Contact

The role of batteries in our economy is exploding. From electric vehicles and energy storage to medical devices and industrial applications, lithium batteries are the beating heart of innovation everywhere. This growth also brings new challenges. Safety, sustainability and transparency in the chain are becoming more important than ever, and this is precisely where the European Union is taking firm action.

With the new EU Battery Regulation (EU 2023/1542), which will take full effect from 2027, the playing field is changing dramatically. The regulation not only sets higher requirements for the production and recycling of batteries, but also imposes new obligations for transport and packaging. Consider stricter requirements around traceability through the Battery Passport, mandatory QR codes, and clear rules for the safe transportation of both new and used or defective batteries.

For companies in the industry, this means that packaging and logistics choices are no longer just operational details. They will become a strategic factor in compliance, cost control and risk management. Those who start preparing now can make the difference in 2027 between a smooth supply chain and costly disruptions.

Overview of the EU Battery Regulation (EU 2023/1542).

The European Union has introduced a completely new legal framework with the Battery Regulation (EU 2023/1542), replacing the former Battery Directive 2006/66/EC. Whereas the directive mainly regulated the end-of-life cycle, the new regulation looks at the entire chain: from design and production to use, transport and recycling.

Core pillars of the regulation

  1. Sustainability and CO₂ footprint
    • Manufacturers must report on the environmental impact of their batteries from 2024-2025.
    • Thresholds for CO₂ emissions and mandatory minimum percentages of recycled materials (e.g. lithium ≥ 50% recovery, cobalt/copper/nickel/lead ≥ 90%) follow towards 2027.
  2. Safety and compliance
    • Batteries must comply with CE marking and conformity assessment.
    • Test standards such as UN 38.3 continue to guide transport and storage.
  3. Traceability and transparency
    • The introduction of the Battery Passport as of Feb. 18, 2027, is one of the biggest changes.
    • Each industrial battery ≥ 2 kWh, EV battery or LMT battery will have a unique digital identity via QR code, with information on composition, origin and reusability.
  4. Access and replaceability
    • As of Feb. 18, 2027, portable batteries must be replaceable by the end user, and larger battery types by a qualified professional.
    • This requires manufacturers and logistics chains to consider return flows and service processes.
  5. Due diligence in the chain
    • Suppliers of critical raw materials must demonstrate compliance with due diligence requirements.
    • Its entry into force has been delayed until Aug. 18, 2027, but the impact on supply chain management is significant: traceability, auditing and reporting will become standard.
Een medewerker van Faes stapelt zorgvuldig dozen op een pallet, gebruikmakend van StackAssist voor een optimale belading van zijn transport.

Why this is relevant to transportation and packaging

This regulation is not a transportation law (like ADR or IATA), but puts additional layers on top of existing rules. Companies will soon have to align their packaging and logistics processes with:

  • Multiple labeling (UN marking, Class 9 label, lithium marking and QR code).
  • Data integration: packaging choices and test certifications must be consistent with the Battery Passport.
  • Circular packaging models: as return flows and replaceability become mandatory.

The message is clear: the EU Battery Regulation (2023/1542) makes packaging and transport no longer operational peripheral issues, but crucial links in compliance, sustainability and strategic supply chain management.

2027 milestones that impact transportation and packaging

The EU Battery Regulation (EU 2023/1542) will be introduced incrementally, but 2027 represents the real tipping point. From that year, provisions will apply that directly affect not only producers, but also logistics and packaging processes. The four main milestones are summarized below.

  1. The Battery Passport and QR code (likely from Feb. 18, 2027)

Starting Feb. 18, 2027, all industrial batteries of at least 2 kWh, LMT batteries and EV batteries will have a mandatory Battery Passport. This passport is digitally accessible via a QR code on the battery and contains information on its composition, carbon footprint, source of raw materials and recyclability.

For packaging, there is currently no mandatory reporting on carbon impact. However, since the European Commission is expected to develop this topic further, it makes strategic sense for companies to start measuring and reporting the environmental impact of packaging now.

Implications for packaging and transportation

  • Packaging should provide sufficient surface area for durable and legible labels that remain intact during storage and transportation.
  • Logistics systems must be able to scan and link QR data to transportation documentation and supply chain platforms.
  • There is a risk of label overload because existing ADR and UN markings remain mandatory in addition to the QR code.

  1. Removability and replaceability (as of Feb. 18, 2027)

As of the same date, portable batteries must be removable and replaceable by the end user. For LMT, industrial and EV batteries, a qualified professional must be able to perform replacements.

Implications

  • Return flows are increasing, requiring companies to transport used or defective batteries more often.
  • Packaging solutions must be suitable for safe transportation of used batteries, often in accordance with ADR instructions P908 or P911.
  • Logistics chains face shorter replacement cycles and greater dynamics in packaging movements.

  1. Due diligence in the chain (as of Aug. 18, 2027)

The obligation to conduct due diligence on the origin of raw materials has been pushed back to August 2027. Companies must then demonstrate that their supply chains meet environmental and human rights requirements.

Implications

  • Transportation and packaging data will become part of audits and reports.
  • Companies must demonstrate that their packaging and logistics processes are designed sustainably and responsibly.
  • Certificates and test reports, such as UN 38.3 and EUMOS 40509, are more likely to be requested as evidence in due diligence processes.

  1. Recycling and collection targets (by the end of 2027)

The regulation sets clear targets. Lithium must be recovered 50%, and cobalt, copper, lead and nickel have a 90% recovery rate. In addition, producers must collect 63% of all portable batteries.

Implications

  • Packaging designs should support reuse and recycling.
  • Closing return logistics becomes indispensable, with packaging needing to be suitable for multiple cycles.
  • Companies that already deploy their packaging in a circular manner not only benefit from cost savings, but also lead the way in compliance.

2027 as a turning point for packaging and transportation choices

2027 marks the moment when packaging and transportation become inextricably linked to European battery regulations. Companies that anticipate packaging CO₂ reporting now, develop circular packaging solutions and prepare systems for QR and data linking will soon have a clear head start. Not preparing means not only risk of fines, but also disruption and higher failure costs in the supply chain.

Added value of Faes

The EU Battery Regulation shows that from 2027 packaging and transport are no longer just operational preconditions, but strategic links in compliance, sustainability and cost control. This is precisely where Faes’ strength lies.

As a Fourth Party Packaging (4PP) partner, we take on the complete management and direction of packaging. We ensure that packaging is used optimally throughout its entire life cycle: from design and use to reuse, cleaning, repair and replacement. Because Faes operates independently, we work with multiple manufacturers and partners. This way we always guarantee the right specialization, the best price-quality and the most sustainable solution for our customers.

Our added value lies in three pillars:

  1. Compliance and assurance
    Faes translates complex regulations such as ADR, IATA, IMDG and the EU Battery Regulation into practical packaging solutions that are certified and audit-proof. Our systems are set up to meet the requirements of the Battery Passport, QR codes and future CO₂ reporting. Thus, we reduce the risk of non-compliance and help companies fulfill their audit and reporting obligations efficiently.
  2. Efficiency and risk management
    With real-time data on rotations, reuse rates and material flows, we provide insight that directly contributes to optimization of logistics and inventory management. We coordinate maintenance, cleaning and replacement through the most suitable partners, ensuring continuity with minimal packaging inventory and maximum availability. We also take administrative burdens off your hands with integral invoicing and transparent reporting, saving time and creating predictability in the process.
  3. Sustainability and future-proofing
    Faes integrates circular packaging concepts that already prepare customers for the stricter CO₂ and recycling targets coming into force towards 2027. By managing packaging smarter and more circularly, we realize value creation for the entire supply chain. Companies benefit from reuse, material optimization and clear reporting, while control always remains with the customer.

In this way, we make packaging not a cost item, but a strategic tool that provides security, reduces risk and at the same time achieves sustainability goals.

The future of batteries calls for smart packaging management

The EU Battery Regulation (EU 2023/1542) changes the rules of the game for the entire lithium battery chain. From 2027, packaging and transportation will shift from an operational necessity to a strategic focus directly linked to compliance, sustainability and risk management. Companies that prepare now for the Battery Passport, the QR code, stricter recycling targets and the impact of return flows will build a lead in the market.

The message is clear: 2027 is not a distant future, but a concrete tipping point. Those who wait risk high failure costs, fines and supply chain disruptions. Those who act now seize the opportunity to make packaging and logistics not only compliant, but also more efficient and sustainable.

With Faes as a 4PP partner, companies get the assurance that their packaging and processes meet the new requirements while contributing to grip, efficiency and circular value creation. In this way, packaging changes from a cost item to a strategic tool that makes the difference between lagging behind and leading the energy transition.

Print
Email Download PDF