The European Commission published COM(2025) 981 final (proposal) to amend Regulation (EU) 2023/1542 (and also references amendments involving Regulation (EU) 2024/1244) aiming to simplify and clarify certain requirements and reduce administrative burden. The research notes examples including clarifications to the producer definition for cross-border selling, refinements to SVHC labelling scope, adjustments related to LMT battery removability/replaceability approach, and removal of certain redundant Commission reporting. Compliance teams should monitor this proposal because it may change how obligations are interpreted or applied if adopted.
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.
The European Commission published proposal COM(2025) 982 to amend Regulation (EU) 2023/1542 on batteries and waste batteries regarding cross-border participation in Extended Producer Responsibility (EPR) schemes. The proposal aims to simplify obligations for producers selling products in other Member States by clarifying participation requirements in EPR schemes established in those Member States. This reduces administrative burden while ensuring producer responsibility obligations are properly fulfilled. The proposal also amends Regulation (EU) 2025/40 on packaging and packaging waste with similar cross-border EPR provisions.
The European Commission published a legislative proposal (COM(2025) 982) to suspend the application of Article 56(3) of Regulation (EU) 2023/1542 (authorised representative requirement linked to extended producer responsibility for batteries) until January 2035. If adopted, the change would reduce administrative burden for certain cross-border sales scenarios by altering when/where an authorised representative must be appointed for EPR purposes. This is a proposal (not yet adopted), and should be tracked for potential downstream impacts on EPR registration strategy and representation arrangements across Member States.
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.
The European Commission adopted proposal COM(2025) 981 on 10 December 2025 to amend Regulation (EU) 2023/1542 as part of an omnibus legislative package addressing circular economy legislation. The proposal seeks to modify certain requirements under the Battery Regulation following the Commission's stress-testing exercise and stakeholder engagement, as part of the simplification and competitiveness agenda. The omnibus package addresses legislation related to the circular economy, industrial installations, geospatial data management, and environmental permitting.
A draft Commission Delegated Regulation (consultation-stage) proposes amending Regulation (EU) 2019/1021 to add medium-chain chlorinated paraffins (MCCPs) to Annex I (Part A), aligning with Stockholm Convention COP-12 Decision SC‑12/10. The draft proposes an unintentional trace contaminant (UTC) limit of 0.1% by weight (1,000 mg/kg) for MCCPs in substances, mixtures and articles, and describes time-limited exemptions (5 years, with a possible additional 5-year extension) for certain uses (e.g., metalworking fluids in professional/industrial settings, aerospace/defence applications, medical/IVD devices, and certain spare-parts/repair contexts). Compliance teams should begin supplier engagement and material verification planning for MCCP presence and evaluate whether any exempted uses apply to their products and lifecycle/spare parts obligations if/when the amendment is finalized.
A draft Commission Delegated Regulation (consultation-stage) proposes amending Annex I (Part A) of Regulation (EU) 2019/1021 to list chlorpyrifos as a persistent organic pollutant, aligning with Stockholm Convention COP-12 Decision SC‑12/9. The draft indicates chlorpyrifos would be listed without EU-specific exemptions (noting it is not approved under EU plant protection products/biocides regimes) and would set an unintentional trace contaminant (UTC) limit applicable to substances, mixtures, and articles for enforcement of the general prohibition. Compliance teams should anticipate future supply-chain restrictions and need to verify chlorpyrifos absence/trace levels in articles and mixtures once finalized and published.
The European Commission opened a 'Have Your Say' consultation (initiative page) related to a draft delegated amendment to the EU POPs Regulation (EU) 2019/1021 concerning long-chain perfluorocarboxylic acids (LC‑PFCAs; described in secondary sources as C9–C21 PFCAs), their salts and related compounds, with the objective of listing them in Annex I (Part A) (prohibited POPs). Compliance teams should monitor the final delegated act text once adopted/published for specific unintentional trace contaminant limits, any exemptions, and application dates affecting substances/mixtures/articles containing LC‑PFCAs and related substances.
The European Commission announced recognition of the Responsible Minerals Assurance Process (RMAP) as the first supply chain due diligence scheme recognised under Regulation (EU) 2017/821 (EU Conflict Minerals Regulation), via Implementing Decision (EU) 2025/2071. This is directly relevant to CMRT users because RMAP is administered by the Responsible Minerals Initiative (RMI), which also maintains the CMRT. The recognition increases the compliance value of CMRT/RMI-aligned due diligence outputs for EU importers of 3TG (tin, tantalum, tungsten, gold) by allowing reliance on a recognised scheme to help demonstrate conformity with EU due diligence obligations.
Commission Implementing Regulation (EU) 2025/2289 establishes the reporting format that Member States must use when submitting waste battery data to the Commission under Article 76(1) of Regulation (EU) 2023/1542. The regulation specifies that data must be reported separately for each battery category defined in Article 1(3) and differentiated by battery chemistries. Member States must use Tables 1-5 of Annex I for their reporting submissions, creating a harmonized EU-wide reporting framework for waste battery statistics.
A published EU amending act (“stop-the-clock”) postpones the application date of the EU Battery Regulation’s due diligence obligations to 18 August 2027 (from 18 August 2025, per the research summary). The same change also extends the deadline for the European Commission to publish due diligence guidelines to 26 July 2026 (from 18 February 2025, per the research summary). This affects compliance program timelines for in-scope economic operators required to implement battery supply-chain due diligence processes and to align internal procedures with forthcoming Commission guidance.
Regulation (EU) 2025/1561 amends the EU Battery Regulation (EU) 2023/1542 to postpone battery supply chain due diligence obligations from August 18, 2025 to August 18, 2027. The regulation also extends the deadline for Commission guidelines from February 18, 2025 to July 26, 2026. This provides companies additional time to establish due diligence policies for cobalt, lithium, natural graphite, and nickel supply chains, and allows for the development of third-party verification infrastructure (notified bodies).
Commission notice C/2025/4907 provides guidance on implementing Article 20a paragraph 3 of the revised Renewable Energy Directive, covering real-time, cost-free sharing of electric vehicle battery data with users and authorized third parties. Includes elements such as state of charge, health of the battery, and other performance parameters. Supports transparency and energy transition objectives relevant to Battery Regulation data sharing requirements.
The European Commission published guidance (C/2025/4907) on battery-related data sharing under Article 20a, paragraph 3 of the revised Renewable Energy Directive. The guidance helps EU Member States implement data sharing requirements for batteries used in renewable energy applications, which intersects with the EU Battery Regulation's data and traceability requirements. This supports implementation of both frameworks for batteries in energy storage and renewable energy systems.
Regulation (EU) 2025/1561 amends Regulation (EU) 2023/1542 regarding obligations of economic operators concerning battery due diligence policies. The amendment modifies the due diligence requirements for companies placing batteries on the EU market, affecting supply chain traceability, documentation, and third-party verification obligations. Economic operators must align their compliance programs with the revised due diligence framework.
Regulation (EU) 2025/1561 amends Regulation (EU) 2023/1542 as regards obligations of economic operators concerning battery due diligence policies. As reflected in the research summary, the amendment postpones the application date of Article 48(1) due diligence obligations from 18 August 2025 to 18 August 2027 and shifts the timeline referenced for Commission due diligence guidelines (Article 48(5)) to 26 July 2026. Compliance teams subject to battery raw-material due diligence (and related third-party verification/notified body expectations) should update project plans, supplier engagement schedules, and assurance readiness to the revised timeline.
The European Commission published Delegated Regulation (EU) 2025/606 setting the methodology for calculating and verifying recyclers’ recycling efficiency (including for lead-acid, nickel-cadmium, lithium and other batteries) and for calculating/verifying material recovery (including cobalt, copper, lithium, nickel, and lead). The act also introduces a harmonised documentation format that recyclers must provide to Member State competent authorities. This is a binding implementing measure under Regulation (EU) 2023/1542 that affects how recyclers generate and substantiate performance data used for compliance with recycling-efficiency and material-recovery obligations and downstream reporting/data needs.
The European Commission published Delegated Regulation (EU) 2025/606 under the EU Batteries Regulation (EU) 2023/1542. The delegated act establishes harmonised methodologies for calculating and verifying (1) recycling efficiency and (2) material recovery from waste batteries, and provides a harmonised format for documentation to be supplied by recyclers to Member State competent authorities. This is directly relevant to battery recyclers and producer responsibility schemes because it standardises evidence and calculation approaches used to demonstrate performance against Battery Regulation requirements.
The European Commission published delegated rules under Regulation (EU) 2023/1542 establishing harmonised methodologies to calculate and verify recycling efficiency for waste batteries (including lead-acid, nickel-cadmium, lithium and other categories) and to measure material recovery for cobalt, copper, lithium, nickel and lead. The rules also introduce a harmonised documentation format that recyclers must provide to Member State authorities, supporting consistent compliance evidence and enforcement of Batteries Regulation waste-battery targets (incl. Annex XII-related obligations). The Commission news item states the methodology enters into force on 24 July 2025.