, we must look beyond the battery itself and focus on what it helps avoid. Let’s explore how to assess and highlight the carbon footprint of your installations.

    Assessing avoided emissions

    Once the facility’s carbon impact has been calculated, we can quantify its avoided emissions. Be careful: this does not mean mathematically subtracting these emissions from the project’s carbon footprint to display an artificially zero footprint. The battery will always have its own impact. The correct approach consists instead in comparing our project to a “reference scenario” (what would happen on the grid if this project did not exist?). It is through this comparison that we can demonstrate the overall environmental benefit of the project.

    Indeed, the most common mistake when assessing the environmental impact of a storage project is to omit its use phase. A battery is a flexibility asset: its purpose is not to generate electricity, but to shift its use in time relative to when it was produced. It is through this role that GHG emissions can be avoided.

    The idea is simple: how much CO2e has the project prevented from being released into the atmosphere through its operation? To calculate and highlight this, it is essential to understand the environment and the usage scenario of the installation. Let’s have a look at the following two examples, which are common setups for storage facilities:


    Scenario 1: Integration with a solar photovoltaic plant: the hunt for curtailment
    Let’s imagine that our project involves a battery integrated with a solar photovoltaic plant. During production peaks, the grid is sometimes unable to absorb all the electricity generated by the facility. National or even European demand may be lower than production. In such cases the plant’s electricity output must then be limited to avoid negative prices (where the producer has to pay to produce). The photovoltaic installation will then curtail (cap) its production, leading to a loss of renewable electricity.


    When these situations occur on a facility coupled with a storage solution, the system will store this surplus electricity that would otherwise not have been produced. By feeding it back into the grid in the evening, when demand is higher, it injects 100% renewable electricity at a time when thermal power plants might have been fired up to meet demand. The environmental benefit here is direct: we maximize the production of renewable electricity that would otherwise have been wasted while limiting the activation of polluting thermal plants.

    Scenario 2: A grid-connected battery (Stand-alone)

    If the battery is simply connected to the national power grid for trading (buying/selling), the logic is different but equally valuable. And this is where the excellent news comes in: the economic optimum is (almost always) aligned with the environmental optimum. In the energy market, electricity is cheapest (or even negatively priced) when it is abundant, that is, when wind turbines and solar panels are producing. Conversely, it is expensive in the evening, during peak consumption hours, because the grid must turn on backup thermal (gas) plants to supply the electricity needed to meet demand.

    By charging at low cost, the battery stores electricity that is very often produced by renewables and has a very low carbon intensity. By discharging at a higher price, it prevents the grid from starting up thermal plants that run on fossil gas. The emissions avoided by the project therefore correspond to the difference between the emissions of the avoided fossil source and the low emissions of the stored renewable energy.

    By comparing the project’s avoided emissions to its net emissions, we can determine if the facility is virtuous from a carbon point of view. Indeed, if the emissions avoided by the project are greater than the emissions generated over its life cycle, then the project can be considered environmentally beneficial.

     

    Entrepôt STEF à Nevian
    équipe PINK STRATEGY

    Different scenarios: The importance of time granularity

    We have seen that to highlight the carbon benefit of a storage project, we must look at its avoided emissions. To account for these, using an annual average of the French grid’s carbon intensity (around 31 gCO2e/kWh in 2025 according to Electricity Maps) to calculate a project’s carbon impact doesn’t really make sense. Because electricity generation sources and the grid’s carbon intensity vary constantly, the environmental footprint of a storage project plays out on a much finer time scale!

    Thus, to model avoided emissions relevantly, the project analysis must be performed using the finest possible time granularity (hourly, or even down to the quarter-hour or minute). This is the only way to accurately overlay the battery’s charge/discharge curve with the national grid’s carbon intensity curve. Above a certain level of precision, the analysis of avoided emissions loses its meaning.

    This methodology is supported by french leading institutions like ADEME. All scenarios (from ADEME, RTE, CRE, etc.) show that the massive deployment of renewables in France will require tens of gigawatts of flexibility (including storage projects), and that their environmental assessment must absolutely take into account this temporal dynamic of the electricity mix.

    Specific constraints: Why is every project unique?

    If we insist on precise modeling of the operating scenario, it is because each project is tied to its own specific industrial and economic context. The valuation of a project’s environmental footprint must therefore reflect its specific context.

    Take the example of a company that couples its solar panels, its battery, and the charging stations (EVSE) for its electric vehicle fleet. The energy management system (EMS) algorithm will not just seek the financial optimum on the grid. It will have to respect an operational constraint: “The vehicles plugged into the charging stations must absolutely be recharged to 80% before 5:00 PM for the employees’ end of the day.” This constraint will force the battery to discharge at a specific time to power the cars, thereby altering its natural charging profile. In return, the system could use compatible vehicles (V2G – Vehicle-to-Grid) as additional storage capacity! This is exactly why the carbon footprint of every storage project is unique. There is no universal magic formula: the balance depends on geographic location, market prices, the storage technology used and its capacity, and above all, local usage constraints and the charge/discharge and integration scenario.

    équipe PINK STRATEGY

    Modeling for better valuation

    Highlighting the environmental gain of a storage system is a complex exercise, but one with real value. Whether it is to meet your CSR obligations, secure green financing, or simply validate the relevance of your investment, performing a Life Cycle Assessment of your storage project makes perfect sense. While batteries are often criticized, you must be able to prove that the impact of their manufacturing and installation will be fully offset by the emissions avoided over their lifespan.

    Do you have a storage project and want to conduct a detailed analysis of its operational cycle and environmental impact (emissions avoided, hourly modeling, optimization of usage)?

    We are here to guide you

    Contact us to assess your project’s potential and maximize your benefits over its entire lifespan!