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Regulations and Regulatory Framework Necessary for Preparing for Battery EOL, and Recycling

The regulations and frameworks required to prepare for the end-of-life of batteries and their recycling are examined in this article.
A man checking the fron part of an E-Bus.

The EU is presently undertaking the revision of its primary legal framework concerning batteries, with the proposal of a comprehensive Batteries Regulation. The regulation covering the lifecycle of electric vehicle batteries will encompass standards for all types of batteries utilized in electric vehicles. These standards are anticipated to witness increased demand as the European Union shifts away from fossil fuel-powered transport.

The proposed regulation by the European Commission, follows a comprehensive approach, encompassing all stages of a battery’s life cycle to promote a circular supply chain (see Commission’s proposal).

Key obligations to promote circularity include good supply chain, maximum carbon footprint, minimum recycled content, recycling efficiency levels, performance, reporting and labeling requirements, extended producer responsibility for the collection and recycling of used batterie, and a digital battery “passport” to record key events in the battery life cycle. (Sidley Austin LLP, 2022)

The obligations imposed by the proposed regulation vary according to the type of battery: portable, industrial, automotive (for starting, lighting or ignition) and EV.

The proposal defines EV batteries as “any battery specifically designed to provide traction for hybrid and electric vehicles intended for on-road use”.

The commitments, from raw material extraction to disposal, cover the entire life cycle of each battery type. Commitments can be broadly divided into two categories: “upstream” and “downstream” (Sidley Austin LLP, 2022).

Upstream refers to the initial stages of the production process. It typically includes activities such as sourcing raw materials, manufacturing components, and assembling products. Upstream requirements focus on ensuring environmentally friendly practices and resource efficiency during these early stages of production.

Downstream refers to the later stages of the product life cycle, specifically after the product has been used and is ready for disposal and recycling. Other activities include collecting, recycling, and properly disposing of batteries at the end of their useful life. This stage involves activities that occur downstream from the initial use and consumption of the product.

These obligations also apply to producers/manufacturers placing batteries on the EU market with additional compliance obligations, with due care and information for other actors in the supply chain (e.g., distributors, wholesalers, and retailers).

Course Mascot saying "LIB recycling regulations are crucial to minimize environmental costs and maximize reuse of valuable battery materials.!" Course Mascot. PEM Motion (2023)

Requirements for sustainable production at the upstream stage

Batteries are only allowed to be placed on the market in the EU if they meet certain sustainability and safety criteria.

  • Hazardous Substances Prohibition: EV batteries must not contain any hazardous substances. These substances include but are not limited to (the list may be expanded over time) lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBBs), and polybrominated diphenyl ethers (PBDEs).
  • Carbon footprint: As of July 1, 2024, EV batteries must be accompanied by a carbon footprint declaration; as of January 1, 2026, they must carry a label indicating the carbon footprint class; and as of July 1, 2027, they must meet a maximum carbon footprint threshold. (Sidley Austin LLP, 2022)

Signaling with the text "CO2 carbon footprint" with a representation of the earth in the letter O. Carbon Footprint. (n.d.)

  • Recycled content:
    • Beginning January 1, 2027, batteries for electric vehicles must be accompanied by documentation indicating the content of cobalt, lead, lithium, or nickel recovered from waste.
    • By January 1, 2030, electric vehicle batteries must contain a minimum of recycled materials, specifically 12% cobalt, 85% lead, 2% lithium and 1% nickel.
    • Minimum recycled content increases to 20% cobalt, 10% lithium and 12% nickel (lead remains at 85%) effective January 1, 2035. This implies that a higher proportion of these specific materials must be sourced from recycled materials in the production of electric vehicle batteries.

A representation of the recycling symbol in 3D with batteries underneath it. Battery recycling. (2021)

  • Performance and Durability: EV batteries shall be accompanied by the necessary documentation indicating specific electrochemical performance and durability parameters.
  • Labeling: Batteries must carry a “separate collection” label (starting July 1, 2023) and other labels with important battery information, such as shelf life and safety risks (starting January 1, 2027).
  • QR Code: EV batteries must carry a QR code that provides access to (1) all labeling information, (2) carbon footprint and recycled content information, and (3) a declaration of compliance with sustainability and safety requirements. (Sidley Austin LLP, 2022)

Representation of a QR Code with an electric bus icon in te middle. QR Code representation. PEM Motion (2023)

  • Passport for batteries: Batteries in electric vehicles will have to be accompanied by an electronic passport. This passport will be linked to information on the basic characteristics, performance and durability of the battery.
  • Due Diligence: These battery supply chains must be subject to a system of control and transparency verified by a third party, based on international due diligence standards.

All this to identify, assess and mitigate negative impacts in the supply chain associated with the extraction of specific raw materials in relation to a list of social and environmental risk categories.

End-of-life management obligations for batteries in the downstream sector

This proposal introduces a number of end-of-life requirements, in particular for the collection, treatment and recycling of used batteries. Included in these are:

  • Extended Producer Responsibility (EPR): Producers of batteries used in electric vehicles are responsible for managing the entire battery waste stream.
  • End-of-life Information: Producers must provide end-users and distributors with information on the prevention and management of waste batteries, such as the selective collection and reuse/recycling systems available, safety precautions and the impact of the various substances, and the meaning of the labels and symbols that the batteries will carry.

The regulation will also impose environmental standards to ensure responsible recycling. Recycling targets can be met by exporting used batteries, but only if it can be demonstrated that the treatment is carried out in accordance with the requirements of the regulation.


This development presents both opportunities and risks, particularly for automakers, battery manufacturers, and recyclers specifically for the EU. Companies should begin preparing for the new regulations by carefully reviewing their supply chains and operations for potential compliance issues.

Later on, you’ll dive into some fascinating topics about recycling companies in Europe. So stay tuned as you explore these interesting subjects in more detail!


  • Sidley Austin LLP. (2022) European Union a step closer to adopting expansive new rules covering lifecycle of electric vehicle batteries. Retrieved from: Link
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