Navigating the new EU battery regulation with TÜV Rheinland: Insights from an expert

Don't miss out: the associated webinar from TÜV Rheinland

The new EU battery regulation 2023/1542 came into force in August 2023. As almost every application today contains batteries, not least the cars on our roads, some manufacturers are overwhelmed by the new EU approval scheme and have many questions. In an expert interview with Dr. Nicolas Bogdanski from TÜV Rheinland, Automotive News Europe wants to clarify these questions.

Automotive News Europe: Mr. Bogdanski, could you please start by giving us a brief overview of the most important provisions of the new Battery Regulation?

Nicolas Bogdanski:

This regulation is part of the EU Green Deal and is intended to promote sustainability and a circular economy in the battery sector. This means that many aspects of the regulation are aimed precisely at these issues. Let's take a look at them one by one: For example, new requirements were introduced for so-called critical substances, or existing demands were tightened. This means that batteries will no longer be allowed to contain certain substances such as mercury, cadmium and lead in the future or, in some cases, will only be allowed to contain them up to a certain level. These regulations are intended to reduce environmental pollution and increase safety in the use and disposal of batteries.

But that's not the whole picture, isn’t it?

No, of course not. It is also important that manufacturers provide more information on battery performance in the future: detailed information on energy content, performance and durability is required. Then there is that important area, well-known as CE conformity. In the future, for example traction batteries for vehicles must bear a CE mark and fulfil the associated harmonised standards. But of course this was already the case for most batteries, meaning it is not a new requirement. However, since all batteries now have to bear the CE mark, some areas of application, in particular the automotive sector, have been added.

From the beginning of 2025, the carbon footprint of a battery must also be determined by the manufacturer – and verified by an independent third party, a so-called "Notified Body", which is granted the right to carry out these verifications in each EU country.

What other new requirements will we face with the battery regulation?

Well, two important points are still missing: I have already mentioned the issue of the circular economy. Accordingly, the proportion of a particular recyclate in the battery must first be determined in 2027, then gradually increased and must not fall below a certain value in the future. This is also intended to ensure that important raw materials such as lithium or cobalt, which are already available in the EU in considerable quantities thanks to recyclates, are no longer "lost" but are available as raw materials through recycling.

Last but not least, there is another area to be mentioned, which is called Due Diligence. In principle, this should be seen in conjunction with the supply chain law: manufacturers must have established and maintained a management system that covers their whole supply chain.

What role does TÜV Rheinland play in this entire process?

TÜV Rheinland acts as a global independent third party for testing and consulting. We help manufacturers within and outside the EU understand the requirements and how to navigate through them. Provided that we have not previously supported the customer in any other way, we also carry out independent inspections as the aforementioned "Notified Body".

Is this regulation ultimately also intended to reduce dependence  on suppliers?

Well, we cannot give an assessment of the EU's intentions. However, the goal is sustainability, which indirectly – for example through recycling – reduces dependence on material suppliers. In recent years, we have all had to experience that supplier dependencies bear major risks for the industry. It also might create a competitive advantage for European manufacturers who are familiar with the CE marking.

What impact will the regulation have on battery manufacturers around the globe?

Of course, the regulation is more of an advantage for European manufacturers, as they are already familiar with the CE marking and harmonised standards. Manufacturers outside the EU, especially from Asia, have more difficulties with this. However, as TÜV Rheinland has a lot of facilities and experts located in Asia, these manufacturers can take great advantage of our global network.

What would you guess, how are the requirements for the technical design of batteries changing?

The regulation is not necessarily a great driver of innovation at the moment. It rather prepares manufacturers for future, stricter requirements, such as the reduction of their carbon footprint.

Are there also new labelling requirements?

Yes, as I said, the CE marking for traction batteries is new. In addition, batteries must provide more information and in future will have to carry a QR code that leads to a kind of battery passport providing different levels of information for users, experts and authorities.

Will the regulation improve disposal and recycling?

Absolutely. The regulation promotes the circular economy by increasing the proportion of recycled materials in batteries and clearly regulating disposal.

What are the biggest challenges for companies when implementing it?

The biggest challenges are: firstly, understanding the regulation, because a new EU regulation  is complex and difficult to understand. Secondly, the declaration of conformity: manufacturers must prove that they meet the requirements. Thirdly, the establishment of new structures for supply chains, because many companies have to adapt their supply chains and management systems.

Can companies overcome these challenges with their own resources?

Well, large companies have to and can build up structures and obtain external expertise to ensure that they meet the requirements. Small companies need the same support, but they usually lack the capacity to deal with it. They are very grateful when we at TÜV Rheinland support them in this. However, even large international companies benefit from our expertise since navigating through such a complex piece of regulation is definitely not their core business.

What long-term effects do you expect on the European battery market?

In the long term, the regulation will hopefully improve the supply of raw materials within the EU, but it will not significantly change the EU's competitive position in global terms.

Does the EU have any sanctions for non-compliance?

Yes, of course! There are sanctions for non-compliance, including fines and market exclusion, similar to other CE-compliant products.

Mr. Bogdanski, thank you very much for the highly informative interview.

Don't miss out: the associated webinar from TÜV Rheinland

If you want to delve deeper into the topic and ask questions to Dr. Nicolas Bogdanski: On 26 September 2024, TÜV Rheinland will be hosting a webinar from 1:30 p.m. CEST entitled "Navigating the EU Battery Regulation 2023/1542 for Automotive Applications". In particular, employees of OEMs, system integrators and battery cell manufacturers get answers to many of their unanswered questions in the webinar.

About:

Dr. Nicolas Bogdanski

Dr. Nicolas Bogdanski has been with TÜV Rheinland for 15 years. He started out in the solar sector and later became involved in setting up the battery test laboratory in Aachen. In the meantime, the trained electrical engineer is responsible for business development in the field of engineering and type approval, including the worldwide implementation of battery related services.