Staying charged: the evolving regulatory landscape needed for sustainable battery production

As we move towards a green transition, the demand for battery technology is significantly increasing. However, this demand brings with it a set of challenges for sustainable production, such as the potential shortages of critical minerals. In this article we look at how the EU Commission is developing a regulatory framework for battery production to encourage traceability and sustainable end-of-life processing.

By Laure Davis, Sustainability Consultant, Jonathan Leclercq, Senior Manager, Sustainability & Supply Chain Solutions, and Christopher Lilholm, Head of Global Key Customer Management at DNV.


Fuelled by the EU’s ban on the sale of new petrol and diesel cars from 2035 and the growth of energy storage systems, the demand for batteries is expected to skyrocket over the next decade. To ensure that this expected mass increase in battery production is sustainable, the European Commission is taking action as part of its Circular Action Plan.

A new regulatory framework will modernize the 2006 Battery Directive, with a renewed focus on sustainable production, deployment, and waste management of batteries, including portable batteries, automotive batteries, industrial batteries, and batteries for electric vehicles.

What are the upcoming regulations?

The EU Battery Regulation Amendment (agreed by EU Parliament and the European Council in December 2022), or Sustainable Batteries Regulation, seeks to improve traceability by making information available across the battery value chain, from sourcing to production to end-of-life processing. It aims to establish a comprehensive framework covering all types of batteries, addressing the whole lifecycle.

Who does this affect?

Operators placing batteries on the EU market will be required to provide specific up-to-date documentation and accurate information on the product and production process.

This will impact the battery industry value chain at large, including battery manufacturers, component suppliers, recyclers, second-life operators, remanufacturers, and distributors.

What information and documentation will be required?

Production disclosures:

  • Battery manufacturers will be required to disclose the carbon footprint associated with the overall life cycle of the battery from 1st July 2024. This will have to be verified by a third party and made publicly available (see DNV’s carbon footprinting offering).
  • From 1st July 2027, batteries will be classified according to their carbon footprint life cycle and will be required to meet the life cycle carbon footprint thresholds.
  • It is anticipated that the EU Commission will make resources available to aid with the process of calculating the carbon footprints.
  • By 1st January 2030, batteries will be required to contain a minimum recycled content of 12% cobalt, 85% lead, 4% lithium and 4% nickel.
  • Following the implementation of the EU Battery Regulation, there will be a 12-month period before it becomes mandatory for battery manufacturers to conduct social & environmental supply chain due diligence (see DNV’s supply chain due diligence offering).

Product disclosures:

  • All EV and industrial batteries (with a capacity of over 2kWh) placed on the EU market from 1st January 2026 will require a battery passport (see DNV’s digital product passport offering). The battery passport will be accessed by a product identifier QR code and will contain publicly available information on the battery manufacturer, the battery type, model, production date, chemical composition, repair, and durability.
  • A conformity assessment issued by a notified body will be necessary in order for a battery to be placed on the EU market.
  • Technical documentation will need to be provided to prove that the battery is safe and does not contain hazardous substances (hazardous to humans and hazardous to the environment).

Information to empower decisions on end-of-life battery processing:

The Regulation places an increased focus on producer responsibility, whereby producers will need to provide electronic information on the battery model to end users/those conducting repair or end-of-life processing.

  • Producers will be responsible for raising awareness of end-of-life processing and for organising collection programmes.
  • Information on the health of the battery will need to be made available to the owner of the battery to empower them to make decisions on reuse, repurpose and remanufacture.

How DNV can help

DNV can help you comply with the upcoming regulations by:

  • Setting up a battery passport and providing full technical and business support in the setup, implementation and roll-out.
  • Carrying out the overall assurance process to ensure that validated, accurate, complete, and up-to-date information on the origin, composition, and environmental performance of the product is inputted into the battery passport.
  • Supporting proactively in verifying environmental and social claims, mitigating supply chain risks and uncovering further opportunities to decarbonize to lead a business towards a more nature-positive outcome.
  • Offering certification and verification of equipment used at a battery production plant, such as machinery, and process systems in compliance with EU regulation. DNV can furthermore assess and test the battery for its application and use in a system that is operating in an explosive atmosphere (Ex).
  • Besides the battery passport verified traceability solution, DNV also leverages in-depth battery knowledge and industry experience drawing on expertise within the energy sector, providing a comprehensive suite of services ranging from feasibility studies, tools, development, construction, operation, and testing of batteries. Our service for batteries also includes a battery benchmark report, called battery scorecard, which is the ranking and evaluation of battery vendors based on testing performed in DNV’s laboratories.

Do you have questions about how the new regulations might impact your business? Contact us to find out more.