The new European Battery Regulation (no. 2023/1542) was published on 18 August 2023. The aim of the new law, which is applicable in all 27 member states of the European Union, is to regulate homogeneously in the single EU market battery applications and technologies which are fundamentals for the transition towards sustainable mobility and energy generation. Compliance with the requirements grants end-users products performance, durability, and sustainability.

The Regulation entered into force on 18 February 2024 and provides over the years a set of additional obligations for battery players like manufacturers, importers, and producers.

The first deadline, with a significant impact on batteries used in data centers, was set for August 18th, 2024. From that date, all batteries placed on the market must be CE marked and therefore comply with the related environmental, technical, and performance requirements.

Additional requirements include the name and address of the manufacturer which must be indicated on the battery label. The lack of these elements makes the products non-compliant with the law and therefore not marketable. Products placed on the market before August 18th or in-stock may also be used until stocks run out without reworking and re-labeling them.

It is important to underline that all Fiamm batteries used in data center applications are classified as Industrial Batteries in compliance with the new Regulation and therefore shall comply with this category's requirements. In fact, they are designed, tested, and labeled in compliance with the EN 60896-21/22 standard.

Another important innovation introduced by the Regulation is the definitions of “battery” and “manufacturer”. Battery, according to the Regulation (ref. Article 3), “means any device delivering electrical energy generated by direct conversion of chemical energy”. Therefore, any 12V block shall be considered a battery by itself and shall be CE marked accordingly.

In case several blocks are connected to each other in series or parallel, they are going to form a new battery with different characteristics from the single block used for its construction. This is typically the data center configuration, where up to hundreds of blocks are connected to a single UPS.

In accordance with battery regulation, the legal entity who makes this assembly (battery supplier, system integrator, or equipment manufacturer) becomes the manufacturer of the new battery and shall fulfill all the related obligations, which include for example, the drafting of the technical dossier with the relative declaration of conformity and CE marking of the new complete battery obtained.

The original block manufacturer has the obligation to provide, upon request and free of charge, all the technical documentation necessary to fulfill the above obligation. Fiamm Energy Technology is the manufacturer only when providing the complete battery system, including for example connections and housing racks/cabinets. In these cases, CE marking and declaration of conformity will be under its responsibility. In all other cases, this responsibility falls under the battery assembler.

“Producer” is on the other hand the legal entity placing the battery onto the market. It can coincide with the “Manufacturer” or being a different entity according to how the battery is put onto the market (ref. Article 3). Producers and Manufacturers have different obligations. Just as an indication, the first can be considered in charge of value chain due diligence, and the second in charge of technical and product obligations.

This may cause confusion as in the old Battery Directive this differentiation was not present. Considering the battery definitions introduced in the Regulation, there is also a risk of double-counting batteries placed onto the market in case they are declared by both the block manufacturer and their assembler. Placing onto the market declaration in accordance with the new Regulation will enter into force in August 2025. The battery industry is working with its category associations in order to clarify with competent authorities the situation prior to August 2025.

Fiamm Energy Technology has been closely following the new Regulation since the first draft publication in December 2020, has undertaken a series of actions to ensure compliance with all requirements within the required timeframes, and confirms all batteries placed in the market after 18th August will be CE marked.

Great attention has always been paid to environmental aspects.

As evidence of this, over 80 percent recycled lead is currently used in the production of new batteries in the Fiamm Energy Technology plants, anticipating the requirements that will be set in the Regulation starting from 2031. Lead batteries represent a model of circular economy, being the most recycled product worldwide with collection rates close to 99 percent in Europe and the USA.

This is encouraged by the fact that among the various battery technologies available, lead is the only one offering a residual value at the end of its life. This makes their recycling with the recovery of raw materials profitable and virtuous, unlike other technologies in which recycling and disposal represent a cost, sometimes even high, due to the amount of energy and safety required for their processing and transport.

Therefore, due to its low cost, the wide availability of materials needed for its production, and the fact that continuous technological and performance improvements are being introduced in new products, lead technology is expected to grow steadily in the global market in the coming years.

Fiamm Energy Technology S.p.A. will make available to its customers all the support and documentation necessary to fulfill the prescribed obligations and its skills to accompany them in the transition and implementation phase of the new Regulation.