The European Union (EU) is treading the wrong path on battery regulation, according to industry groups from battery, energy storage, electric mobility and adjacent sectors.
The complaint concerns battery labelling rules introduced in the EU’s updated Batteries Regulation (EU) 2023/1542. The direction taken since then risks overburdening Europe’s industry while creating regulatory uncertainty, according to the trade associations.
A joint open letter was sent to Brussels earlier this week (2 November), co-signed by rechargeable battery and lithium batteries association Recharge, Energy Storage Europe, Flow Batteries Europe and European automotive and industrial battery manufacturers’ association Eurobat.
They were joined by associations representing e-mobility, garden machinery, consumer battery, home appliances, power tools and metals and materials industry groups.
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The letter was addressed to European Commission (EC) Executive Vice-President for Prosperity and Industrial Strategy and Commissioner for Industry, Stéphane Séjourné; Commissioner for Economy and Prosperity, Valdis Dombrovskis; and Commissioner for Environment, Water Resilience and a Competitive Circular Economy, Jessika Roswall.
The Batteries Regulation entered into force in August 2023 and, as of August 2025, has fully replaced the existing regulation, introduced in 2006.
The legislation is multi-faceted, and its various layers are being implemented in phases. For instance, a requirement for CE marking already went into effect in 2024, while rules on the management of waste batteries became applicable a year later; a new digital Battery Passport (essentially QR code labelling of a battery’s provenance down to each component) becomes mandatory from February 2027.
Due diligence obligations on supply chains and procurement become mandatory from August next year.
The trade association’s complaint and urge to action for Commissioners
You can read much more about the EU Batteries Regulation from our coverage on Energy-Storage.news, including a November 2025 video discussion with Suriya Edwards, partner at law firm Freeths and Sarah Montgomery, co-founder and CEO of battery supply chain traceability platform Infyos, for ESN Premium subscribers.
The trade associations’ joint letter pertains to the labelling of “certain hazardous substances,” aimed at providing information to end-users of batteries and helping to direct the management of waste batteries.
The EC’s Environmental Omnibus negotiations on battery substance labelling appear to be steering the bloc towards creating its own definitions of these hazardous substances.
The co-signees argue, meanwhile, that workable definitions of such substances already exist, in the form of the EU’s REACH Candidate List of Substances of Very High Concern (SVHC). This is managed by the European Chemicals Agency (ECHA) and includes 253 entries.
The EU’s direction on SVHCs is moving away from the regulation’s original legislative intent and risks overcomplicating the process, the letter argued, urging the European Union to adopt the REACH Candidate List.
Whereas the Environmental Omnibus negotiation was meant to simplify EU legislation and reduce administrative burden for businesses, negotiations as they stand “risk doing the opposite by expanding the scope of substances subject to labelling, creating regulatory uncertainty and imposing additional obligations across complex battery supply chains,” the trade associations’ letter said.
