EU Battery Regulation (EU) 2023/1542 Full Guide: The Latest Version in 2026, Must See for Exporting to the EU

 EU Battery Regulation (EU) 2023/1542 Full Guide: The Latest Version in 2026, Must See for Exporting to the EU

1、 What is the new Battery Regulation (EU) 2023/1542?

In July 2023, the European Union officially released the "Battery and Waste Battery Regulation" (EU) 2023/1542, which fully replaces the 2006/66/EC Battery Directive that has been in use for over a decade.

What does it mean to change from 'directive' to 'regulation'? Simply put, in the past, it was a directive and each member state translated and implemented it themselves, with inconsistent standards; Now it is a regulation, directly implemented uniformly throughout the entire EU, without any room for negotiation.

This regulation covers the entire lifecycle of batteries, from production, sales, use, to waste recycling, all of which are subject to regulation.

Types of batteries covered (5 major categories):

·Portable batteries: batteries in mobile phones, power banks, Bluetooth earphones, handheld game consoles, weighing no more than 5 kilograms

·Light Transport Vehicle Battery (LMT Battery): Battery for short distance transportation vehicles such as electric bicycles and electric scooters

·Starting, Lighting, and Ignition Battery (SLI Battery): Automotive Starting Battery

·Industrial batteries: batteries used in large data centers, telecommunications base stations, and factory assembly lines, weighing over 5 kilograms

·Electric vehicle battery: a power battery used for various types of electric vehicles

2、 What are the core requirements of the new regulations to focus on in 2026?

The requirements of the new regulations are implemented in stages. As an exporter, you need to focus on the following time points and requirements:

1. Restriction of harmful substances (basic, to be done now)

The new regulations have strict restrictions on harmful substances in batteries, which is the most basic testing item:

Explanation of Material Limit Values

Mercury (Hg) 0.0005% (5ppm) for all batteries, regardless of type

Cadmium (Cd) 0.002% (20ppm) portable battery (exempted)

Lead (Pb) 0.01% (100ppm) will be implemented from August 18, 2024

Attention: The limit for lead is 0.01%, which is 10 times stricter than RoHS's 0.1% limit! If your battery contains more than 0.01% lead, it does not comply with the new regulatory requirements.

Reference price for testing package: Lead+Cadmium+Mercury three item testing, starting from 450 yuan

2. Labeling and identification requirements (fully implemented from August 2025)

Starting from August 18, 2025, all batteries sold in the European Union must meet the new labeling requirements:

·The crossed wheel trash can symbol: All batteries must have this symbol to remind consumers not to dispose of them at will

·Heavy metal symbols: If mercury, cadmium, and lead exceed the limit values, the corresponding chemical symbols (Hg, Cd, Pb) must be marked below the trash can symbol

·Battery capacity labeling: Portable batteries must be labeled with capacity

·QR code: Some batteries require a QR code, scan the code to view the battery passport information

Where should the label be printed?

In principle, it should be directly printed on the battery body. If the battery is too small to fit, it can be printed on the packaging or in the accompanying documents.

3. Extended Producer Responsibility (EPR) registration (starting from August 2025)

Many sellers tend to overlook this. Starting from August 18, 2025, if you sell batteries or products with batteries to the European Union, you are required to register as a producer in each selling country and assume financial responsibility for the collection, treatment, and recycling of used batteries.

Simply put, you need to pay for local companies in the European Union to help you recycle used batteries.

This registration is not one-time and requires payment every year. The cost is calculated based on the quantity and type of products you sell.

4. Carbon footprint statement (for some batteries)

For electric vehicle batteries, industrial batteries with a capacity exceeding 2kWh, and light vehicle batteries, carbon footprint data needs to be disclosed from August 2024. After 2026, these batteries will still need to be labeled with carbon footprint performance levels.

If you don't make this type of battery, don't worry about it for now.

5. Requirements for Disassembly and Replacement (February 2027, not yet arrived but should be noted)

This is currently the most discussed topic. According to Article 11 of the new regulation, after February 18, 2027, all portable batteries sold in the European Union must be designed to be "removable and replaceable by the end user".

What does this mean?

·Mobile phones, Bluetooth earphones, power banks, and electric toys - the batteries of these products cannot be firmly glued together with glue anymore

·Special tools (such as specialized screwdrivers) cannot be used to open, only "commercially available tools" (regular screwdrivers are sufficient) should be used

·Cannot use software to prevent users from replacing compatible batteries

Which products can be exempted? There are mainly two types:

·Products mainly used in humid environments (such as electric toothbrushes and razors) may pose safety risks if users replace the batteries themselves

·Specific professional medical equipment (such as pacemakers)

February 2027 hasn't arrived yet, but friends who are currently engaged in product design are already starting to consider it.

3、 How to conduct testing? What is the process?

Step 1: Confirm your battery type

·Is it a portable battery (power bank, Bluetooth headset, mobile phone)?

·Or industrial batteries (energy storage power supply, UPS)?

·Or light vehicle batteries (electric bicycles)?

Different types have different detection focuses.

Step 2: Select the testing items

Basic package (all batteries must be included):

·Mercury, cadmium, and lead content detection

·Reference price: 450-800 yuan

Advanced package (depending on customer requirements):

·If the customer requests "compliance with the new EU battery regulations", it is recommended to conduct a comprehensive testing, including hazardous substances, label review, and technical document review

·Reference price: 2000-4000 yuan

Attention: If the battery is assembled into a battery pack with battery cells, the entire pack needs to be sent for testing. The sample size is generally: 1 battery pack (represented by battery cells, 1 battery cell)

Step 3: Sample testing

·Sample size: typically 5 complete batteries (or battery packs)

·Testing cycle: 5-7 working days

·Urgent: About 3 days, urgent fee of 500-1000 yuan

Step 4: Produce a report

The report does not have an expiration date, but if there are changes in battery materials, processes, or regulatory updates, it needs to be redone.

4、 Under what circumstances must it be done?

1. Your product comes with a battery and is sold in the European Union

Whether you are selling power banks, Bluetooth earphones, electric toothbrushes, or children's toys, as long as the product contains a battery, the battery itself must comply with the new regulations.

2. The customer requests a battery report

Many EU buyers will separately request compliance reports for batteries when purchasing products. This is their procurement compliance process, it cannot be avoided.

3. You are a battery manufacturer

If you specialize in exporting batteries, this regulation is mandatory.

5、 Finally, let me say a few words

The new EU Battery Regulation (EU) 2023/1542 has replaced the old Battery Directive and has been in effect since February 2024. Many people are still stuck in the old impression of the "Battery Directive 2006/66/EC", but customs and platforms have long started to investigate according to the new regulations.

I have handled a case where a customer made Bluetooth earphones and had both CE and RoHS reports, but the battery was not tested separately. The goods arrived at German customs and were found to have a lead content of 0.05% in the battery (which was not required by the old directive). According to the new regulations, the lead content exceeded the standard and the goods were confiscated. Finally, it took more than a month to complete the testing, rectification, and reapplication.

So my suggestion is simple:

·If your product is sold to the EU with batteries, it is recommended to undergo basic testing for the new battery regulations (mercury+cadmium+lead)

·If the customer or platform has stricter requirements, conduct a comprehensive inspection

·The requirement for "detachable" in 2027 has not yet arrived, but those who design products now can lay out their layout in advance

I have compiled a 'EU Battery Regulation Testing Avoidance Checklist', which includes a comparison of new and old regulations, recommendations for testing items for different battery types, label templates, and EPR registration processes.