
In 2023 the EU replaced its twenty-year-old Battery Directive with Regulation (EU) 2023/1542 — and the change of legal instrument matters as much as the content. A regulation applies directly in every member state, no national transposition required. It covers the entire battery lifecycle, which means it doesn't stop at manufacturers: companies that hold, collect or move used batteries are inside its scope too.
This overview focuses on what the regulation means for that group — scrapyards, dismantlers, fleets, retailers and industrial operators with lithium-ion batteries on site. (It's an orientation, not legal advice; obligations depend on your role and member state.)
The regulation in one paragraph
2023/1542 entered into force in August 2023 and has been applying in stages since early 2024. It sets rules for every battery category — portable, light means of transport (LMT), SLI, industrial and EV — covering sustainability requirements (carbon footprint, recycled content), due diligence, labelling, collection targets, recycling efficiency, and a digital Battery Passport for EV and larger industrial batteries.
What matters if you hold used batteries
1. Waste batteries have a mandatory destination
Used batteries may not be landfilled, incinerated or left in general-waste streams. They must enter formal collection and treatment channels, and recyclers must meet rising recycling-efficiency and material-recovery targets for lithium, cobalt, nickel and copper. Practically: the informal routes that used to absorb old batteries are being squeezed shut, and holders are expected to hand batteries to documented, certified channels.
2. Documentation is the new default
The regulation's logic runs on traceability. Producers must register and finance take-back; treatment operators must report; and from 2027 EV and larger industrial batteries carry a Battery Passport with data on composition, capacity and state of health. For anyone holding batteries today, the direction is clear: a pallet of packs with no paper trail is increasingly hard to sell, move or even dispose of. Chain-of-custody records — what left your site, when, to whom — are becoming the baseline auditors expect.
3. Second life is explicitly legitimised
Crucially for value recovery, the regulation recognises repurposing and second-life use: a used EV battery prepared for a new purpose (like stationary storage) can stop being "waste" and become a product again — with conditions on who does it and how its condition is documented. This is the legal foundation under the entire second-life market, and it rewards exactly one thing: measured, documented battery health. Untested packs can't make that transition.
4. Transport rules still apply on top
Nothing in 2023/1542 relaxes dangerous-goods law. Used lithium-ion batteries remain Class 9 goods under ADR for road transport, with stricter provisions for damaged or defective units — and cross-border movements of waste batteries add waste-shipment requirements. Moving batteries to a buyer or recycler is a regulated logistics task in its own right.
Dates worth knowing
- February 2024 — the regulation's main provisions began applying across the EU.
- 2025 onwards — carbon-footprint declarations phase in for EV batteries; recycling-efficiency targets tighten; due diligence obligations start for larger companies.
- February 2027 — the Battery Passport becomes mandatory for new EV and LMT batteries and larger industrial batteries placed on the market.
- 2027–2031 — collection targets rise (63% for portable batteries in 2027, 73% in 2030) and minimum recycled-content requirements approach for new batteries.
Switzerland isn't an EU member, but Swiss companies trading batteries with the EU market operate inside this framework in practice — and Swiss law imposes its own return and disposal obligations for batteries.
The practical takeaway
For battery holders, 2023/1542 turns a vague duty ("dispose of batteries responsibly") into a documented pipeline: collect formally, test and document, repurpose what qualifies, recycle the rest through certified channels — with records at every step. Companies that set up that pipeline early convert a compliance burden into a revenue stream; the batteries were worth something all along.
That pipeline is literally our business model. We collect used EV, e-mobility and industrial batteries, grade every asset, and route each one — documented — to reuse or certified recycling.
Want your batteries inside a compliant pipeline by next month? Start with the collection form.