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EU battery 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. Dr Hartmut Stahl and Dr Johannes Betz, Senior Researchers of Resources & Mobility, comment on this success.


EU battery regulation - a success for the circular economy soc
L-R: Dr Hartmut Stahl and Dr Johannes Betz

It is a great success that the battery regulation has now been passed by the European Parliament and the Council. Since the battery market is growing rapidly, especially in the area of ​​electromobility with lithium-ion batteries, it is important to meet the associated challenges in good time. The new European regulation is part of the Circular Economy Action Plan and modernizes the EU legal framework for batteries with sustainable principles. Since this is a regulation, it comes into force directly without having to be transposed into national law, as is the case with an EU directive, for example. That is to be welcomed.

As the Oeko-Institut, we were involved in the development process with important contributions. Among other things, we have been continuously involved in evaluating the previous battery directive, supporting the impact assessment process and advising the commission before the regulation was actually passed.

Objectives of the regulation

EU battery rules aim to make batteries sustainable throughout their lifecycle – from sourcing of materials to collection, recycling and reuse. The new rules aim to support the development of a competitive, sustainable battery industry in the EU, as well as Europe’s clean energy transition and independence from fuel imports. The regulation aims to strengthen the EU internal market since the same competitive conditions are guaranteed for all companies within the EU. Since comprehensive labor and sustainability standards apply in the EU as a whole, the rules on sustainability can also prove to be a global competitive advantage.

The EU has decided on the following measures for the future handling of batteries:
  • Higher mandatory guidelines for recycling

Recovery targets (for certain metals) and efficiency increases for recycling the batteries are set. Lithium-ion batteries have so far been classified as “other batteries” because there is no separate category for them. Therefore, the minimum recycling efficiency for lithium-ion batteries is currently only 50 percent of the total weight. In addition to an increase in overall efficiency, binding recovery quotas have been set for the most important metals such as copper, cobalt, nickel and lithium.

In addition, significantly higher collection rates for portable batteries will also be introduced so that batteries can be collected and recycled consistently instead of being disposed of in a disorderly manner. In addition, a new category of the so-called Light Means of Transport (LMT) will be established, among other things, to set collection quotas for batteries from smaller vehicles such as e-scooters or e-bikes. Both quotas are expected to increase over time.

For certain raw materials in batteries that are placed on the EU market, a recycled content is specified that these newly manufactured batteries must contain. This is to ensure that the recycled materials are also reused in new batteries, thus closing the loop.

  • Mandatory due diligence along the supply chain

The minerals used in battery manufacture today are sourced from global supply chains. They often come from countries with low human rights standards and few health and safety measures. According to the new battery regulation, when procuring batteries, companies must now ensure that no human rights violations are committed in connection with the extraction of certain metals, transport and trade. If these occur, the cooperation with the suppliers must be terminated. These standards help reduce corruption along the supply chain.

  • Calculation of greenhouse gas emissions in the CO2 footprint

With the new Battery Ordinance, companies are also obliged to publish their CO2 footprint, and, with a certain delay, they are not allowed to exceed a maximum value of greenhouse gas emissions for the entire life cycle of the batteries. The calculation is based on the Product Environmental Footprint method of the European Commission, which sets specifications for balancing the greenhouse gas emissions of material, energy and other substances.

  • Removal and interchangeability of batteries

Another important point in the Battery Ordinance is that in the future, it must be possible to remove the batteries without destroying them. The batteries must also be designed in such a way that they can be replaced in the event of damage or after aging. This is intended to improve the longevity of products and thus reduce their ecological footprint.

  • Implementation of positive aspects with regard to the products

Batteries must be provided with further information in the future. This enables consumers to inform themselves more consciously and easily when making a purchasing decision. For this purpose, the batteries are to be provided with a QR code in the future, under which information, for example, on the charging capacity and the exact materials, can be called up. Other important points in the regulation are increasing the longevity of the products and sustainable rules for public procurement. As a result, environmental impacts must be taken into account in public procurement.

What remains to be done

Although the Battery Ordinance is a great success for Europe, its effect still has to be seen. Many measures will only come into force in a few years, and it will therefore take some time before changes become apparent.

In addition, some measures have not yet been precisely regulated; the European Commission still has to do this in other so-called legal acts (delegated acts or implementing acts). There, for example, it is determined how the CO2 footprint is calculated exactly. For example, if there are no strict rules there, this measure will have no effect.

In addition, some measures are missing, such as the deposit on larger batteries, for example, in battery-powered tools or e-bikes etc. This would further increase the collection rate and reduce the risk of these batteries being disposed of incorrectly. Incorrectly disposed batteries cause hundreds of small and large fires at disposal companies every year.


Different objectives are achieved with this regulation, and as such, it can serve as a good example for other sectors or legislation within the EU in general. In addition, other countries could also use this regulation as a blueprint for their own legislation.

Overall, the new battery regulation of the European Union is a great success for the development towards a sustainable society.

Dr Hartmut Stahl and Dr Johannes Betz are experts in batteries and circular economy. You work in the “Resources & Mobility” department at the Darmstadt site. Together with other scientists, they researched the EU battery regulation.

Further information

Study – “Assessment of options to improve particular aspects of the EU regulatory framework on batteries” by the Oeko-Institut, Ramboll and the Federal Environment Agency in Vienna

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

Summary of the mobility sector roadmap “Towards Responsible Sourcing – What’s Next for the Mobility Sector?” of the Oeko-Institut in the project Re-Sourcing

News report – “How can lithium-ion batteries be better recycled?” by the Oeko-Institut

Blog post – “The new supply chain law – a step forward with potential for improvement” by Dr Peter Gailhofer

This article was originally published at Oeko-Institut