Batteries – definition of labelling requirements

VDMA feedback on European Commissions draft Implementing Regulation laying down rules for the application of Regulation (EU) 2023/1542 of the European Parliament and of the Council as regards format and harmonised specifications for certain labelling requirements.

European battery-grade graphite offers demonstrably superior sustainability performance compared to imports: lower carbon emissions from more efficient processes and cleaner energy grids, full regulatory compliance, transparent supply chains, and respect for labour rights.

Active-Sites Consulting support climate positive action in light of sustainability and circular economy through our global presence. We see the development and implementation of EU Battery Regulation 2023/1542, Battery Passport, Digital Product Passports as an integral part of our core business, enhancing transparency, compliance, and long-term value creation, specifically for the SMEs.

MedTech Europe, the European trade association for the medical technology industry, including diagnostics, medical devices and digital health, welcomes the opportunity to provide its comments and recommendations on the draft Implementing Act laying down harmonised specifications for the labelling requirements according to Articles 7 and 13 of the Batteries and Waste Batteries Regulation (EU) 2023/1542.

APPLiA Home Appliance Europe welcomes the opportunity to provide feedback on the Draft Implementing Regulation regarding the labelling of batteries. Our members are fully committed to the successful implementation of the Batteries Regulation, supporting a digital-first approach that reduces waste and provides consumers with accurate, dynamic information.

EPBA - Consumer Batteries Europe Position on the Draft Battery Labelling ‎Implementing Act ‎ ‎ In the publication of the draft implementing act on battery labelling, the European Commission ‎addresses feasibility challenges linked to limited space on batteries and the role of digital solutions. ‎EPBA - Consumer Batteries Europe welcomes the progress made.

Position of the Polish Toy Industry Association on the draft implementing regulation laying down rules on the labelling of batteries (pursuant to Regulation (EU) 2023/1542 of the European Parliament and of the Council) Thank you for having the opportunity to comment on the draft implementing regulation laying down rules on the labelling of batteries (pursuant to Regulation (EU) 2023/1542 of the European Parliament…

Filed in Polish · English published by the European Commission

Following the publication of the Batteries labelling (new rules) for the labelling requirements of the Implementing Act under Articles 7 and 13 of the EU Batteries Regulation (Regulation (EU) 2023/1542), RECHARGE would like to share with the attached submitted paper the industrys concerns and recommendations with the ongoing consultation.

CLEPA, the European Association of Automotive Suppliers, representing over 3.000 companies, from multi-nationals to SMEs, supplying state-of-the-art components and innovative technology for safe, smart and sustainable mobility, directly employing 1.7 million people in the EU, welcomes the opportunity to provide feedback on the draft battery labelling rules under Regulation (EU) 2023/1542, and would like to submit…

E-Mobility Europe the voice of Europes e-mobility ecosystem - welcomes the publication of the European Commissions draft implementing regulation laying down harmonised specifications for the labelling requirements pursuant to Articles 7 and 13 of the Batteries Regulation (Regulation (EU) 2023/1542).

DIGITALEUROPE welcomes the continued collaborative approach on the Battery Regulation labelling provisions, including earlier discussions with the European Commission, Member States and stakeholders experts in the Expert Group on Waste. We appreciate that several of our earlier recommendations have been taken into consideration on the draft act, and the opportunity to provide the following additional feedback.

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the Commissions efforts to harmonise battery labelling requirements under Article 13 of Regulation (EU) 2023/1542.

ACEA acknowledges the updated draft Implementing Regulation on battery labelling and welcomes the direction taken by the European Commission towards greater flexibility and digitalisation of battery labelling requirements.

Ecosystem is a leading eco-organisation in France on the PWR sectors for electrical and electronic equipment and batteries. Our mission is to help extend the lifespan of equipment by supporting repair and reuse, and ensuring depollution and recycling of these products at the end of their life. We take care of household and professional EEE, lamps and batteries.

Filed in French · English published by the European Commission

Stakeholder feedback on the draft Implementing Regulation on labelling Regulation (EU) 2023/1542 Stationary battery energy storage systems This contribution is submitted by the Energy Storage Systems Association (BVES e.V.) representing manufacturers, system integrators, operators, research organisations and accredited test laboratories active in the field of stationary battery energy storage systems.

FEM welcomes this consultation in the context of the implementation of the Batteries Regulation. Our feedback acknowledges the Commission's progress on this topic and provides insights and recommendations on the provisions affecting the material handling machinery industry.

In AnnexV on the carbon footprint label, we recommend expanding the color require-ments so that a reverse layout black background with white inner elements is ex-plicitly permitted alongside the current white background specification.

The European Association of Motorcycle Manufacturers (ACEM) welcomes the possibility of submitting written feedback to the public Have your say consultation, due on the 26th of January 2026, regarding the draft Implementing Act for Articles 7 and 13 of the EUBR EU 2023/1542. The motorcycle industry remains available to collaborate closely with the European Commission and the Stakeholders.

SolarPower Europe and its Battery Storage Europe Platform are the voice for the solar PV and BESS (Battery Energy Storage Systems) sector in the EU and welcome the publication of the draft implementing act on Battery Labelling as it provides key information for timely compliance with the Batteries Regulation (2023/1542).

The European Power Tool Association (EPTA) and the European Garden Machinery Federation (EGMF) welcome the opportunity to provide feedback on the draft Implementing Regulation laying down harmonised specifications for the labelling requirements set out in Articles 7 and 13 of Regulation (EU) 2023/1542. Please find our comments in the enclosed position paper.

Doro AB welcomes the opportunity to provide feedback on the draft implementing regulation on battery labelling and thanks the European Commission for engaging stakeholders at this early stage. We fully support the objective of ensuring clear, harmonised, and accessible information for end-users, while maintaining proportionality and feasibility for different types of batteries and products.

Being a cross-sectoral association with member companies operating in different industries and across various stages in the supply chain, the Japan Business Council in Europe (JBCE) welcomes the opportunity to submit its feedback regarding the upcoming Implementing Regulation laying down rules as regards format and harmonised specifications for certain batteries labelling requirements.

We welcome the approach adopted by the European Commission aimed at ensuring access to battery-related information throughout the entire battery life cycle, notably through the combination of physical labelling, information displayed on the battery pack, and digital access via a QR code.

Filed in French · English published by the European Commission

The BMW Group welcomes the European Commission's public consultation on labelling under the EU Battery Regulation. In principle, minor adjustments should be made to the labelling requirements to ensure clarity on labels. This requires greater flexibility in labelling methods and formats. The BMW Group has listed its feedback with the most important points. Please find this overview in the document attached.

Integer is a manufacturer of batteries intended for use in medical applications. We appreciate the opportunity to provide feedback on the draft Implementing Act for Battery Labelling. We respectfully request that the European Commission consider our comments while finalizing the Implementing Regulation in order to support practical implementation of battery labelling requirements. Please refer to the attached file.

We appreciate the Commissions effort with the implementing regulation under Regulation (EU) 2023/1542 to harmonize battery labelling in order to enhance transparency, sustainability, and consumer information. We welcome the use of QR codes as digitalization is key to manage multilingual and multi-market requirements. However, we would like to highlight several points that need further adjustments.

The wording of Article 4(2) and Annex III, Part A, point VIII, refers to hazardous substances contained in batteries. The Implementing Act should instead align with the Environmental Omnibus proposal (COM(2025) 981), which refers to Substances of Very High Concern (SVHC).

EBRA welcome the opportunity to respond to the European Commission in respect of the proposed amendments and guidelines regarding the labelling of all battery categories. EBRA recognises that the Batteries Regulation was adopted in recognition of the expected demand for batteries in the coming years, the strategic role of batteries in the circular economy, and in particular, the need to establish a functioning…

Exide Technologies a manufacturer of lead and lithium based industrial and SLI batteries welcomes the European Commissions draft implementing regulation laying down rules for the application of Regulation (EU) 2023/1542 of the European Parliament and of the Council as regards format and harmonised specifications for certain labelling requirements (Implementing Regulation).

Clarios welcomes the opportunity to provide comments on the draft implementing regulation under Regulation (EU) 2023/1542 concerning the harmonised labelling requirements for batteries. As a global leader in low-voltage energy-storage solutions supplying one in three vehicles worldwide, Clarios supports the objectives of transparency, safety, and traceability pursued by the Batteries Regulation.

Mazda welcomes the opportunity to provide feedback on the European Commission's draft Implementing Regulation on harmonised specifications for battery labelling under Regulation (EU) 2023/1542 (Batteries Regulation). The Commission's efforts to enhance clarity and consistency in the proposed framework are welcomed, and certain aspects would benefit from further consideration.

We, Japanese electrical and electronic industrial associations-JEMA, JEITA, CIAJ and JBMIA (hereinafter JP4EE) welcome the opportunity to offer our comments and proposals on the draft Commission Regulation laying down rules for the application of Regulation (EU) 2023/1542 of theEuropean Parliament and of the Council as regards format and harmonised specifications for certain labelling requirements.

Makita is a leading global manufacturer of professional power tools, outdoor power equipment, and related accessories, with a strong focus on battery-powered technologies. We welcome the opportunity to provide feedback to this consultation. We supply a wide range of cordless solutions to professional users across construction, manufacturing, maintenance, and landscaping sectors.

SOMFY Group is a manufacturer of motorisation and solution for home and building applications. Our product portfolio includes appliances (motors/drive for shutters, screens, garage doors) powered by Li-ion or Ni-MH batteries as well as remote controls powered by coin batteries. In many cases the QR code and/or battery label is requested on the document accompanying the battery AND on packaging.

We welcome the opportunity to provide our comments on the draft Implementing Regulation concerning labelling requirements under the EU Battery Regulation (EU) 2023/1542. As a battery manufacturer committed to supporting the European Commissions objectives of ensuring sustainability, transparency, and consumer protection, we appreciate the efforts made to establish clear and practical labelling provisions.

In ANNEX V Format of the carbon footprint label, I think the rule The background of the label shall be 100 % white and the inner border of the label shall be 100 % black should be adjusted. Reverse color should also be allowed, that means The black background and the white inner border . The reasons are as follows： 1.

Dear European Commission Team, Please find the attached position paper from Simplo Technology Corp. regarding the draft labeling requirements of the EU Battery Regulation. As a leading manufacturer of portable battery packs, we provide these insights from the perspective of safety compliance and high-volume manufacturing feasibility.

In a global landscape defined by complex supply chains and rising environmental demands, both manufacturers and consumers are increasingly calling for clear and reliable information on product sustainability and performance. The harmonization of requirements for the labelling of all battery categories is therefore a step in the right direction.

The Toy Industries of Europe (TIE), welcomes the chance to comment on the draft Implementing Regulation detailing the label required by Regulation (EU) 2023/1542 concerning batteries and waste batteries (EUBR). Unfortunately, we are concerned that this draft legislation lacks the necessary regulatory clarity, is not technically feasible and runs counter to the Commissions simplification efforts, resulting in new…

ESPP (European Sustainable Phosphorus Platform) welcomes that the proposed update on Battery Labelling maintains and clarifies the obligation to declare Critical Raw Materials present at > 0.1% w/w (this obligation is already included in the Annexes of 2023/1254). We note that the CRM Act 2024/1252 Annex II (list of CRMs) includes both Phosphate Rock and Phosphorus.

Thank you for providing Energizer Europe, BV the opportunity to comment on the draft labelling requirements. Energizer wholly supports and endorses the positions presented in the EPBA - Consumer Batteries Europe submission and expands on a few of the topics raised in the attached comment.

Rockwell Automation welcomes the opportunity to provide feedback on the proposed EU battery labelling rules. As a global supplier of industrial automation solutions, Rockwell supports clear and harmonised requirements that strengthen transparency while avoiding disproportionate or unnecessary administrative burdens. Rockwells detailed position and recommendations are provided in the attached document.

Please find attached the expert opinion of Robert Bosch GmbH on the draft Implementing Act on Articles 7 and 13 of the Batteries Regulation. The Bosch group manufactures batteries falling within various of the battery categories of the Batteries Regulation and also produces battery-operated electrical and electronic equipment. Therefore, the Bosch group is directly affected by the draft Implementing Act.

The Austrian Federal Economic Chamber welcomes the European Commission's initiative on harmonized labeling requirements for all battery categories based on Articles 7(2) and 13 of the EU Battery Regulation (EU 2023/1542) and appreciates the opportunity to comment on it. Article 1(2) of the draft specifies how to proceed if the surface of the battery is not large enough to affix a label.

Overall, we think the proposed legislation is good. But we have some concerns that we have summarized below. The list of electrochemical compositions in Annex IV point 4 is focused on the chemistry on the cathode side. For the most part you can from this deduct what chemistry you find on the anode side.

Please find attached the opinion of the German Electrical and Digital Industry Association (ZVEI) on the draft Implementing Act on Articles 17 and 13 of the Batteries Regulation. Both battery producers and battery manufacturers and the downstream customer industries use the batteries are organised in the ZVEI.

Filed in German · English published by the European Commission

EUROMOT, the European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers, represents the key manufacturers of internal combustion engines and alternative powertrains installed in industrial non-road mobile machinery, marine and stationary applications that are operating in Europe and worldwide.

The Committee for European Construction Equipment (CECE) represents the interests of European construction equipment manufacturers. Through its national member associations, CECE speaks on behalf of an industry comprising approximately 1,200 companies, employing around 300,000 people and generating an annual turnover of 60 billion.

With regards to the requirements set out in Annex VI, Part A, and the requirements to be marked on the battery label: As a UK based battery manufacturer of 0.1% w/w need to go on the label? Why not only via the QR code?

Comment on the Draft Rule: 1. Article 1 (2): "...shall be provided on the packaging and documents accompany..." --> No need to show on both (or on all other documents). Please consider using "or" instead of "and". 2. Article 1 (5) & (6): Why can't put the QR code on "packaging"?

Uniform labeling of the CO2 footprint can improve transparency regarding the environmental impact of batteries and provide consumers with a reliable basis for making sustainable purchasing decisions. At the same time, uniform labeling provides reuse operators, recyclers, and interested consumers with essential information on chemical composition, hazardous substances, and critical raw materials.

1. Could the commission please clarify the distinction between the separate document accompaning the battery and documents accompanying the battery as referred to in the Implementing regulation? 2. For non button batteries, if a QR code is provided within the accompanying documents, is it still mandatory to affix a physical label on the packaging? 3.

1. Article 1(2) & 1(3) The text states that the information referred to in Annexes I, II and III shall be provided on the packaging and documents accompanying the battery following the specifications set out in those Annexes. Does information refer exclusively to Part A (Labelling Information) of each Annex? Or does it also include Part B (Label design)? 2.

We, JMC would like to request that the final regulation be revised along the proposals outlined below, so that the requirements remain reasonable and simple while in line with Regulation (EU) 2023/1542. 1. ANNEX I: We propose that EUBR Part A Labelling information shall set minimum necessary requirement, and label format in Part B Label design shall be optional.

1. The implementation date of the General Information on Batteries (i.e. Aug 18, 2026 or 18m after the date of entry info force of the implementing act) and the QR code implementation date (i.e. Feb 18, 2027) should be postponed and aligned on the same date. Because the General Information is not finalised and not likely to be enforced on/before Feb 18, 2027.

With regard to Article 1(2), if a battery is too small (which will apply to most portable batteries, e.g. AA batteries or AAA batteries) to display all the information there and this information may then be displayed on the packaging, why must this information be added to the accompanying documents (e.g. instructions)? Why does it mean and not or?

Filed in German · English published by the European Commission

The Ministry of the Environment of the Czech Republic (MoE) submits its contribution to the European Commission's public consultation on the draft implementing regulation pursuant to Regulation (EU) No. 1542/2023 of the European Parliament and of the Council of July 12, 2023, on batteries and waste batteries, amending Directive 2008/98/EC and Regulation (EU) 2019/1020, laying down rules for the application of…

Gigaset endorses the harmonisation of labelling requirements for batteries and commends the clear guidelines provided to manufacturers and distributors on implementing these requirements. The flexibility granted with the possibility of utilising QR codes, has been well received.

We strongly support the European Commission's push for compliance requirements for battery labels under the new Battery Act. Regarding the QR code on battery labels, we believe manufacturers should be given more design options. For example, in connected vehicles with displays, could the full battery information displayed on the battery label be replaced with the physical battery label via a screen?

We fully support the EUs objectives to promote battery sustainability and information transparency. However, the current draft provisions on label format and QR code implementation present clear technical and practical challenges, which may unnecessarily increase compliance costs and hinder the achievement of the regulation's goals. 1.

I find this Battery Regulation a very useful initiative, but would have the following comments: The QR code itself can be forged by a copier or a new one can be created by a QR generator. Furthermore, in this context, some batteries are also at risk of counterfeiting and it is therefore essential to use a security mark in addition to the QR code.

Filed in Hungarian · English published by the European Commission

With the attached position we welcome the Commissions efforts to clarify and streamline labelling requirements and welcome several improvements in the current draft. At the same time, we would like to highlight several points where further adjustments are necessary to ensure the regulation remains practical, proportionate, and aligned with industry realities.

Considering the costs needed for implementation of given regulations, this regulation will lead small and medium-sized companies and businesses into a disadvantageous position. While large organizations have the economic potential to easily implement these regulations, small and medium-sized businesses will be significantly economically affected by this requirement.

Feedback on Draft Implementing Regulation on Battery Labelling Re: Requirement to label the names and concentrations of restricted and hazardous substances referred to in Article 4(1) and (2) We respectfully submit the following concerns regarding the practical enforceability of the requirement that battery labels must include "the names and concentrations of restricted and hazardous substances referred to in…

Our company is developing, manufacturing and selling li-ion batteries for various industry sectors ranging to cover any on- and off-road moving applications. After studying EU Battery Regulation and spending nearly 3 years arounds its implementation, I am seriously worried about proposed rules regarding battery labelling.

The labelling of button cell batteries is to be on packaging or an accompanying document. It is not clear how products that are shipped from manufacturers to the EU that already contain a button cell battery should be labelled. Sometimes these products do not have any packaging, e.g. a child's battery operated book. Does the labelling (QR code) have to go on the product?

In general, the Association of Finnish Automobile Dismantlers warmly welcomes the objective of harmonising the labelling of batteries and improving the availability of information throughout the life cycle of a battery. For the car dismantling industry, battery identity, knowledge of chemical composition and safe handling are critical factors as electrification increases the amount of batteries that can be treated.

Filed in Finnish · English published by the European Commission

In the main document, an order of priority is indicated in the information to be displayed on labels, because sometimes not all mandatory information is available in the space available. The second priority corresponds to the addition of the separate collection symbol when batteries become waste: (2) separate collection symbol referred to in Article 13 (4) of Regulation (EU) 2023/1542 However, there is no space…

Filed in Spanish · English published by the European Commission

Battery labels should be required to state the number of chargedischarge cycles, determined under clearly defined and standardized reference conditions. This information is particularly relevant for high-power and high-capacity batteries, such as those used in electric vehicles and industrial or stationary energy storage applications.

As a SME trader placing decorative products with portable non-rechargeable batteries on the EU market, we would like to raise several practical and legal concerns regarding the draft Implementing Regulation, in particular Annex I and Articles 3 and 6.