The Importance of Tracking Battery Waste to Comply with EU Standards

As the European Union accelerates its shift toward a circular economy, the regulatory framework governing batteries is becoming significantly stricter. At the heart of these changes is a clear mandate: battery traceability and tracking are no longer optional — they are legal and operational imperatives.

For battery collectors, this evolving landscape presents both a compliance challenge and a strategic opportunity.

Understanding the Legal Framework

The cornerstone of this shift is the EU Battery Regulation (Regulation (EU) 2023/1542), adopted in July 2023 and applicable across all Member States. This regulation replaces the 2006 Battery Directive and introduces mandatory requirements for the full lifecycle management of batteries, from design and production to end-of-life collection and recycling.

For collectors, several key responsibilities now apply:

Registration and Reporting

Collectors must be registered with national authorities and report the quantities and types of batteries collected. This information feeds into national statistics and helps track progress toward EU collection targets.

Documentation of Waste Flows

Detailed records must be kept on each collection batch, including:

• Battery type and chemistry (e.g. lithium-ion, nickel-metal hydride, lead-acid)
• Source and location of collection
• Date of collection
• Quantity and weight
• Storage and transport conditions

Battery type and chemistry (e.g. lithium-ion, nickel-metal hydride, lead-acid)

Source and location of collection

Date of collection

Quantity and weight

Storage and transport conditions

This documentation must be made available to both competent authorities and, in many cases, producers under Extended Producer Responsibility (EPR) schemes.

Safe Handling and Labelling

Improper handling of batteries, particularly lithium-ion cells, can lead to safety incidents. The regulation enforces specific standards for:

• Sorting by chemistry
• Secure packaging and labelling
• Compliance with ADR transport rules for hazardous goods

Sorting by chemistry

Secure packaging and labelling

Compliance with ADR transport rules for hazardous goods

Why Traceability Matters

Beyond legal compliance, traceability plays a vital role in building an efficient, transparent, and circular battery value chain.

Risk Reduction

By knowing the exact composition and condition of collected batteries, collectors reduce the risk of fire, leakage, or incorrect treatment — all of which carry legal and environmental consequences.

Market Access

More and more recycling partners, OEMs, and producers are demanding traceability data from their partners. Without reliable documentation, collectors may find themselves excluded from key contracts or partnerships.

Data-Driven Optimization

Accurate tracking also enables better route planning, resource allocation, and forecasting. With the right systems in place, traceability becomes a lever for operational efficiency, not just compliance.

Digital Tools and Best Practices

To comply with these requirements efficiently, battery collectors are increasingly turning to digital tools. These include:

• Barcode or QR-code systems to tag and trace containers or batches
• Cloud-based inventory platforms for real-time documentation
• Battery passports, a concept introduced in the regulation, which provide detailed product information from the manufacturer
• Automated identification and sorting systems based on battery form factor and chemistry

Barcode or QR-code systems to tag and trace containers or batches

Cloud-based inventory platforms for real-time documentation

Battery passports, a concept introduced in the regulation, which provide detailed product information from the manufacturer

Automated identification and sorting systems based on battery form factor and chemistry

Implementing such systems not only facilitates smoother inspections and audits but also strengthens long-term partnerships across the battery lifecycle.

The Road Ahead

As enforcement of the new regulation becomes stricter, and with additional requirements such as carbon footprint disclosures, recycled content targets, and due diligence obligations entering into force in phases, traceability will become even more central to battery logistics and recycling operations.

Battery collectors who invest now in robust, digital, and transparent tracking systems will not only ensure compliance — they will position themselves as trusted, strategic players in Europe’s emerging battery circular economy.

Are you prepared for the new traceability standards?

Companies that act early will have a significant advantage as the market consolidates around transparency, safety, and circularity.

• Regulations & compliance in the EU