Position Concerning Batteries and Waste Batteries

The EU Commission has presented an ambitious proposal for future sustainability and safety requirements for batteries. The TÜV Association welcomes the plan and highlights the relevance of conformity assessment bodies in this process in its new position paper.

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Demand for batteries is growing throughout society - they are becoming increasingly important in the areas of mobility, energy and communications in particular. It is therefore crucial that their social and environmental footprint is as low as possible. In addition, the increased demand must not be at the expense of respect for human rights. That is why the TÜV-Association welcomes the EU Commission's initiative to modernise EU legislation on batteries (regulating portable, automotive, EV and industrial batteries). The inclusion of due diligence requirements for large batteries also deserves full support. It should be regarded as a starting point for the upcoming horizontal regulation on due diligence.

To achieve the ambitious goals of the Circular Economy Action Plan and the EU Green Deal, clear regulatory measures setting ambitious and binding requirements are needed. In addition to defining ambitious requirements, it is crucial to ensure their consistent and effective compliance. The TÜV-Association welcomes the European Commission's proposal to involve Notified Bodies in the conformity assessment of batteries. Third-party conformity assessment bodies can ensure that batteries meet the relevant safety and sustainability criteria, thereby preventing non-compliant products from being placed on the EU market.


  • Introduce monitoring by independent third parties and accreditation
  • Define sustainability and safety requirements
  • Monitor supply chains and define due diligence requirements
  • Set requirements for battery labeling

Download the position

Position "EU Commission proposal concerning batteries and waste batteries (COM(2020) 798)"