News & Insights

EU Battery Regulation (EUBR)

A lifecycle approach to every battery

The EU Battery Regulation (EUBR) applies to all batteries placed on the EU market, whether sold on their own or built into products. It groups batteries into five categories:

From sourcing of raw materials through manufacturing, use, reuse and end-of-life, the Regulation introduces requirements that affect product design, data systems, supply-chain management and recycling operations.

Carbon footprint and recycled content become mandatory

One of the most important innovations is the introduction of a carbon-footprint framework for EV, LMT and rechargeable industrial batteries above 2 kWh. This will be phased in through three steps:

1. Carbon-footprint declarations

2. Performance classes

3. Maximum carbon-footprint thresholds

Minimum Recycled Content Requirements for BatterieS

The regulation sets mandatory minimum shares of recovered metals in the active materials of certain battery types.

From 2031, for industrial, SLI, and EV batteries: 

16 % cobalt 
85 % lead
6 % lithium
6 % nickel

From 2036, for industrial, SLI, EV, and LMT batteries:

26 % cobalt
85 % lead
12 % lithium
15 % nickel 

Digital battery passports and new labelling rules

From February 2027, EV, LMT, and industrial batteries over 2 kWh must have a digital battery passport, accessible via a QR code. This passport will contain information on:

  • Battery composition
  • Carbon footprint
  • Performance and durability
  • Repairability and end-of-life handling

Designing batteries for removal, repair and reuse

The Regulation also tackles one of the key barriers to circularity: batteries that are hard or impossible to remove. By 18 February 2027:

  • Portable batteries in products must be readily removable and replaceable by the end-user using commonly available tools.
  • LMT batteries must be readily removable and replaceable by independent professionals.

These requirements are intended to support repair, refurbishment, safety and second-life use, and to prevent valuable batteries from being lost inside products that are discarded too early.

New due-diligence obligations for critical raw materials

For companies above defined turnover thresholds, the EUBR introduces mandatory supply-chain due diligence for critical raw materials including cobalt, lithium, nickel and natural graphite. This includes:

  • Risk assessment of human-rights and environmental impacts
  • Risk-mitigation measures
  • Independent third-party verification

Higher collection and recycling targets

The Regulation significantly raises expectations for what happens when batteries reach the end of their life. For portable batteries, collection targets will rise to:

  • 63% by 2027
  • 73% by 2030

For LMT batteries, collection targets will be:

  • 51% by end-2028
  • 61% by end-2031

Recyclers must also meet stricter requirements for recycling efficiency and material recovery for cobalt, lithium, nickel, copper and lead. At the same time, the Regulation actively supports repurposing and second-life applications, helping extend battery lifetimes and reduce pressure on virgin raw materials.

Performance, durability and safety move to the forefront

Minimum performance and durability standards will be introduced for rechargeable industrial batteries over 2 kWh and later for portable batteries of general use. This ensures that batteries placed on the EU market deliver longer lifetimes and reliable real-world performance. Specific safety requirements also apply to stationary battery energy storage systems (SBESS), reflecting their growing role in Europe’s energy transition.

Stronger producer responsibility and enforcement

Extended producer responsibility (EPR) remains at the core of EU battery policy, but the EUBR creates a more harmonised and enforceable framework applicable from 18 August 2025. Producers must:

  • Register in each Member State where they place batteries on the market
  • Finance and organise collection and treatment
  • Provide information to end-users
  • Report data to authorities

These obligations are backed by stronger market-surveillance powers, increasing the importance of compliance and accurate reporting.

Share article