Battery Regulation 2023/1542: digital passport, carbon footprint and due diligence in 3 seconds.

Regulation (EU) 2023/1542 (the EU Battery Regulation, replacing Directive 2006/66/EC) introduces carbon footprint declarations on a phased timeline by battery category. Electric vehicle (EV) traction batteries: carbon footprint declaration mandatory from 18 August 2024; carbon footprint performance class labelling from 18 February 2025; maximum carbon footprint thresholds to be established by a subsequent delegated act. Industrial batteries above 2 kWh: carbon footprint declaration from 18 August 2024 for batteries with an external power management system. Light means of transport (LMT) batteries: declaration from 18 February 2025. The carbon footprint must be calculated following the lifecycle assessment (LCA) methodology specified in the implementing act, covering raw material extraction, manufacturing, transport and end-of-life. Third-party verification is required for EV and industrial batteries above defined thresholds. IgeraIndustria retrieves the applicable timeline, LCA methodology requirements and verification obligations by battery category.

UN 38.3 (United Nations Manual of Tests and Criteria, Part III, Section 38.3) sets mandatory safety tests for lithium batteries before they can be transported by any mode. The test sequence must be completed in full and in order: T.1 Altitude simulation (low pressure: 11.6 kPa, 6 hours); T.2 Thermal test (-40°C to +75°C, 10 cycles); T.3 Vibration (sine sweep 7-200 Hz); T.4 Shock (peak acceleration 150 gn); T.5 External short circuit (55°C, 24 hours); T.6 Impact/crush (for cylindrical and prismatic cells); T.7 Overcharge (at 2x maximum charge current); T.8 Forced discharge. All tests must be conducted by an accredited laboratory. A test summary (T.1 to T.8) must accompany battery shipments — or refer to a publicly accessible summary. For cells, tests are conducted on prototype cells; for batteries, tests are conducted on assembled batteries. Cells in batteries cannot substitute for battery-level testing. IgeraIndustria identifies which test variants apply based on cell chemistry, form factor and assembly configuration.

The EU Battery Regulation Annex XIII defines the categories of information to be included in the digital battery passport (DBP), mandatory for industrial batteries above 2 kWh and EV batteries from 18 February 2026 (Regulation Article 77). Mandatory data categories include: (1) General information — battery model, manufacturer, date of manufacture, battery category, electrochemical chemistry; (2) Carbon footprint — total lifecycle carbon footprint (kgCO2eq per kWh), carbon footprint by lifecycle stage, carbon footprint performance class; (3) Material composition — hazardous substances above 0.1% w/w, critical raw materials (cobalt, lithium, nickel, natural graphite) by active material weight percentage; (4) Supply chain due diligence — cobalt, natural graphite, lithium and nickel sourcing information per OECD 5-step framework; (5) Battery health and state of charge — state of health (SoH), state of certified energy (SoCE); (6) Recycled content — percentage of recycled cobalt, lithium, nickel and lead by active material. The passport must be accessible via a QR code with a unique identifier. Data must remain accessible for the battery lifetime plus 10 years.

The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (3rd edition) provides the framework for cobalt, lithium and nickel due diligence under the EU Battery Regulation Article 52. The five steps are: Step 1 — Establish strong company management systems (due diligence policy, supply chain mapping, monitoring and escalation procedures); Step 2 — Identify and assess risks in the supply chain (survey suppliers to identify risk flags, including artisanal and small-scale mining (ASM) sourcing, country-level risk indicators, labour rights issues including child labour); Step 3 — Design and implement a strategy to respond to identified risks (suspend or disengage from high-risk suppliers if mitigation is not feasible within defined timeframe); Step 4 — Carry out independent third-party audit of supply chain due diligence at identified points of highest risk (smelters, refiners); Step 5 — Report annually on due diligence policies and practices (EUDR-aligned disclosure). The Battery Regulation requires the due diligence report to cover the entire supply chain from mine to battery cell. IgeraIndustria can retrieve the specific documentation requirements for each step applicable to a battery manufacturer.

IEC 62619:2022 (Safety requirements — Secondary lithium cells and batteries for use in industrial applications) is the key safety standard for battery energy storage systems (BESS) in stationary applications. Key requirements: Clause 5 — Design requirements: protection against overcharge, over-discharge, overcurrent and thermal runaway propagation; cell-level and battery-level fusing; Battery Management System (BMS) mandatory functions (voltage, current and temperature monitoring, protection cutoff thresholds); Clause 6 — Manufacturing process controls: cell screening, formation cycling records, moisture control during assembly; Clause 7 — Performance tests: capacity verification, cycle life testing, temperature performance; Clause 8 — Safety tests: thermal abuse, overcharge, external short circuit, drop, crush; Clause 9 — Transportation: conformance with UN 38.3. For grid-scale BESS, IEC 62619 is complemented by IEC 62933 (Electrical Energy Storage Systems — performance and safety requirements for grid integration). CE marking for BESS may involve the Low Voltage Directive 2014/35/EU and the Machinery Directive 2006/42/EC depending on configuration.

The EU Battery Regulation introduces specific provisions for second-life batteries under Article 74 (General producer responsibility) and Annex XIII (digital battery passport second-life data). Key regulatory positions: (1) Repurposed batteries (batteries used in a new application different from original) must receive a new CE marking and comply with all applicable conformity assessment requirements for the new application — including UN 38.3 if the repurposed battery will be transported; (2) Remanufactured batteries (batteries where cells are replaced or refurbished) are treated as new batteries for regulatory purposes and require full Battery Regulation compliance including carbon footprint declaration and digital passport; (3) Second-life batteries used in stationary BESS must meet IEC 62619 safety requirements and BMS functionality requirements regardless of original first-life application; (4) The Regulation introduces a “preparatory measures” clause (Article 12) requiring battery manufacturers to provide technical documentation to enable dismantling and second-life assessment. A delegated act on second-life battery procedures was expected by 18 August 2025. IgeraIndustria retrieves the current regulatory status and the published delegated act requirements.