BATTERIES REGULATION
EU Batteries Regulation (BattVO): Obligations, Labelling and Conformity for Batteries
The EU Batteries Regulation (BattVO) governs the placing on the market, labelling, safety, carbon footprint, life cycle as well as the take-back and disposal of batteries throughout Europe. It applies directly in all EU Member States, with the national Batteries Act (BattG) taking a back seat. A key innovation is that the Regulation is much broader in scope and is linked to chemicals legislation, unlike the previous regulations, which were essentially aimed at take-back procedures for waste batteries. The aim of the Regulation is greater transparency, better reuse, a higher collection rate and a sustainable supply chain for all battery types.
Scope of the Batteries Regulation and Key Changes
Scope of Application, Definitions and Distinction from the Batteries Act (Batteriegesetz/BattG)
The Batteries Regulation applies to all batteries, rechargeable batteries and battery-powered products, including portable batteries, industrial batteries, starter batteries and electric vehicles. Accordingly, the EU Regulation permeates a large number of different market sectors, some of which are in turn subject to their own applicable regulations. In contrast to the previous Batteries Act, the Regulation contains significantly extended obligations, particularly with regard to labelling, conformity, carbon footprint, removability and reuse.
Entry into Force, Transition Periods and Implementation in the EU Member States
The EU Regulation applies directly, but is implemented via staggered deadlines. These deadlines are essentially based on the size and economic relevance of the different battery types. The entry into force of individual requirements concerns, among other things, labelling obligations, conformity assessment and due diligence obligations in the supply chain.
Economic Operators and Producer Responsibility
Manufacturers, Importers, Distributors, Authorised Representatives
Under the Batteries Regulation, economic operators are manufacturers, importers, distributors and their authorised representatives. Anyone who places batteries on the market in the EU for the first time is legally a producer and bears producer responsibility.
Placing on the Market, Obligations & Commitments Along the Supply Chain
All operators must ensure that only compliant batteries with valid labelling, safety information and a declaration of conformity are placed on the market. The obligations apply along the entire supply chain.
Registration, Declaration/Declaration of Conformity and Compliance with the Regulation
Registration is required before placing on the market. In Germany, the “stiftung elektro-altgeräte register” (ear) has been entrusted with this task by the authorities. In addition, a formal declaration of conformity must be issued confirming compliance with all provisions of the Batteries Regulation.
Battery Types, Products and Requirements Across the Life Cycle
Portable Batteries, Industrial Batteries, Starter Batteries, Electric Vehicle Batteries
The BattVO distinguishes between several battery types, for which different requirements regarding safety, performance, durability and recycling apply.
Rechargeable Batteries, Durability and Performance/Safety Requirements
Rechargeable batteries must meet defined limit values for performance, durability and safety, particularly in the case of lithium batteries.
Battery Management System (BMS) and Safety-Relevant Information
For complex batteries, a battery management system is required that monitors states of charge, safety and protection against malfunctions.
Labelling and Labelling Obligations
Labelling, Symbols, Carbon Footprint and Transparency Requirements
Under the Batteries Regulation, the labelling must include, among other things, information on the carbon footprint, recyclability and reuse, thereby creating transparency for the market and end users.
Battery Type, Series/Product or Type Reference, Safety Information on the Product
Every battery must be clearly labelled, including battery type, product reference and mandatory safety information.
Due Diligence Obligations in the Supply Chain
Raw Material Sourcing, Producers/Production and Evidence in the Supply Chain
Special due diligence obligations and evidence requirements regarding production and origin apply to critical raw materials such as lithium.
LV/Guidelines, Internal Implementation and Documentation
Companies must establish internal processes for implementing the LV requirements and for documenting the supply chain.
Collection, Take-Back, Reuse and Repurposing
Collection Points, Collection Rate, Take-Back Systems and Disposal/Recycling
Manufacturers and distributors must provide collection points and take-back for waste batteries. The collection rate is mandatory.
Reuse, Repurposing (Second Life) and Recovery Obligations
The BattVO prioritises reuse, repurposing and high-quality recycling over disposal.
Conformity Assessment Procedures and Market Surveillance
Conformity, Conformity Assessment Procedures, Testing/Verification Processes
Under the Batteries Regulation, conformity is demonstrated by means of a regulated conformity assessment procedure.
Market Surveillance Authorities, Rules/Regulations and Enforcement
National market surveillance authorities check compliance with the rules and can withdraw products from the market.
Technical Requirements & Testing Reference (Our Services)
Safety and Performance Testing
Testing ensures that lithium batteries and other products meet the safety and performance requirements.
Labelling/Document Checks, Carbon Footprint Evidence
The check covers labelling, the declaration of conformity and the carbon footprint.
Testing of Electrolytes and Recycled Electrolytes
SAS hagmann carries out investigations of battery electrolytes. Analyses using ion chromatography (IC) and mass spectrometry (ICP-MS) provide information on composition, purity, recycled content, etc. The data obtained form the basis for elements of the labelling and the declaration of conformity.
FAQ on the EU Batteries Regulation for End Users and Companies
The EU Batteries Regulation creates a uniform set of rules for batteries, strengthens safety, transparency and sustainability, and makes conformity a central prerequisite for market access.
