European Commission Proposed Harmonized Labeling Specifications

On December 22, 2025, the European Commission notified the World Trade Organization (WTO) of a draft Implementing Regulation regarding harmonized specifications for battery labeling. This proposal establishes standardized rules for implementing the requirements of Articles 7 and 13 of Regulation (EU) 2023/1542. Article 7 specifically governs the carbon footprint declaration, while Article 13 covers general marking and labeling obligations for all battery categories.

To comply with these emerging standards, manufacturers must maintain precise data on the chemical composition of their products. This includes knowing the names and concentrations of restricted and hazardous substances (as defined in Article 4), as well as identifying any critical raw materials present in concentrations above 0.1% by weight (w/w). Compliance Data eXchange (CDX) can facilitate the collection and management of this granular supply chain data, which is now required for all battery types.

The draft regulation is scheduled for adoption by April 20, 2026, with the public comment period open until January 26, 2026. Full text of the proposal and detailed design specifications can be found in the WTO notification documents and Annex on label design.