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Effects of the Battery Ordinance on mechanical and plant engineering

Batteries are an indispensable source of energy and a key technology for the transition to climate neutrality and a more circular economy. Global demand for batteries is growing rapidly and is expected to increase 14-fold by 2030. The EU could account for around 17 percent of this demand.

The EU Battery Regulation (BattVO, 2023/1542), which was published in the EU Official Journal on July 28, 2023 and came into force on August 17, 2023, brings with it extensive new requirements. These include substance restrictions, CE marking and information requirements on electrochemical performance and durability, which have been in force since August 18, 2024.

To inform the industry about these developments, ProduktionNRW organized an information event in cooperation with VDMA Nord on 9 September 2024.

The EU Battery Regulation and the consequences for the mechanical and plant engineering industry

Alena Knauz, a consultant for product-related environmental protection at VDMA, explained that the EU Battery Regulation will replace the previous EU Battery Directive. Although some of the requirements of the BattVO have already been in force since August 18, 2024, the EU Battery Directive will remain in force until August 18, 2025, as will the German Battery Act.

The new requirements aim to make batteries sold in the EU more sustainable, more cycle-oriented and safer. For the first time, batteries are being considered and regulated holistically. The EU Battery Regulation comprises three main areas of regulation:

  • EU harmonization legislation (“CE legislation”): This requires a conformity assessment procedure, the preparation of EU declarations of conformity and CE marking.
  • Due diligence obligations in the supply chain: These aim to identify and mitigate social and environmental risks associated with raw materials for battery production.
  • Management of used batteries: Registration, take-back, reporting and information obligations must be observed here.

The mechanical and plant engineering sector is highly affected, as the regulation covers the introduction, production, manufacture and sale of batteries as well as batteries installed in machines and devices. According to the EU Battery Regulation, only batteries and machines containing batteries that have a CE marking may be placed on the market. The regulation defines batteries comprehensively, for example according to portable batteries, industrial batteries or stationary battery energy storage systems.

In summary, it was emphasized that the obligations for battery manufacturers have been greatly expanded by the BattVO. This entails considerable legal, economic and organizational challenges. In addition, the BattVO is regarded as an “unfinished” law, as many relevant obligations require further specification – here the planned time frames are viewed critically.

Exchange of experience and discussion

In the concluding discussion, various questions regarding the roles of companies under the BattVO were discussed. It became clear that there are uncertainties regarding the interpretation of the terms “producer” and “manufacturer”. The participants also dealt with questions regarding transitional periods and cross-border registrations. Overall, it became clear that the BattVO is causing uncertainty for many companies in the mechanical and plant engineering sector and that prompt regulatory clarification is urgently required.

Further information
Organizer

The event was offered by VDMA Nord in cooperation with ProduktionNRW. ProduktionNRW is the cluster for mechanical engineering and production technology in North Rhine-Westphalia and is organized by VDMA NRW. ProduktionNRW sees itself as a platform for networking, informing and marketing companies, institutions and networks with each other and along the value chain. Significant parts of the services provided by ProduktionNRW are funded by the Ministry of Economic Affairs, Industry, Climate Protection and Energy of the State of North Rhine-Westphalia.