How can battery manufacturers strategically prepare for the EU’s new rules?

It has taken a long time to reach this point. Three years to be precise. But as of yesterday, the European Union’s new rules on batteries are now active. In light of this, I thought it would be worth diving into a question Infyos has received time and time again: How do I comply with the various sustainability requirements before the regulation’s deadlines?

For some, this is a billion dollar question. Those who don’t answer it face being cut out from Europe’s battery market, which is projected to reach $43.84 billion over the next five years. Thankfully, there is still time to answer it, but it will require manufacturers to act quickly and be strategic about which requirements to focus on first.

The sustainability requirements come in at staggered intervals (see Figure 1), with the carbon footprint requirements and due diligence obligations being the first major ones to hit manufacturers in February and August 2025. After that, there is a flurry of activity that culminates in the regulation’s well known product-level reporting requirement, the battery passport, in 2027.

In response, we are seeing manufacturers focus their efforts on preparing for the more immediate carbon footprint and due diligence requirements, which both, among others, require a system in place to engage with and collect accurate data directly from suppliers. The due diligence requirements, for example, include a supplier tracking system to identify upstream suppliers and collect detailed information on the provenance of the raw materials present in the battery.

The systems that manufacturers put in place for these more pressing deadlines will set a solid foundation for compliance with future requirements, including the battery passport, as it establishes a connection between the different nodes of the value chain and enables companies to collect the required information that feeds into the passport in 2027.

The fact that this phased approach is front and centre is a positive sign for the European manufacturers, with industry players seeing sustainability as one way to establish competitive advantage in an otherwise difficult market. Those who understand the relationship between the major requirements and their deadlines and deploy their resources strategically will therefore be well equipped to realise this aspiration.

That’s plenty to think about this week, but if you’re eager for more, consider joining our in-house sustainability expert Jeff and me this Thursday lunchtime as we discuss the incoming rules and how manufacturers can stay ahead in more detail.

Until then!

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