With the new EU Batteries and Waste Batteries Regulation in force, non-compliance is no longer just a regulatory oversight — it's a business risk. Companies across the battery value chain, from producers to recyclers, are now legally required to meet strict standards for sustainability, traceability, and end-of-life treatment.

Failing to comply with these rules can result in severe penalties, reputational damage, and even legal bans from the European market. So what exactly are the risks — and how can your company stay compliant?

Understanding the New Legal Landscape

The EU Regulation on Batteries and Waste Batteries (2023/1542), which replaces older national frameworks like the Waste Batteries and Accumulators Regulations 2009, is designed to create a harmonized approach to battery sustainability across all member states.

The regulation applies to all battery types — portable, automotive, industrial, and EV batteries — and introduces requirements across their entire lifecycle, including:

• Carbon footprint declaration and thresholds
• Minimum levels of recycled content
• Collection targets for waste batteries
• Design for disassembly and reuse
• Clear labeling and digital battery passports

Carbon footprint declaration and thresholds

Minimum levels of recycled content

Collection targets for waste batteries

Design for disassembly and reuse

Clear labeling and digital battery passports

These rules are now binding across the EU and require both producers and recyclers to comply — or face consequences.

What Are the Compliance Risks?

1. Financial Penalties
2. Member states have the authority to enforce substantial fines for non-compliance. These vary by country but can reach into the millions of euros, especially for large producers who fail to meet collection or recycling targets.
3. Market Access Restrictions
4. Companies that do not meet requirements under the EU regulation battery framework can be barred from selling batteries in the EU. This applies particularly to those failing to meet carbon footprint limits or recycled content thresholds.
5. Reputational Damage
6. Being flagged for non-compliance can severely impact brand reputation — especially in a market where sustainability performance is becoming a key competitive differentiator.
7. Operational Disruptions
8. Failing to build proper systems for waste tracking, labeling, and digital battery passports can delay shipments, trigger audits, or block product certification altogether.

Financial Penalties

Member states have the authority to enforce substantial fines for non-compliance. These vary by country but can reach into the millions of euros, especially for large producers who fail to meet collection or recycling targets.

Market Access Restrictions

Companies that do not meet requirements under the EU regulation battery framework can be barred from selling batteries in the EU. This applies particularly to those failing to meet carbon footprint limits or recycled content thresholds.

Reputational Damage

Being flagged for non-compliance can severely impact brand reputation — especially in a market where sustainability performance is becoming a key competitive differentiator.

Operational Disruptions

Failing to build proper systems for waste tracking, labeling, and digital battery passports can delay shipments, trigger audits, or block product certification altogether.

Specific Requirements from the EU Batteries and Waste Batteries Regulation

• Collection Targets: 63% by 2027 for portable batteries, with higher thresholds expected later.
• Recycled Content Targets: Batteries must include minimum percentages of recycled cobalt, lead, lithium, and nickel, increasing progressively toward 2031.
• Carbon Footprint Disclosure: Required for EV and industrial batteries, including calculation, verification, and labeling.
• Producer Responsibility: Extended Producer Responsibility (EPR) applies, meaning that manufacturers are legally responsible for ensuring proper battery end-of-life treatment.

Collection Targets: 63% by 2027 for portable batteries, with higher thresholds expected later.

Recycled Content Targets: Batteries must include minimum percentages of recycled cobalt, lead, lithium, and nickel, increasing progressively toward 2031.

Carbon Footprint Disclosure: Required for EV and industrial batteries, including calculation, verification, and labeling.

Producer Responsibility: Extended Producer Responsibility (EPR) applies, meaning that manufacturers are legally responsible for ensuring proper battery end-of-life treatment.

The EU batteries and waste batteries regulation is a game-changer for the industry — and companies cannot afford to ignore it.

How Circu Li-ion Helps You Stay Compliant

At Circu Li-ion, we support battery producers, recyclers, and logistics providers in ensuring full compliance with EU regulations. Our automated disassembly systems:

• Enable safe, efficient, and traceable battery dismantling
• Provide granular data on battery types and contents
• Support collection and recycling tracking systems
• Facilitate design-for-recycling strategies

Enable safe, efficient, and traceable battery dismantling

Provide granular data on battery types and contents

Support collection and recycling tracking systems

Facilitate design-for-recycling strategies

Whether you're handling waste batteries and accumulators, or preparing to meet new EU regulation battery thresholds, we help turn compliance into a strategic advantage.

Conclusion: Don’t Wait for a Fine — Build for Compliance Now

The new EU batteries and waste batteries regulation marks a turning point. Regulatory pressure is rising, and so are the expectations from customers, investors, and policymakers. The risks of doing nothing are real — but the rewards of early compliance are even greater.

• Regulations & compliance in the EU