EU Battery Regulation: Performance class requirement for EV batteries begins

Battery Regulation (EU) 2023/1542 replaced the Battery Directive of 2006 and, as a directly applicable regulation, introduced sustainability, safety and transparency requirements across the whole life cycle of a battery.

The scope is broad: all batteries placed on the EU market — including electric bicycle and light means of transport (LMT) batteries — fall within the framework. This binds not only automotive but also portable and industrial battery manufacturers.

The logic of the regulation is not that everything starts on a single date but a staged timetable. Every obligation has its own date and these differ by product type.

From 18 August 2024, documentation including electrochemical performance and durability values became mandatory for rechargeable industrial batteries above 2 kWh capacity, LMT batteries and electric vehicle batteries.

This means the values printed in a battery's catalogue are no longer marketing information but a component of a conformity document. How the values were measured and under what conditions they were obtained must be on record.

The regulation requires the manufacturer to calculate and declare the carbon footprint arising over the battery's manufacturing process using the life cycle assessment (LCA) method. For electric vehicle batteries the carbon footprint declaration obligation became mandatory on 18 February 2025.

August 2026 brings the next stage: classification according to carbon footprint performance classes. Declaring is no longer enough; the declared value must correspond to a class and that class must be visible on the product.

Classification makes two batteries of the same capacity comparable on carbon performance. The commercial consequence is direct: a buyer can now write the class into the specification.

The carbon footprint calculation is not limited to the manufacturer's own facility; the result cannot be established without data on inputs such as cells, cathode material and electrolyte. The real bottleneck is therefore not the calculation but obtaining data from suppliers.

The regulation also brings headings such as recovered content and the battery passport on their own timetables. The passport means that the data gathered today will eventually come together in a single digital record — and the quality of today's record-keeping is what pays off on that day.

Battery regulation establishes a different scope from classical product legislation: alongside the product's safety it governs its performance over its life, its substance content, its recycled content, its carbon footprint and its end-of-life management together.

This expansion comes from the battery's distinctive position: it is at once a product component, a store of energy and a waste stream carrying critical raw materials. It cannot be regulated on a single axis.

The practical consequence is that the conformity file is broader than a classical technical file: alongside test reports, supply chain data, the recycled content calculation and the carbon footprint declaration also enter the file.

Performance classification aims to express, in comparable language, the extent to which a battery retains its capacity over its life. Its function is to allow a buyer to compare different products on the same scale.

A class is not a guarantee: degradation in real use depends on charging habits, temperature history and charging rate, and these are specific to the user. The class represents behaviour under a standard cycling regime.

The basis of the declared class is test data, and those tests take a long time: cycle life tests run over months. For a product requiring a performance declaration, the test plan is therefore started before every other item.

The component of the arrangement requiring the most infrastructure is the digital carriage of information about the battery: identity, composition, performance and life data become accessible through a record tied to the product.

Preparing for this is not a software exercise but a DATA exercise: which data is held where, who updates it and how items coming from the supply chain are collected are all determined. Without the data, a system to carry it is of no use.

Adding a data-sharing clause to supplier contracts is the earliest and highest-return step of that preparation.