18 August 2025 marks the first anniversary of the EU Battery Regulation (EU) 2023/1542 coming into force. This new legislation governs the entire life cycle of batteries, from the extraction of raw materials to their use and recycling. For the first time, it establishes a uniform legal instrument with direct validity throughout Europe. TÜV SÜD reflects on the past year and looks ahead to the next regulatory milestones, including CO2 footprints, battery passports and extended producer responsibility.
Looking back: A challenging start to a new era
The EU Battery Regulation replaces the previous Battery Directive (2006/66/EC) and covers electric vehicle batteries, lead-acid batteries, industrial energy storage systems, and stationary systems, among other things. The aim is to transform the market towards sustainability, the circular economy and product safety.
„Many companies initially found it difficult to define their role correctly, such as determining whether they were considered a supplier, producer or importer,“ explains Nicholas Bellino, Senior Account Manager and battery expert at TÜV SÜD. „Technical documentation in particular – the core element of proving battery conformity – presented challenges for our customers and often required several revisions before meeting the requirements.“
The mandatory CE marking and conformity assessment procedure have been in force since 18 August 2024, but smaller market players in particular have found the requirements overwhelming. Additionally, as the regulation was new, many secondary legal acts were still in the process of being drafted and are still in the process of being drafted. „The market was looking for guidance – and many found it at TÜV SÜD. Our customers value us as both a testing body and as a sparring partner with an international overview and in-depth technical understanding,“ Bellino continues.
CO2 footprint: the game changer from 2025
According to Article 7 of the Regulation, manufacturers of certain types of batteries (including EV and industrial batteries) must prepare and independently verify a CO2 balance sheet for each battery model and production site. The final version of the Delegated Regulation is expected in the third or fourth quarter of 2025 and is considered a regulatory turning point.
The calculation is carried out in accordance with the PEF (Product Environmental Footprint) methodology and covers all life stages – from raw material procurement and manufacturing to the point of „placing on the market“. Particularly critical: Primary data must be used for certain processes, and the data used must undergo a data quality rating. „Implementing the current version of the Delegated Act presents affected companies with significant procedural, strategic and resource-intensive challenges. We are helping to reduce the complexity and the error rate through training and compliance checks,“ emphasises Bellino.
Further stages: responsibility and transparency
Notified bodies: TÜV SÜD is seeking designation
Conformity assessments – for example, for the carbon footprint, the proportion of recycled material or the safety of stationary battery storage systems – may only be carried out by notified bodies. TÜV SÜD has applied for designation and is preparing for this role with its global network.
„Our globally networked team enables us to operate effectively worldwide and offer our customers optimal service. This is particularly helpful when plants need to be audited on site,’“ says Bellino.
Support from TÜV SÜD
TÜV SÜD offers a comprehensive portfolio of services related to the EU Battery Regulation:
Further information:
Looking back: A challenging start to a new era
The EU Battery Regulation replaces the previous Battery Directive (2006/66/EC) and covers electric vehicle batteries, lead-acid batteries, industrial energy storage systems, and stationary systems, among other things. The aim is to transform the market towards sustainability, the circular economy and product safety.
„Many companies initially found it difficult to define their role correctly, such as determining whether they were considered a supplier, producer or importer,“ explains Nicholas Bellino, Senior Account Manager and battery expert at TÜV SÜD. „Technical documentation in particular – the core element of proving battery conformity – presented challenges for our customers and often required several revisions before meeting the requirements.“
The mandatory CE marking and conformity assessment procedure have been in force since 18 August 2024, but smaller market players in particular have found the requirements overwhelming. Additionally, as the regulation was new, many secondary legal acts were still in the process of being drafted and are still in the process of being drafted. „The market was looking for guidance – and many found it at TÜV SÜD. Our customers value us as both a testing body and as a sparring partner with an international overview and in-depth technical understanding,“ Bellino continues.
CO2 footprint: the game changer from 2025
According to Article 7 of the Regulation, manufacturers of certain types of batteries (including EV and industrial batteries) must prepare and independently verify a CO2 balance sheet for each battery model and production site. The final version of the Delegated Regulation is expected in the third or fourth quarter of 2025 and is considered a regulatory turning point.
The calculation is carried out in accordance with the PEF (Product Environmental Footprint) methodology and covers all life stages – from raw material procurement and manufacturing to the point of „placing on the market“. Particularly critical: Primary data must be used for certain processes, and the data used must undergo a data quality rating. „Implementing the current version of the Delegated Act presents affected companies with significant procedural, strategic and resource-intensive challenges. We are helping to reduce the complexity and the error rate through training and compliance checks,“ emphasises Bellino.
Further stages: responsibility and transparency
- Due diligence postponed to 2027
- Extended producer responsibility from 2025
- Battery passport from 2027
Notified bodies: TÜV SÜD is seeking designation
Conformity assessments – for example, for the carbon footprint, the proportion of recycled material or the safety of stationary battery storage systems – may only be carried out by notified bodies. TÜV SÜD has applied for designation and is preparing for this role with its global network.
„Our globally networked team enables us to operate effectively worldwide and offer our customers optimal service. This is particularly helpful when plants need to be audited on site,’“ says Bellino.
Support from TÜV SÜD
TÜV SÜD offers a comprehensive portfolio of services related to the EU Battery Regulation:
- Conformity assessments
- Verification of CO2 footprints (PCF) and recycling rates
- Training and workshops
- Support with battery passport requirements
- Preparation for due diligence and supply chain transparency
- Coming soon: Approval as a notified body (including CE marking)
Further information:
- https://www.tuvsud.com/... Note for editorial staff: The press release is available on the Internet at: tuvsud.com/newsroom.
