EU Battery Regulation
Turn EU Battery Regulation into a structured, auditable process
Manage due diligence, supplier data and Digital Battery Passport requirements in one system, without spreadsheets, manual processes or fragmented tools.
EU Battery Regulation (EUBR) is a data problem, not just a compliance task
The EU Battery Regulation (2023/1542) spreads obligations across minerals due diligence, material traceability, carbon footprint declarations, recycled content targets, and the Digital Battery Passport, each with its own timeline and data demands. For most companies, this is not a lack of understanding. It is a lack of structure.
Supplier data is fragmented, validation is manual, and audit requirements are increasing. Without a system, compliance becomes difficult to manage and even harder to prove.
CDX solves this by centralizing, validating and structuring compliance data in one system.
Why this matters now
- Market access is at risk. Non-compliant batteries cannot be placed on the EU market.
- Your suppliers are part of your compliance. You depend on their data.
- One dataset supports multiple regulations. CSRD, CSDDD and EU Taxonomy.
- Compliance affects access to finance. ESG data is increasingly required.
- Transparency creates reputational risk. Audit requirements are becoming standard.
What does EU Battery Regulation looks like in practice?
Challenge |
CDX Advantage |
|
|---|---|---|
| EMRT data collected manually from individual suppliers, with no centralised aggregation or automated validation | Centralised EMRT data collection with automated validation, deduplication and gap detection | |
| Limited traceability of smelters, refiners and mine-of-origin; high-risk nodes not systematically identified | Full supply chain mapping of smelters, refiners and mines, with flagging of high-risk sourcing nodes | |
| Material composition data fragmented across suppliers and internal systems | Centralised material declarations supporting battery chemistry reporting and regulatory compliance | |
| No structured data foundation for Digital Battery Passport requirements | Structured data points covering battery chemistry, technical performance and responsible sourcing (EMRT), providing a foundation for Digital Battery Passport (DPP) integration | |
| Compliance data collected and maintained separately for each obligation | Single dataset reused across EU Battery Regulation, REACH and Conflict Minerals reporting, with supply chain data that can also feed broader ESG due diligence processes | |
| High manual effort to collect, consolidate and prepare data for audits | Automated supplier engagement workflows with validation rules and reporting | |
| Compliance data spread across multiple systems, making audit preparation time-consuming and inconsistent | Centralised, structured data records supporting traceability and audit documentation |
Benefits of Using CDX
CDX simplifies and streamlines product compliance across industries by offering a powerful platform for material data management. It ensures compliance with global regulations, enhances supply chain transparency, and reduces operational risk.
Comprehensive Regulatory Compliance Across Multiple Industries
- CDX supports compliance with major global regulations like REACH, RoHS, SCIP, PFAS, California Proposition 65, EU POPs, TSCA, EU Battery Regulation (2023/1542), and more.
- CDX includes substance lists like AD-DSL, HEDSL, GADSL, RISL, and the IAEG PFAS List, ensuring industry-specific compliance coverage.
Simplified Supply Chain Communication
- Built-in workflows and multilingual communication tools enable seamless data exchange between suppliers and customers.
- Free for suppliers to respond to material data requests, improving data accuracy and response rates.
- CDX enables multi-tier data requests and traceability, reducing manual follow-ups and ensuring a smoother compliance process.
Automated Data Collection and Reusability
- CDX allows for data reuse by linking material declarations (MDS) and supplier inputs across multiple products and customers.
- It includes tools to import/export standardized data (e.g., IPC-1752A, IPC-1754), minimizing duplication and saving time.
SCIP Database Integration
- CDX automates the creation and submission of SCIP dossiers, ensuring compliance with EU Waste Framework Directive requirements.
- It supports ECHA´s API for direct uploads and manages required data such as substance of concern, article identifiers, and material categories.
Risk Mitigation
- Helps prevent product recalls by ensuring accurate tracking of hazardous and restricted substances throughout the product lifecycle.
- Supports early detection of non-compliant materials, reducing regulatory exposure and costly late-stage design changes.
Security & Data Protection
- Adheres to high security standards such as ISO certifications and Oracle-powered cloud infrastructure.
- Ensures secure data storage, controlled access, and compliance with global data protection regulations.
Easy Integration with Existing Systems
- Offers APIs and web services for smooth connection to ERP, PLM, and other enterprise systems.
- Compatible with multiple data formats including IPC, IEC, and IMDS, reducing technical friction.
One Platform - Two Powerful Solutions
Material Data Reporting
Stay ahead of global regulations like REACH, SCIP, and RoHS with CDX´s Material Data Reporting tools. Collect, validate, and share material data across your supply chain with ease. Our advanced features ensure compliance, transparency, and streamlined communication.
Responsible Minerals Reporting
Take control of your conflict minerals compliance with our Responsible Minerals Reporting solution. Designed for regulatory frameworks like the EU Conflict Minerals Regulation and the U.S. Dodd-Frank Act, CDX empowers your team to meet due diligence requirements and drive sustainable sourcing.
EU Battery Regulation: What You Need to Know
What is the EU Battery Regulation?
The EU Battery Regulation (2023/1542) entered into force on 17 August 2023 and replaces the previous Battery Directive. It applies to all battery types: portable, light means of transport (LMT), electric vehicle (EV), industrial and starting, lighting and ignition (SLI) batteries placed on the EU market or put into service in the EU. The regulation is built on four pillars:
- Sustainability and safety,
- Due diligence for critical raw materials,
- Information and labelling, and
- End-of-life management.
What makes it different from earlier legislation is that it is not just about hazardous substances and Extended Producer Responsibilities (EPR). It is not just about what is in the battery. Companies must trace where their materials come from and take responsibility for those batteries when they reach end of life.
Why does the EU Battery Regulation matter to my business right now?
EU Battery Regulation is not a future compliance challenge. The first obligations are already in force, and the commercial and legal consequences of being unprepared are real for manufacturers, importers and suppliers across the battery value chain.
Five reasons it matters now:
- Market access is at stake
Non-compliant batteries cannot be placed on the EU market. Battery Regulation introduces a broad and growing set of requirements phased in progressively, with new obligations entering into force each year. Which requirements apply, and when, depends on the battery type and the role your company plays in the supply chain. Staying on top of which deadlines affect you is no longer optional. - Suppliers are affected too
Regulatory obligations fall differently across the supply chain. But companies above the relevant thresholds (manufacturers, importers, brand owners) need verified compliance data from their suppliers to meet their own obligations. Regardless of your own direct scope, if you supply into the battery value chain, your customers will ask. - One dataset, multiple regulations
The compliance data you collect for Battery Regulation supports far more than one legal obligation. The same material and supply chain data feeds CSRD value chain reporting, CSDDD due diligence evidence and EU Taxonomy criteria. Build the infrastructure once, use it across all of them. - Better access to sustainable finance
Verifiable product and supply chain compliance data (carbon footprint declarations, material traceability, due diligence records) helps you meet the ESG criteria that banks, investors and EU funding programmes increasingly apply. Companies that can demonstrate it have a real advantage. - Reputational risk is real
Battery Regulation introduces new transparency and audit requirements that will become part of everyday business conversations with customers, investors and regulators alike. Companies that build their compliance data now will be ready for those conversations. Those that wait risk finding themselves unprepared at the worst possible moment.
Who needs to comply with the EU Battery Regulation?
The regulation applies to manufacturers, importers and distributors placing batteries on the EU market. Obligations are extensive and vary by battery type, company size and role in the supply chain. Among the most significant:
- Carbon footprint declarations: mandatory for EV batteries first, extending to other battery types in later phases
- Due diligence for critical raw materials: applies above relevant turnover thresholds for cobalt, lithium, nickel and natural graphite
- Digital Battery Passport: mandatory for EV, LMT and industrial batteries above 2 kWh
- Recycled content targets: minimum thresholds for cobalt, lithium, nickel and lead in new batteries
- Extended Producer Responsibility (EPR): waste collection, take-back and recycling obligations across battery types
This is not a complete list: the regulation also covers labelling, performance, safety and conformity assessment. If you place batteries on the EU market, the question is not whether it affects you, but which obligations apply first.
Even companies not directly in scope are affected. Manufacturers, importers and brand owners who do fall under the regulation will require verified compliance data from their entire upstream supply chain, which means suppliers need to start preparing now.
How does CDX help with Digital Battery Passport readiness?
The Digital Battery Passport is one of the most complex data challenges the battery industry has faced. It requires material composition records, carbon footprint data, responsible sourcing declarations, performance information and recycling data, each coming from different systems, teams and supply chain tiers. No single platform covers all of it, and companies that wait until 2027 to start gathering that data will not have enough time.
DXC's integrated solutions, CDX and MaCS (Material Collector System) together with carefully selected external partners, create the data foundation needed to support a complete Digital Battery Passport process. For the automotive industry, International Material Data System (IMDS) joins this ecosystem, enabling an end-to-end solution from data collection to the final battery passport.
The data you collect and validate in CDX today (material composition, responsible sourcing declarations, smelter and refiner mappings, country of origin and audit status) is already part of that foundation. When you are ready to move toward a Digital Battery Passport, the underlying data layer is already in place.
How does the EU Battery Regulation connect to other EU frameworks?
Battery Regulation does not stand alone; it is part of a broader EU legislative push on sustainability and supply chain transparency. Key frameworks that overlap or interact with it directly:
- European Green Deal and Circular Economy Action Plan: set the strategic direction for climate neutrality and resource efficiency that Battery Regulation operationalises
- Critical Raw Materials Act (CRMA): secures EU access to the strategic materials that Battery Regulation requires companies to trace and report on
- Ecodesign for Sustainable Products Regulation (ESPR): provides the horizontal framework for Digital Product Passports, of which the Digital Battery Passport is one sector-specific implementation
- Corporate Sustainability Reporting Directive (CSRD): overlaps directly through value chain reporting requirements, particularly ESRS E5 (resource use and circular economy) and S2 (workers in the value chain), and depending on your double materiality assessment, potentially E3 or E4 for environmental risks in upstream processing
- Corporate Sustainability Due Diligence Directive (CSDDD): adds mandatory value chain due diligence obligations that closely mirror Battery Regulation requirements for mineral supply chains
What happens if a company does not comply with the EU Battery Regulation?
Batteries that do not meet Battery Regulation requirements cannot be placed on the EU market. Member States are establishing enforcement regimes with financial penalties for violations. Companies that cannot demonstrate due diligence compliance when notified bodies conduct verification will face serious operational and reputational consequences.
Perhaps more immediately: large customers and OEMs are already requiring responsible sourcing documentation from their suppliers. Non-compliance creates commercial risk well before regulatory deadlines arrive.
What are the key EU Battery Regulation deadlines?
EU Battery Regulation compliance obligations span from 2024 to 2031, covering carbon footprint declarations, Digital Battery Passport requirements, supply chain due diligence, recycled content targets and more. Which obligations apply depends on your battery type, company size and role in the supply chain. The earlier you build your compliance data infrastructure, the better positioned you are when the next deadline arrives.
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