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Details
- European Union
The EUBR applies to all economic operators in the battery supply chain, including manufacturers, importers, distributors, and recyclers placing batteries on the EU market.
Deep dive
Background
The EU Battery Regulation (EUBR), formally adopted as Regulation (EU) 2023/1542, was announced in July 2023 and entered into force on 17 August 2023, replacing the 2006 Batteries Directive (2006/66/EC). This landmark legislation aligns with the European Green Deal and the Circular Economy Action Plan, aiming to reduce the environmental and social impacts of batteries across their entire lifecycle—from raw material sourcing to end-of-life recycling. Unlike its predecessor, the EUBR is a directly applicable regulation (not a directive), ensuring uniform implementation across all EU member states without national transposition. It introduces stringent sustainability measures, including carbon footprint disclosure, recycled content mandates, and due diligence for critical minerals, reinforcing the EU’s commitment to climate neutrality by 2050.
Reporting Requirements
The EUBR imposes rigorous carbon footprint reporting obligations on manufacturers, requiring them to calculate and declare emissions for each battery model at each production site, expressed in kilograms of CO₂ equivalent per kilowatt-hour (kWh) of energy capacity. Starting February 2025, electric vehicle (EV) batteries must disclose their carbon footprint, followed by industrial batteries (February 2026) and light transport (LMT) batteries (August 2028). Companies must use primary data for manufacturing processes and adhere to the Product Environmental Footprint (PEF) methodology, with verification by notified bodies. Additionally, by 2027, batteries must include a digital passport with lifecycle emissions data accessible via QR code, enhancing transparency for consumers and regulators. Complying with the EUBR requires the collection, calculation, and reporting of detailed carbon data for each battery model and production facility. Product Carbon Footprinting (PCF) software such as ISI's Sustainability Tracker can manage thousands of data points and complex PEF-based methodologies, ensuring traceable, auditable, and EUBR-compliant carbon disclosures.
Consequences of Noncompliance
Failure to meet EUBR requirements can result in market exclusion, fines, or product recalls 10. For instance, batteries lacking a CE mark, carbon footprint declaration, or passport after the deadlines (e.g., 2027 for passports) will be banned from sale in the EU. Noncompliant companies risk reputational damage and legal penalties, particularly under the regulation’s "no compliance, no market access" principle. By enforcing these rules, the EU aims to drive industry-wide decarbonization and circularity, with stricter recycling targets (e.g., 50% lithium recovery by 2027) incentivizing compliance.
Enforcement Outlook
Implementation Challenges
While no formal court cases have emerged under the EUBR, several implementation challenges have surfaced. Industry groups like EUROBAT, for example, have flagged concerns around the carbon footprint methodology, specifically the requirement to calculate emissions per "functional unit" and verify data for each plant and model—a process some say is unnecessarily granular, especially at the batch level. More recently, the debate extended to whether to base lifecycle emissions on actual electricity consumption or on national grid averages, with manufacturers from carbon-intensive countries such as Germany arguing the latter unfairly penalizes them.
Current Status
As of mid-2025, national authorities are embedding carbon-footprint verification into enforcement frameworks. Notified bodies tasked with validating carbon footprint declarations are being appointed, though several Member States are still completing accreditation. Battery producers, covering EV, industrial (> 2 kWh), and LMT types, are preparing PEF-based carbon-footprint reports, capturing emissions per model and manufacturing site. Starting February 2025, EV batteries must come with third-party verified carbon footprint declarations and labels, available via the battery passport or accompanying documentation.
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