EU's New Battery Labeling Rules: Carbon Footprint Grading to Reshape Global Market Access

December 15, 2025 — A draft implementing act on battery labeling quietly released by the European Commission is becoming a document of intense focus for battery manufacturers worldwide.

The draft, published on December 15, 2025, stipulates unified labeling requirements, design, size, and placement, introducing a carbon footprint performance label graded from A to E. The feedback period for this draft is open until January 12, 2026.

It explicitly mandates that electric vehicle batteries and rechargeable industrial batteries with a capacity exceeding 2 kWh must display a clear and prominent carbon footprint performance grade on the product itself.

1. The Policy Rollout

On December 15, 2025, the European Commission officially released the draft implementing regulation detailing the format and requirements for battery labeling. As a crucial supporting document to the new EU Battery Regulation adopted in 2023, this draft provides a standardized framework for communicating battery product information.

The release marks a significant step in finalizing the EU's battery regulatory framework. The draft is open for stakeholder feedback until January 12, 2026. Once finalized, the implementing act is expected to enter into force 20 days after its publication in the EU Official Journal, with the full labeling requirements applying 18 months later.

2. Key New Requirements

Compared to the old 2006/66/EC Battery Directive, the new draft significantly expands the scope and depth of information disclosure.

A central change is the introduction of a mandatory carbon footprint performance label. For electric vehicle batteries, light means of transport batteries, and industrial batteries over 2kWh, a clear A-to-E grade must be displayed. Notably, the label must also bear the specific lifecycle carbon footprint value, expressed in "kg CO₂-eq/kWh."

Furthermore, labels must now include several new data points: a list of critical raw materials present above 0.1% by weight, the specific chemical composition rather than just common names, and information on suitable fire suppressants.

3. The Carbon Footprint Grading System

The EU's carbon footprint grading system is determined using a "dynamic threshold" method based on market data.

Instead of fixed numerical limits, the EU will first collect carbon footprint data for batteries placed on the EU market over a three-year period. This data will then be statistically analyzed to establish five performance classes (A to E), with class A representing the lowest 20% of footprints and class E the highest 20%.

Each class is associated with a distinct color code. Thresholds are set independently for different battery categories. This design allows the system to adapt to market evolution and technological progress, but also means companies cannot aim for a fixed target value and must pursue continuous carbon reduction.

4. Mandatory Information Checklist

The draft outlines an unprecedented level of detail for battery labels, creating a 10-point mandatory disclosure system.

Manufacturer information includes name, registered trademark, and contact details. Product identification covers type, batch, or serial number.

Environmental and safety information requires disclosure of the exact electrochemical composition, names and concentrations of restricted/hazardous substances, and suitable fire suppressant types.

Critically, when the concentration of critical raw materials like cobalt, lithium, nickel, or natural graphite exceeds 0.1% by weight, they must be listed individually on the label.

5. Label Design Specifications

The draft sets detailed rules for the label's physical presentation. It must cover at least 5% of the battery or packaging's largest printable surface area.

Icons are limited to a maximum size of 2.5cm x 2.5cm. Labels must use an open-source font compatible with all EU official languages to ensure readability.

For small batteries with insufficient space, a "hybrid solution" is proposed. Information can be moved to the packaging or provided in full via a QR code.

For multilingual needs, the physical label can be in one language, with a QR code linking to digital versions in other languages, balancing compliance costs with member state language requirements.

6. Compliance Challenges for Companies

The new requirements present significant compliance challenges, shifting the focus from simple "packaging compliance" to comprehensive "data governance."

Building a complete product data management system is now urgent. Companies need traceability systems to collect data across the entire supply chain, from raw material extraction to manufacturing.

Calculating and verifying carbon footprint data according to the EU's prescribed PEFCR methodology requires building carbon accounting capabilities aligned with international standards.

For SMEs, these requirements may lead to substantially higher compliance costs. Labels must also comply with the European Accessibility Act, ensuring accessibility for persons with disabilities, adding further design complexity.

7. Industry Impact

The EU's new battery labeling rules will have a profound impact on the global battery value chain, shifting competition towards low-carbon and transparent operations.

Market access barriers are rising significantly. Batteries with poor carbon footprint grades (D or E) may face market exclusion, potentially rejected by automakers even if competitively priced, as they could harm the overall environmental profile of the final vehicle.

This will force global manufacturers to accelerate green transitions, invest more in optimizing supply chain emissions, adopt cleaner energy for production, and improve material recycling rates.

The rules may also accelerate the convergence of global battery standards. China is developing its own national standard for lithium-ion battery product labeling, potentially signaling a global trend towards standardized battery information disclosure.

Once implemented, a battery marked with a red "D" or "E" label, even if high-performing and low-cost, is likely to be rejected by European automakers. This transparent grading system acts as an "environmental report card" for every battery, making low-carbon performance a more critical competitive factor than capacity or price alone.

With this small label, the EU is rewriting the rules of the game for the global battery industry.

December 15, 2025 — A draft implementing act on battery labeling quietly released by the European Commission is becoming a document of intense focus for battery manufacturers worldwide.

The draft, published on December 15, 2025, stipulates unified labeling requirements, design, size, and placement, introducing a carbon footprint performance label graded from A to E. The feedback period for this draft is open until January 12, 2026.

It explicitly mandates that electric vehicle batteries and rechargeable industrial batteries with a capacity exceeding 2 kWh must display a clear and prominent carbon footprint performance grade on the product itself.

1. The Policy Rollout

On December 15, 2025, the European Commission officially released the draft implementing regulation detailing the format and requirements for battery labeling. As a crucial supporting document to the new EU Battery Regulation adopted in 2023, this draft provides a standardized framework for communicating battery product information.

The release marks a significant step in finalizing the EU's battery regulatory framework. The draft is open for stakeholder feedback until January 12, 2026. Once finalized, the implementing act is expected to enter into force 20 days after its publication in the EU Official Journal, with the full labeling requirements applying 18 months later.

2. Key New Requirements

Compared to the old 2006/66/EC Battery Directive, the new draft significantly expands the scope and depth of information disclosure.

A central change is the introduction of a mandatory carbon footprint performance label. For electric vehicle batteries, light means of transport batteries, and industrial batteries over 2kWh, a clear A-to-E grade must be displayed. Notably, the label must also bear the specific lifecycle carbon footprint value, expressed in "kg CO₂-eq/kWh."

Furthermore, labels must now include several new data points: a list of critical raw materials present above 0.1% by weight, the specific chemical composition rather than just common names, and information on suitable fire suppressants.

3. The Carbon Footprint Grading System

The EU's carbon footprint grading system is determined using a "dynamic threshold" method based on market data.

Instead of fixed numerical limits, the EU will first collect carbon footprint data for batteries placed on the EU market over a three-year period. This data will then be statistically analyzed to establish five performance classes (A to E), with class A representing the lowest 20% of footprints and class E the highest 20%.

Each class is associated with a distinct color code. Thresholds are set independently for different battery categories. This design allows the system to adapt to market evolution and technological progress, but also means companies cannot aim for a fixed target value and must pursue continuous carbon reduction.

4. Mandatory Information Checklist

The draft outlines an unprecedented level of detail for battery labels, creating a 10-point mandatory disclosure system.

Manufacturer information includes name, registered trademark, and contact details. Product identification covers type, batch, or serial number.

Environmental and safety information requires disclosure of the exact electrochemical composition, names and concentrations of restricted/hazardous substances, and suitable fire suppressant types.

Critically, when the concentration of critical raw materials like cobalt, lithium, nickel, or natural graphite exceeds 0.1% by weight, they must be listed individually on the label.

5. Label Design Specifications

The draft sets detailed rules for the label's physical presentation. It must cover at least 5% of the battery or packaging's largest printable surface area.

Icons are limited to a maximum size of 2.5cm x 2.5cm. Labels must use an open-source font compatible with all EU official languages to ensure readability.

For small batteries with insufficient space, a "hybrid solution" is proposed. Information can be moved to the packaging or provided in full via a QR code.

For multilingual needs, the physical label can be in one language, with a QR code linking to digital versions in other languages, balancing compliance costs with member state language requirements.

6. Compliance Challenges for Companies

The new requirements present significant compliance challenges, shifting the focus from simple "packaging compliance" to comprehensive "data governance."

Building a complete product data management system is now urgent. Companies need traceability systems to collect data across the entire supply chain, from raw material extraction to manufacturing.

Calculating and verifying carbon footprint data according to the EU's prescribed PEFCR methodology requires building carbon accounting capabilities aligned with international standards.

For SMEs, these requirements may lead to substantially higher compliance costs. Labels must also comply with the European Accessibility Act, ensuring accessibility for persons with disabilities, adding further design complexity.

7. Industry Impact

The EU's new battery labeling rules will have a profound impact on the global battery value chain, shifting competition towards low-carbon and transparent operations.

Market access barriers are rising significantly. Batteries with poor carbon footprint grades (D or E) may face market exclusion, potentially rejected by automakers even if competitively priced, as they could harm the overall environmental profile of the final vehicle.

This will force global manufacturers to accelerate green transitions, invest more in optimizing supply chain emissions, adopt cleaner energy for production, and improve material recycling rates.

The rules may also accelerate the convergence of global battery standards. China is developing its own national standard for lithium-ion battery product labeling, potentially signaling a global trend towards standardized battery information disclosure.

Once implemented, a battery marked with a red "D" or "E" label, even if high-performing and low-cost, is likely to be rejected by European automakers. This transparent grading system acts as an "environmental report card" for every battery, making low-carbon performance a more critical competitive factor than capacity or price alone.

With this small label, the EU is rewriting the rules of the game for the global battery industry.

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