European Commission publishes proposal COM(2025) 981 to amend Battery Regulation (producer definition, hazardous substance labelling scope, LMT removability/replaceability, reporting simplification)

The European Commission published a legislative proposal (COM(2025) 981) to amend Regulation (EU) 2023/1542. The proposal would (among other changes) clarify the producer definition to cover sellers established outside a Member State irrespective of selling technique, add precision to hazardous-substance labelling scope by referencing SVHC concepts under REACH/CLP, adjust removability/replaceability expectations for LMT battery packs to module level (rather than cell level) for safety/repairability balance, and streamline certain Commission reporting obligations related to Member State waste-battery data quality. This is not yet adopted; compliance teams should track the legislative process because the amendments could change producer/EPR scoping, labelling interpretation, and design-for-removal obligations for LMT batteries.