EU carbon rules / Industry dossiers / Batteries, machinery, appliances and electronics
NACE C26–C28 et al. 6 duties 9 related regulations
Batteries, machinery, appliances and electronics
The battery passport and carbon-footprint declaration are hard gates; metal parts in appliances and machinery face pressure as CBAM extends downstream.
Reference only: this dossier is public compliance research, not legal advice, and draws no compliance conclusion. Whether a duty applies depends on product classification (CN code), role (importer, EU producer, downstream purchaser), cumulative volumes and Member State application; rely on the legal text and the competent authority.
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Duties
CCarbon: pricing, accounting, reporting, targets EEnvironment: pollution, waste, ecosystems, product attributes
| Duty | Trigger | Evidence needed | Timing | Legal source |
|---|---|---|---|---|
| Environment Battery carbon footprint declaration Calculate and declare the carbon footprint in accordance with the delegated act methodology; offsetting with green certificates is restricted and verification is required. | EV / LMT / industrial batteries above 2 kWh placed on the EU market | Carbon footprint calculation under the delegated act methodology; specific country/installation electricity rules (restricted offsetting with green certificates) | EV batteries first; LMT/industrial batteries in stages | Reg (EU) 2023/1542, Article 7 |
| Environment Battery passport Provide data on composition, carbon footprint, recycled content and other matters through a unique identifier and QR code. | EV / LMT / industrial batteries above 2 kWh | Data carrier containing the unique identifier, composition, carbon footprint, recycled content, etc. | From 2027-02-18 | Reg (EU) 2023/1542, Article 13 |
| Environment Carbon footprint classes and maximum thresholds Apply classes and thresholds in stages by battery category; batteries exceeding the threshold may not be placed on the market. | In stages by battery category | Class calculation and compliance with thresholds | From approximately 2027–2029 〔in batches〕 | Reg (EU) 2023/1542, Articles 7a/7b |
| Environment Recycled content shares and due diligence Calculate recycled content of cobalt/lithium/nickel/lead and implement a supply chain due diligence policy. | Batteries placed on the EU market | Calculation of cobalt/lithium/nickel/lead recycled content; supply chain due diligence policy | Recycled content from 2031; due diligence from 2025-08 | Reg (EU) 2023/1542, Article 8 and Articles 47–48 |
| Carbon Prepare for downstream CBAM on metal parts for appliances/machinery Establish steel/aluminium content and embedded emissions ledgers for around 180 downstream metal products. | Export of around 180 products such as washing machines, refrigerators, pumps and valves, steel structures and fasteners | Product-level steel/aluminium content and embedded emissions ledgers | Proposed for 2028-01 〔under review〕 | COM(2025) 989 final |
| CarbonEnvironment ESPR digital product passport and refrigerant compliance Prepare DPP data for the first ESPR product groups and meet the F-gas refrigerant GWP requirements. | Appliances/hardware are among the first ESPR product groups; equipment containing F-gases | DPP data; refrigerant GWP compliance | With the product-group delegated acts; F-gas timetable | Reg (EU) 2024/1781; Reg (EU) 2024/573 |
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Related regulations
| Regulation | Number | Status | Key date | Applies to |
|---|---|---|---|---|
| Battery Regulation | Regulation (EU) 2023/1542 | In force | 2027-02-18 | Placing batteries on the EU market |
| Ecodesign for Sustainable Products ESPR | Regulation (EU) 2024/1781 | In force | 2024 | Regulated product categories |
| CBAM Downstream Extension | COM(2025) 989 final | In progress | proposed 2028-01 | Steel/aluminium-intensive downstream products (fasteners, machinery parts, household appliances, etc.) |
| Fluorinated Gases Regulation | Regulation (EU) 2024/573 | In force | 2024 | Fluorinated gases and equipment |
| Net-Zero Industry Act NZIA | Regulation (EU) 2024/1735 | In force | 2024 | Net-zero technology manufacturing |
| Critical Raw Materials Act CRMA | Regulation (EU) 2024/1252 | In force | 2024 | Companies extracting, processing and importing critical raw materials |
| Industrial Emissions Directive IED 2.0 | Directive (EU) 2024/1785 | In force | 2026-07-01 transposition | Large industrial installations |
| Waste Framework Directive | Directive 2008/98/EC | In force | 2008 (as amended by 2018/851) | Waste generators, processors and producer responsibility entities |
| Waste Electrical and Electronic Equipment Directive | Directive 2012/19/EU | In force | 2012 | Producers and importers of electrical and electronic equipment |
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