The Battery Directive is gone — here is what replaced it

If you are looking for the EU Battery Directive, you are looking for something that no longer exists. Directive 2006/66/EC was repealed on 18 August 2025 and replaced by Regulation (EU) 2023/1542. That is more than a renaming: the change from a directive to a regulation altered how the rules apply, who they bind and what they demand — and any compliance file still citing the Directive is citing repealed law.

Last updated: 16 August 2026

The timeline, precisely

• 2006 — Directive 2006/66/EC adopted. As a directive, it had to be transposed into national law by each member state, producing 27 broadly similar but individually different regimes.
• 17 August 2023 — Regulation (EU) 2023/1542 entered into force.
• 18 February 2024 — most of the Regulation began to apply.
• 18 August 2025 — Directive 2006/66/EC repealed. From this date the Regulation is the only reference.
• 18 February 2027 — the battery passport becomes mandatory under Article 77.
• through to 2036 — remaining provisions phase in, including tightening recycled-content and collection targets.

The two instruments deliberately overlapped for roughly eighteen months so the transition could be gradual. That window closed in August 2025, which is why references to the Directive are now simply out of date rather than merely old-fashioned.

Directive versus regulation — why the legal form matters

This is the change most summaries skip, and it is the one with practical consequences.

A directive sets an objective and leaves each member state to write its own law achieving it. Under 2006/66/EC that meant 27 national implementations, 27 sets of registration mechanics and 27 slightly different interpretations. Compliance was, in practice, a country-by-country exercise, and a product legal in one member state could face different paperwork in the next.

A regulation applies directly and identically across the Union the moment it takes effect. No transposition, no national variants of the core obligations. For anyone selling across borders this is a genuine simplification of the substance — though extended producer responsibility registration remains a national matter, so you have not escaped country-level admin entirely.

The practical upshot: you can now read one text and know what applies in all 27 markets. Under the Directive you could not.

What actually changed in substance

The old Directive was, broadly, about the end of a battery’s life: collection targets, restrictions on mercury and cadmium, and producer responsibility for waste. The Regulation keeps all of that and adds obligations across the entire life cycle:

• Carbon footprint — declaration for defined categories, calculated to a prescribed methodology rather than self-described.
• Recycled content — minimum shares of cobalt, lead, lithium and nickel, declared per metal and rising over time.
• Supply-chain due diligence — documented policies on the sourcing of raw materials, not just on the finished product.
• Performance and durability — declared and, for some categories, minimum thresholds.
• Removability and replaceability — portable batteries must be removable and replaceable by the end user, which the Directive never required.
• The battery passport — an electronic record per individual battery, mandatory from 18 February 2027 for EV, LMT and industrial batteries above 2 kWh. This has no equivalent whatsoever in the Directive.

The Regulation also introduced its own battery categories — portable, LMT, SLI, industrial and EV — which do not map one-to-one onto the Directive’s simpler split of portable, industrial and automotive. The LMT category in particular is new, and it is the one that catches e-bike and e-scooter businesses that were previously treated as portable.

What to do if your documents still cite the Directive

This is common and mostly harmless to fix, but worth doing deliberately:

• Declarations of conformity and technical files. Any reference to 2006/66/EC or to national transposing law should now cite Regulation (EU) 2023/1542. A declaration citing repealed law invites questions you do not want during an inspection.
• Supplier contracts and quality agreements. Clauses obliging a supplier to comply with "the Battery Directive" are now pointing at nothing. Worse, they will not oblige anyone to give you the carbon-footprint or recycled-content data the Regulation requires — data you need and the Directive never contemplated.
• Product classification. Re-check which of the five categories each of your batteries falls into. If anything you sell powers a wheeled vehicle, the LMT category almost certainly applies, and LMT carries the passport obligation with no capacity threshold.
• Internal training and templates. The vocabulary changed; people repeat what the templates say.

If you want to know which parts now bite for your products, the Regulation explained covers the pillars, and the free readiness check maps a catalogue against the obligations in a couple of minutes. The complete passport field list is published free as JSON and CSV under CC BY 4.0.

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