What Chinese companies need to report

01Carbon footprint declaration Most urgent

Directly determines whether the product can enter the EU market.

Products concerned: EV batteries, LMT batteries and rechargeable industrial batteries with a capacity >2 kWh.

Report content: manufacturer administrative information; geographical location of the manufacturing plant; lifecycle carbon footprint (kg CO₂e/kWh) with a breakdown by stage (raw materials, production, transport, end of life); a public link supporting the calculation.

Key dates: EV batteries from 2025-02-18; industrial batteries (>2 kWh) from 2026-02-18; LMT 2028-08-18; industrial batteries with external storage 2030-08-18.

02Supply-chain due diligence report

Companies (or groups) with net turnover above EUR 40 million in the previous financial year must comply with this obligation.

Materials concerned: cobalt, natural graphite, lithium, nickel and their compounds (the scope mainly applies to the battery cell supply chain, excluding non-chemical components such as casings and screws).

Report content: annual public report (measures to identify and mitigate environmental, human rights and labour risks); third-party verification report issued by a notified body; names and addresses of direct suppliers, countries of origin of raw materials and transaction routes.

Practical advice: can be integrated into existing annual/ESG reports; must identify the battery products concerned and the measures taken in a way that end users can easily understand.

Salient risks and adverse impacts: report findings and responses against Annex X — environmental (air pollution, greenhouse gases, water, soil, biodiversity) and social and human rights (occupational health and safety, child labour, forced labour, discrimination, freedom of association, community impacts).

03EU declaration of conformity (DoC)

The legal basis for customs clearance and sale. The manufacturer drafts it before placing the product on the market and bears full responsibility for conformity; importers or distributors selling under their own name/trademark assume the manufacturer’s responsibilities.

Must include: battery model (product, batch or serial number); manufacturer name and address; a declaration under the sole responsibility of the manufacturer; the object of the declaration (may include an image); the harmonised standards or common specifications referenced; notified body information (where applicable); signatory information.

• No paper copy needs to accompany the goods: the DoC becomes part of the battery passport (for industrial batteries <2 kWh, a QR code link may provide digital access).
• Multiple acts (e.g. the Batteries Regulation plus the Low Voltage Directive): draft a single DoC listing all relevant acts.
• Multiple categories: handle the battery under the category with the strictest applicable requirements.
• Repair does not generate a new DoC; repurposing (change of use) requires re-assessment of conformity (Module A) and a new DoC and CE marking.
• Stock exemption: batteries already held in the EU by distributors before 2024-08-18 do not need to be retrofitted.
• The technical documentation must include a risk analysis (commonly FMEA in the industry) covering the “intended use”.

04EPR registration and data reporting Easiest to confuse

Whether you must report depends on who is defined as the “producer” — the party that first places the battery on the market in a Member State in the course of a commercial activity.

• Register separately in each Member State, submitting company information, the battery categories and chemical compositions intended to be placed on the market, and explaining how take-back obligations will be met.
• Non-EU companies selling directly to end users in the EU across borders must designate an EPR authorised representative in writing in the Member State of destination.
• How to comply: individual compliance (own take-back network plus financial guarantee) or joining a producer responsibility organisation (PRO) and paying modulated fees based on category, chemical composition, recycled content, carbon footprint, etc.
• Data reporting: once per calendar year, within 6 months of the end of the year — quantities first placed on the market, quantities collected and collection rates, quantities delivered for treatment/reuse/recycling, and quantities exported to third countries.
• Repurposers are regarded as producers of new batteries and assume new EPR obligations; cost allocation is determined by commercial negotiation.

05Battery passport data entry

From 2027-02-18, LMT, EV and >2 kWh industrial batteries must have an electronic record (battery passport).

• Non-EU manufacturers (Chinese companies): the importer is responsible for creating the passport, but the data source (carbon footprint, composition, dismantling instructions) must be provided by the Chinese manufacturer.
• Public information: model, manufacturer, carbon footprint, recycled content, chemical composition, etc.; restricted information: SOH, dismantling instructions, spare parts list (accessible only to repairers, recyclers, etc.).
• Dynamic updates: the regulation requires the record to be kept “up to date”; industry recommends daily updates of dynamic data such as SOH for storage and EV batteries.

06Recycled content and performance parameter documentation

• Recycled content documentation: from 2028-08-18, industrial (>2 kWh), EV and SLI batteries must be accompanied by documentation stating the percentage of recycled cobalt, lead, lithium and nickel in the active materials.
• Performance documentation: from 2024-08-18, relevant batteries must be accompanied by documentation of electrochemical performance and durability parameter values.

Mandatory recycled material shares (for >2 kWh industrial, EV and SLI batteries): from 2031-08-18, cobalt 16%, lead 85%, lithium 6%, nickel 6%; from 2036-08-18, cobalt 26%, lead 85%, lithium 12%, nickel 15%.

07Response strategies for Chinese companies