The EU Battery Regulation: Where we stand in 2025

Early lessons learned since implementation

However, even during this first phase, companies have encountered practical challenges. Three issues stand out:

• Battery classification: The Batteries Regulation introduces new types of batteries, including portable, industry, electric vehicle (EV), light means of transport (LMT), and starting, lighting, and ignition batteries (SLI). The extent and timeline of obligations depend on correct classification, and this is not always straightforward. The most frequent challenge is distinguishing between portable and industrial batteries, but misclassification can also occur with other categories. An incorrect classification can lead directly to non-compliance, or to companies applying obligations that do not actually apply to them.
• Legal role identification: Determining who is the “producer” and the “manufacturer” under the Regulation is complex, particularly in cross-border supply chains or for non-EU companies selling into the EU. Misinterpretation can delay registration in national registers and expose companies to compliance risks.
• Value chain communication: Companies sometimes struggle to obtain necessary information from suppliers or the knowledge to respond to compliance requests from B2B customers. These gaps in communication can slow down conformity assessment, create uncertainty about responsibilities, and even potentially negatively affect business relationships.

These early lessons highlight that the foundations of compliance are not always straightforward. As new requirements are phased in, today’s uncertainties can easily multiply, making it all the more important to establish clarity early.

Key regulatory updates

The past year brought several important changes to the implementation of the Battery Regulation. It is important to note that the application of many obligations depends on certain by-laws, or Delegated and Implementing Acts, due for adoption by the EU Commission. This creates a moving timeline that companies must track closely.

Omnibus IV and due diligence obligations

The Battery Regulation requires companies to establish supply chain due diligence policies covering human rights and environmental risks. Under an EU focus for more competitiveness for industry, the Omnibus IV legislative package has been adopted, postponing the start of these obligations by two years to August 2027. Further guidance from the Commission is expected in 2026.

Although the delay provides more time, experience from other sectors shows that building due diligence systems, from risk mapping to supplier engagement and reporting, is complex and resource-intensive. Companies that wait until 2027 may struggle to set up credible processes in time.

Carbon footprint requirements

The Regulation establishes a three-stage approach to carbon footprint obligations for electric vehicles, industrial, and light means of transport batteries, and each has its own timeline:

• Declaration of carbon footprint data.
• Labelling with carbon footprint information and performance classes.
• Thresholds that must not be exceeded.

In practice, these obligations depend on delegated and implementing acts defining methodology, declaration format, and thresholds. For EV batteries, the first acts should have been adopted in February 2024, which would have triggered the first declarations one year later. Drafts were published for consultation in spring 2024, but since then no final acts have been adopted.

• Batteries – the format for carbon footprint declaration
• Batteries for electric vehicles – carbon footprint methodology

This means the legal compliance clock has not yet started. Once acts are adopted, deadlines will follow quickly, leaving 12 months preparation time. By then, companies should not wait. After all, understanding the general requirements, checking the company internal data required for carbon footprint calculations, and getting in touch with suppliers takes considerable lead time.

Removability and replaceability

From February 2027, products with portable batteries must ensure that these can be readily removed and replaced by the end-user using commercially available tools. For LMT, batteries must be removable and replaceable by an independent professional. Manufacturers must also guarantee spare part availability for five years.

In January 2025, the Commission published guidelines clarifying what counts as being readily removable and how exemptions, such as those for waterproof appliances or certain medical devices should be interpreted. A first round of applications for further exemptions is currently under review, and an extension of derogations is expected in 2026.

Although some products may already comply or can achieve compliance with relatively minor adjustments, in other cases redesign or re-engineering may be needed – a process that can take several years. Companies should therefore assess their product portfolios early and thoroughly to avoid time pressure closer to 2027.

Performance and durability requirements

Already since August 2024, batteries must be accompanied by documentation on electrochemical performance and durability parameters, such as capacity, power fade, and internal resistance. Minimum values for these parameters will only apply from 2027, once the Commission concludes its technical studies and adopts delegated acts.

Digital battery passport

From 2027, all batteries placed on the EU market will require a digital battery passport accessible through a QR code. The passport is intended to increase transparency on composition, performance, and sustainability. However, important questions remain to be clarified, particularly concerning access rights to commercially sensitive information. The Commission is conducting studies to determine how legitimate interest and data sensitivity should be handled.

2025–2026: What companies should expect

The next two years mark the shift from familiar obligations to the groundwork for more complex requirements. While the legal framework for batteries remains stable, companies will face both new compliance tasks and the challenge of keeping pace with evolving secondary legislation.

• Labelling: Extended labelling rules apply to more battery types, including chemical symbols, capacity information, and collection markings.
• Conformity assessment: CE marking and conformity procedures cover a broader set of batteries, requiring manufacturers to maintain complete technical documentation.
• Producer registration: From 18 August 2025, producers established in the EU must register directly in each Member State where they place batteries on the market for the first time. Producers established outside the EU are required to appoint an authorised representative for extended producer responsibility in every Member State where they place batteries on the market. Producers also need to either join a Producer Responsibility Organisation (which takes care of collection and recycling of waste batteries) or, where legally allowed, organise an individual take back of the batteries placed on the market.
  In practice, some national systems are yet in transition to be fully aligned with the EU framework. For example, in Germany, the national legislation completing the EU Batteries Regulation (called Batteriedurchführungsgesetz) was only been adopted in September 2025. The German environment ministry (BMUV) has confirmed that compliance with these new obligations will not be enforced until the end of 2025, and companies can register in a simplified manner during the transition period.

These measures remain relatively familiar, but they widen the scope of compliance and increase the administrative burden across multiple markets.

• Carbon footprint: Although thresholds have been postponed, companies should be advanced by setting up systems for CO2 related data collection and life-cycle modelling by 2026.
• Due diligence: Obligations only start in 2027, but mapping supply chains and building internal procedures takes time. The guidance document to be published by February 2026 will provide more details.
• Delegated acts and guidance: A distinctive feature of the Battery Regulation is its reliance on secondary legislation. Almost every major obligation depends on a delegated act, implementing act, guideline, or study. This level of dependence is unusual in EU product law and makes compliance tracking significantly more complex. For companies, following the evolving set of acts is as important as understanding the Regulation itself.

How we can support you

The Battery Regulation sets out a long and evolving compliance journey. Even the first obligations – labelling, registration, CE conformity – have shown how easily uncertainty can arise, whether in product classification, role identification, or communication along the value chain. And with carbon footprint, due diligence, and recycled content requirements still ahead, the complexity will only increase.

At Ramboll, we support companies and industry associations across Europe and internationally in navigating this complexity. Our services include:

• Regulatory monitoring and interpretation – keeping track of delegated acts, guidelines, and national implementation measures.
• Role and responsibility mapping – clarifying whether you are a producer, importer, distributor, or another actor under the Regulation.
• Compliance planning and documentation – from CE conformity procedures to due diligence policies and data management.
• Engagement along the value chain – helping you obtain information from suppliers and respond to customer requests.

If you are facing uncertainties, or want to prepare strategically for upcoming obligations, we are ready to support you. Get in touch with us to discuss your specific situation, and we can figure out how to turn compliance into an advantage for your business.