Draft Implementing Act for Battery Labelling Response

SolarPower Europe and the Battery Storage Europe Platform successfully submitted the feedback to the draft implementing act on Battery Labelling on 26 January 2026. The Battery Labelling draft regulation defines what information must appear on battery labels to inform about aspects such as the origin, type of battery, electrochemical composition, materials and hazardous substances contained as well as carbon footprint of a battery.

While the draft implementing act provides key information for timely compliance with the Batteries Regulation (2023/1542), the proposal includes measures that could undermine the EU single market and create uncertainty regarding their interpretation, which is why we raised several important points to the European Commission:

1. Request for clarity in definitions and references regarding "Place of Manufacture" and definition of battery vs. battery system
2. Limiting carbon footprint application to the final publication of the methodology under the implementing act for Article 7 Batteries Regulation to avoid fragmentation of the EU Single Market
3. Clarifying the purpose of digital battery labelling information for consumer information, regulatory compliance and market surveillance only
4. Limiting disclosure requirements on hazardous substances to substance disclosure only in case the amount exceeds a threshold of 0.1 % weight by weight of the battery.

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