The EU Battery Regulation 2023/1542 is now in effect, replacing the previous 2006 directive with a more stringent, unified law across all member states. This regulation addresses the entire lifecycle of batteries, aiming to create a circular economy and minimize environmental harm. A key focus is on portable batteries, including the button and coin cells common in small electronics, toys, and medical devices. The demand for batteries is expected to grow 14-fold by 2030, making these regulations critical. Ignoring these changes is no longer an option, as key obligations began applying as of February and August 2024. These rules introduce new requirements for sustainability, safety, and labeling that affect your entire supply chain. The next sections detail the specific actions you must take to ensure EU battery compliance.

A primary goal of the new regulation is to prevent accidents, particularly the ingestion of button cells by children, which can cause fatal chemical burns. To address this, products containing portable batteries must be designed so the batteries are not easily accessible. This has direct consequences for product engineering and manufacturing.

You must ensure compliance with these updated design standards:

• Battery compartments must be child-resistant, meaning they require a tool for opening or a sequence of at least two independent movements.
• The regulation applies to all products, regardless of whether the button cell is pre-installed or packaged separately.
• Products already on the market before August 2024 do not need retrofitting, but all new products must comply.
• Compliance with harmonised standards like EN IEC 62368-1 is a practical way to demonstrate product safety.

Verifying that your products meet these physical requirements is a critical first step. This leads to the equally important updates needed for your product information and battery labeling strategy.

Clear communication of risks is a central pillar of the EU’s strategy. The regulation mandates new, specific labeling for batteries and their packaging. As of August 18, 2024, CE marking is mandatory for batteries, certifying they meet EU safety, health, and environmental standards. This marking is a declaration that your product has undergone the required conformity assessment procedures.

Your packaging and documentation must now include:

1. The universal ‘crossed-out wheeled bin’ symbol for separate collection.
2. A specific warning pictogram indicating the danger of button cell ingestion.
3. Clear instructions on the safe use, replacement, and disposal of the batteries.
4. Information on the chemical composition of the battery.

The Commission is expected to adopt more detailed labeling rules by August 2025, which could become applicable as early as August 2026. Staying ahead of these changes is vital for uninterrupted market access and requires a robust battery labeling management system.

The consequences of failing to solve compliance for products with button cells are significant. National market surveillance authorities have the power to enforce these rules with immediate effect. Non-compliant products can be subjected to a sales ban across the entire EU, leading to a complete halt in revenue from a market of over 440 million consumers. Financial penalties for violations can reach tens of thousands of euros per infringement, depending on the member state.

Beyond fines, there is substantial reputational risk. A product recall or public notice of non-compliance can erode consumer trust that takes years to rebuild. The regulation expands Extended Producer Responsibility (EPR), making producers financially and logistically responsible for end-of-life battery management. This includes meeting ambitious collection targets, which rise to 63% by 2027 and 73% by 2030. To avoid these outcomes, you must engage with a German battery take-back scheme and formalize your compliance strategy.

The time to act is now. Waiting for enforcement actions is a strategy that will fail. A proactive approach is the only way to guarantee 100% legal conformity and protect your business. We strongly advise all affected companies who have not yet taken action to contact Deutsche Recycling immediately to ensure compliance as quickly as possible.

Follow these steps to secure your market position:

1. Conduct a Product Audit: Immediately review your entire product portfolio to identify every item that contains or is sold with button or coin cell batteries.
2. Verify Supplier Compliance: Demand proof of compliance from your suppliers, including technical documentation and conformity assessments for the batteries they provide.
3. Update Product Designs and Packaging: Engage your engineering and marketing teams to implement the necessary changes to battery compartments and labeling.
4. Partner with a Compliance Expert: The complexities of international regulations are difficult to manage alone. A specialist partner ensures nothing is missed.

Deutsche Recycling offers a full-service solution to manage all your EPR obligations under the new Battery Regulation. We handle registration, reporting, and take-back logistics, allowing you to focus on your core business. Take the final step toward complete peace of mind and license your batteries correctly.

The new EU Battery Regulation introduces complex, multi-faceted requirements that carry substantial risk if ignored. From product design and safety testing to labeling and end-of-life management, every step must be handled with precision. Attempting to navigate this landscape without expert support can lead to costly errors, sales interruptions, and legal penalties. By partnering with Deutsche Recycling, you gain more than just a service provider; you gain a dedicated expert team focused on ensuring your 100% compliance.

We simplify the entire process, providing clarity and taking over the administrative burden of your environmental obligations. Don’t let regulatory complexity become a barrier to your success in the EU market. Contact us today for a consultation and let us build a tailored compliance solution that protects your business and ensures your continued market access.