#BatteryRegulation: Review Product and Labeling Requirements Effective August 18, 2024
The EU Battery Regulation came into force on February 18, 2024, introducing new rules for the supply chain/lifecycle of batteries. The regulation includes 97 articles and multiple transitional periods for different requirements. Significant changes took effect on August 18, 2024, with the application of Article 17 and Chapter VI of the regulation. The next major set of requirements will come into effect in August next year, focusing on waste management and producer responsibility as outlined in Chapter VIII.
This article highlights the key obligations that came into force in August for manufacturers, importers, and distributors.
Are You a Manufacturer, Importer, or Distributor?
Each actor in the battery supply chain has its own responsibilities. Article 3 of the Battery Regulation defines the roles of manufacturers, importers, and distributors as follows:
- ‘Manufacturer’: Any natural or legal person who manufactures batteries, or has them designed or manufactured, and markets them under their own name or trademark or uses them for their own purposes.
- ‘Importer’: Any natural or legal person established in the Union who places on the market a battery from a third country.
- ‘Distributor’: Any natural or legal person in the supply chain, other than the manufacturer or importer, who makes a battery available on the market.
Manufacturers Must Add New Labels to Batteries
Manufacturers must ensure the following for batteries:
- CE Marking: All batteries must now carry a CE marking (Article 38). This requirement has already been mandatory for electrical devices and toys.
- Identification Details: Batteries must include a model identifier, batch or serial number, or product number, as well as the manufacturer’s name, registered trade name or trademark, a postal address of one contact point, and, if available, website and email addresses (Article 38).
- Specific Markings: Markings required under national regulations, such as separate collection, heavy metal, and capacity markings.
Importers Must Verify and Add Their Own Information
Importers must ensure that the required markings are present on imported batteries. If the markings do not meet the requirements, the products cannot be placed on the market until they are corrected.
In addition, importers must add their own information to the battery:
- Importer’s name
- Registered trade name or trademark
- A postal address of one contact point
- Website and email addresses, if available
Distributors (Resellers) Have Inspection Duties
Distributors must check that batteries comply with requirements before placing them on the market. If markings are incomplete, the products cannot be marketed until the deficiencies are rectified. Distributors must also ensure that the storage and transportation conditions of the batteries they handle do not compromise compliance.
You can read more about the responsibilities of manufacturers, importers, and distributors on Tukes’ website (note: the table has not yet been updated to reflect the Battery Regulation): The obligations of economic operators as a table | Finnish Safety and Chemicals Agency (Tukes).
Other Provisions Effective August 2024
Performance and Durability Requirements
Industrial batteries over 2 kWh, batteries for light electric vehicles, and electric vehicle traction batteries must include documentation of their electrochemical performance and durability as of August 18, 2024.
Safety Requirements for Energy Storage
Stationary energy storage systems must meet safety standards during normal use and operation. Annex VIII of the Battery Regulation outlines the conformity assessment procedure for this.
Restriction on Portable Lead-Acid Batteries
Portable batteries containing more than 0.01% lead by weight cannot be marketed. An exception applies to zinc-air button cells, where the restriction will take effect on August 18, 2028. However, lead-acid industrial and vehicle batteries can still be marketed.
[1] Finnish Government Decree on Batteries and Accumulators 520/2014, Section 14: Finnish Government Decree on Batteries and Accumulators 520/2014 – Original Regulations – FINLEX®
Further Reading
This article is a part of the joint communications of the battery producer organisations Recser Oy and Akkukierrätys Pb Oy concerning the EU Batteries Regulation. You can also subscribe to our newsletter to receive the latest news on the subject.