Analysis of EU and UK Battery Legislation
Challenge
Artemis Technologies, a provider of zero emission solutions for the maritime sector, requested expert insight into current and potential future battery legislation that could directly or indirectly impact their operations.
Legislative frameworks around battery manufacture and usage have continued to evolve in recent years, in part to reflect the increased demand for batteries across a range of sectors, but also to support policy priorities in areas such as decarbonisation, exposure to harmful materials, and promoting circular economy principles.
In the European Union, for example, the Sustainable Batteries Regulation 2023/1542, adopted in July 2023 (repealing the Batteries Directive 2006/66/EC), introduced provisions in four key areas - (i) sustainability and safety, (ii) supply chain management, (iii) labelling and information, and (iv) end of life management – which affect the entire battery lifecycle. The regulation has implications for the whole value chain, including manufacturers, producers, importers and distributors of every type of battery placed on the EU market, with obligations coming into force from 2025 onwards.
Meanwhile, the UK Battery Strategy (2023) is expected to prompt changes in the Batteries and Accumulators Regulation (2008) and the Waste Batteries and Accumulators Regulation (2009).
With the policy landscape undergoing such rapid change, businesses such as Artemis Technologies value the specialist support we can provide that helps ensure they not only comply with existing legislation, but also gain an early understanding of potential changes and are readily prepared to meet future requirements.
Approach
As a first step, the Ricardo team worked with Artemis Technologies to understand the full extent of the battery value chain that their operations are engaged with (e.g. extraction of raw materials, battery manufacturing and assembly, in-use, collection and transport, and finally recycling, reuse and waste disposal).
Our experts then identified the relevant legislation, policies, strategies and plans that were likely to impact operations and battery value chains in both the UK and Europe. Whilst the Sustainable Batteries Regulation was identified as the primary piece of legislation likely to affect Artemis Technologies, further legislation was also taken into account, including the Industrial Emissions Directive (2010/75/EU) and Regulation on Critical Raw Materials (EU 2024/1252) in the EU, and the UK’s Battery Strategy (2023) and existing battery regulations which transposed the EU’s previous Batteries Directive.
The Ricardo analysts undertook a deep-dive review of each piece of legislation, identifying key requirements for the relevant value chain roles (including timelines for compliance if relevant), and specifying how and where specific responsibilities lie.
Results
Upon completion of the technical deep-dive review, Artemis Technologies were presented with a detailed final report that included a summary of the status of identified legislation, along with key timelines, requirements, and the respective responsibilities of Artemis Technologies and/or relevant third parties in local markets.
The report also provided comparisons of the regulatory requirements in different target markets to highlight potential synergies and identify possible opportunities and challenges arising from the compliance with the legislation.