The EU Batteries Regulation – a success for the circular economy

The EU Regulation concerning batteries and waste batteries is due to enter into force very soon. The Oeko-Institut conducted research in support of the development process and welcomes the Regulation. In our blog, Dr Hartmut Stahl and Dr Johannes Betz comment on this success.

The adoption of the Batteries Regulation by the European Parliament and the Council is a major success. Due to the rapid growth in the market for batteries, particularly lithium-ion batteries for the e-mobility sector, it is important to respond promptly to the challenges arising in this context. The new European regulation is part of the Circular Economy Action Plan and aims to modernise the EU’s legislative framework for batteries in line with sustainability principles. As the legislation takes the form of a regulation, it is directly applicable and – unlike an EU directive, for example – does not have to be transposed into national law. That is also a welcome step.

Here at the Oeko-Institut, we were involved in, and made significant contributions to, the Regulation’s development. We participated continuously in various ways, from evaluating the existing Batteries Directive to supporting impact assessment and advising the European Commission prior to the final adoption of the Regulation.

Objectives of the Regulation

The EU’s batteries legislation aims to ensure sustainability throughout the entire battery life cycle – from procurement of materials to collection, recycling and reuse of wastes. The new rules are intended to support the development of a competitive and sustainable battery industry in the EU and to promote Europe’s clean energy transition and its shift away from fuel imports. The Regulation aims to strengthen the functioning of the internal market by ensuring a level playing field for all companies in the EU. As comprehensive worker protection and sustainability standards apply throughout the EU, the rules on sustainability may also offer a global competitive advantage.

The EU has agreed the following measures in relation to the future management of batteries:

1. More stringent recycling requirements

The Regulation establishes recovery targets (for specific metals), as well as targets for efficiency increases in battery recycling. Lithium-ion batteries are currently classed as “other batteries” as there is no separate category for them. The minimum recycling efficiency of lithium-ion batteries is therefore just 50% of total weight at present. In addition to increasing overall efficiency, the Regulation sets mandatory targets for recovery of key metals such as cobalt, lead, lithium and nickel.

In addition, far more ambitious collection targets are set for portable batteries, enabling them to be properly collected and recycled rather than being incorrectly disposed of. A new “light means of transport” (LMT) category is also introduced, partly in order to set collection targets for batteries from smaller vehicles such as e-bikes and e-scooters. Both targets will gradually increase over time.

Mandatory minimum levels of recycled content are also stipulated for specific metals in new batteries that are placed on the EU market. The aim is to ensure that the recycled materials are reused in new battery production, thus creating a closed loop.

2. Mandatory supply chain due diligence

The minerals used in battery production nowadays are sourced in global supply chains. In many cases, they are procured from countries with a poor record of compliance with human rights standards and a lack of worker protection. The new Batteries Regulation now requires companies to ensure that no violations of human rights occur during the extraction, transportation and trading of certain metals required for battery production. If such violations occur, the collaboration with the suppliers must be terminated. These standards help to minimise corruption along the supply chain.

3. Calculating greenhouse gas emissions – the carbon footprint

Under the new Batteries Regulation, companies are required to publish their carbon footprints; in addition, they may not – after a specified time period – exceed maximum carbon footprint thresholds across the entire life cycle of batteries. This is to be calculated using the European Commission’s Product Environmental Footprint Method, which specifies how the greenhouse gas emissions of materials, energy and other substances are to be measured.

4. Battery removal and replaceability

According to a further key provision of the Batteries Regulation, it must be possible to remove a battery without destroying the device in future. Batteries must also be designed with replaceability in mind if a product is damaged or reaches end-of-life. Here, the aim is to extend the lifetime of products and reduce their environmental footprint.

5. Positive product-related aspects

Batteries will also have to display labels that provide more detailed information, enabling consumers to make conscious choices more easily in future. With that aim in mind, the battery packaging should carry a QR code giving access to detailed information about the product’s capacity, materials, etc. Other key provisions of the Regulation focus on extending product lifetimes or introduce sustainability rules for public procurement, which will require environmental impacts to be considered in public tendering processes.

More work to do

The Batteries Regulation is a major success for Europe, but its impact is still unclear. Many of the measures will not come into effect for several years, so any changes that occur will not be seen for some time.

Furthermore, some measures are not yet regulated in detail; here, the European Commission will need to adopt further legislation (delegated acts or implementing acts) to deal with aspects such as precisely how the carbon footprint is to be calculated. Unless strict rules are put in place, this measure will be ineffective.

Some measures, such as deposit schemes for larger-sized batteries found in battery-operated power tools and in e-bikes, etc., are absent from the Regulation. Measures such as these would increase the collection rate and reduce the risk of these batteries being disposed of incorrectly. Every year, incorrect disposal of batteries causes hundreds of fires, large and small, at waste disposal companies.


The Regulation achieves various objectives and can therefore serve as a best practice model for other sectors or, indeed, for legislation across the EU as a whole. There is also potential for other countries to use the Regulation as a blueprint for their own legislation.

In sum, the European Union’s new Batteries Regulation is a major milestone in the transition to a sustainable society.

Dr Hartmut Stahl and Dr Johannes Betz are experts on batteries and the circular economy. They are based in the Resources and Transport Division at the Oeko-Institut’s Darmstadt office. Together with other researchers, they conducted various studies on the EU Batteries Regulation.

Further information

Study: Assessment of options to improve particular aspects of the EU regulatory framework on batteries, by the Oeko-Institut, Ramboll and Umweltbundesamt Wien

Study report in support of evaluation of the Directive 2006/66/EC on batteries and accumulators and waste batteries and accumulators, by the Oeko-Institut and Trinomics

Summary of roadmap for the mobility sector: Towards Responsible Sourcing – What’s Next for the Mobility Sector? by the Oeko-Institut as part of the Re-Sourcing Project

What can be done to improve lithium-ion battery recycling? – News (german) from the Oeko-Institut

The new Supply Chain Act – a step forward with potential for improvement – Blog article (german) by Dr Peter Gailhofer

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