EU Batteries Regulations and the GBA Battery Passport

Overview  

The EU’s Batteries and Waste Batteries Regulation (EU 2023/1542)  establishes one of the EU’s most stringent regulatory frameworks governing how batteries are sourced, designed, manufactured, used and recycled. Central to the Regulation is the Digital Battery Passport (DBP), a mandatory digital record that standardises lifecycle data for EV, LMT, and industrial batteries above 2kWk.  

In parallel, the Global Battery Alliance (GBA) Battery Passport provides a voluntary, global ESG performance framework that inspired and extends the EU’s DBP. While the EU regulation mandates minimum data and due-diligence requirements, the GBA system introduces performance benchmarking across ESG indicators, enabling companies to demonstrate sustainability leadership rather than compliance.  

Key differences: 

• The EU DBP is legally binding, limited to batteries placed on the EU market, and primarily focused on data disclosure and due diligence for four critical raw materials (cobalt, natural graphite, lithium and nickel). 
• The GBA Passport is voluntary, globally applicable, and aims to assess, score and improve ESG performance across supply chains.
• Using the GBA Passport does not replace the EU DBP obligations, however, GBA data and assurance processes can support or exceed EU requirements.  

Batteries and Waste Batteries Regulation (EU 2023/1542)  

As part of the European Green Deal, the EU aims to decouple economic growth from resource use and transition away from fossil fuels with the promotion of electric vehicles and renewable energy. This shift is expected to increase demand for batteries and has prompted the EU to introduce mandatory regulations governing how batteries are sourced, designed, manufactured, used and recycled.   

The Batteries and Waste Batteries Regulation (EU 2023/1542) was adopted in 2023 with phased obligations for all member states from February 2024.  

The Regulation sets legally binding requirements for sustainability, safety, durability, labelling, circularity, environmental- and social-due-diligence for batteries placed on the EU market, regardless of where they are produced. Companies must map their battery supply chains, identify and address ESG risks, and ensure third-party verification down to the level of the country of extraction, processing and trading for the four raw materials – cobalt, natural graphite, lithium and nickel.  

From 18 February 2027, it will become mandatory that each battery within scope must carry a scannable QR code linking it to a verified digital record, the Digital Battery Passport (DBP). The DBP contains all relevant data, including: 

• origin of raw materials
• manufacturing location and date
• carbon footprint
• battery chemistry, composition and performance
• capacity, durability, efficiency and repair history
• recyclability and second life potential.  

The regulation applies to all batteries placed on the market or used in the EU regardless of whether they have been produced in the EU or imported. The categories of batteries covered include: 

• portable batteries
• starting, lighting and ignition batteries (SLI)
• light means of transport batteries (LMT)
• electric vehicle batteries
• industrial batteries 
• all batteries incorporated into or added to products  

Due diligence should address at least the most prevalent social and environmental risk categories which include biodiversity (“including damage to habitats, wildlife, flora and ecosystems, including ecosystem services,” Annex X, 2(iv)), water, human rights and community life impacts. Failure to comply with due diligence requirements results in the operator not being allowing to place those batteries on the EU market.  

Economic operators include manufacturers, importers, distributors and retailers, and any company (EU or non-EU) placing batteries on the EU market.  

For many companies, the biggest shift will not be in technology but in data management. Collecting reliable, standardised information across global supply chains requires both new infrastructure and cross-sector collaboration. 

Implementing Regulation (EU 2025/2289) 

The European Commission has published the Implementing Regulation (EU 2025/2289) laying down rules for the application of Regulation (EU) 2023/1542. It came into force in November 2025 and still applies to all economic operators placing batteries in the EU market. The regulation aims to ensure consistent implementation across Member States, focusing on: 

• the format and structure of reported data 
• the assessment methods and the operational conditions for the collection and treatment of waste batteries. 

As supply chain disruptions (costs, raw material availability, geopolitics) pose risks to battery production, enhancing circularity along the battery value chains is a core policy objective. By 2040, recycling could contribute 51% of the EU’s cobalt and 42% of its nickel demand, decreasing the EU’s dependency on external supply chains. 

Omnibus delays 

Due diligence requirements, originally scheduled for August 2025, have been delayed till August 2027 under the Omnibus package with guidance expected mid-2026. The delay also raises economic operator threshold from €40m to €150m annual global turnover.  

However, this gives organisations more time to establish due diligence systems and early action is essential as the systems must be fully implemented and functioning well before the 2027deadline.  

Due diligence reporting will be required every three years, starting in 2028 (European Commission amendments p5,pt19).  

Global Battery Alliance Battery Passport 

Founded in 2017, the Global Battery Alliance (GBA) is a pre-competitive, multi-stakeholder initiative focussed on scaling a sustainable, responsible and circular battery value chain by 2030.  

The GBA’s Battery Passport is a due diligence and sustainability reporting framework designed to support economic operators and raw material suppliers to prepare for, and go beyond, the Regulation (EU) 2023/1542 (see Fig. 1).