Commission publishes ‘environmental omnibus’ proposal (COM(2025) 981) to amend Battery Regulation (producer definition, labelling/substances of concern scope, and LMT battery removability/replaceability)

The European Commission issued COM(2025) 981, a proposal to amend Regulation (EU) 2023/1542. The research summary indicates the proposal would clarify the definition of “producer” (including non-established sellers regardless of sales technique), adjust the approach for removability/replaceability for LMT battery packs (module vs. cell-level), and clarify/simplify aspects of hazardous substance / substances-of-concern labelling (including reference to SVHCs). If adopted, these changes could affect producer responsibility determinations, product design/serviceability expectations for certain battery types, and compliance documentation/label content requirements.