Request for evidence on the regulation of substances in batteries

On 12 November 2025, ECHA launched a public consultation to collect additional information on substances of concern present in batteries, as defined by Regulation (EU) 2023/1542 on batteries:

«substances that have harmful effects on human health or the environment, or that hinder the safe and high-quality recycling of secondary raw materials, present in batteries or used in their manufacture.»

The consultation is not limited to collecting data on substances used in battery production but also aims to obtain evidence on currently available recycling technologies and substances that hinder end-of-life recycling processes.

This information, together with data already gathered during the preliminary survey, will enable ECHA to prepare a final report on the presence of substances of concern in batteries, to be submitted to the European Commission by 20 December 2026. Under Article 6(5) of the Batteries Regulation, the Commission, assisted by ECHA, must then draft a final report to be presented to the European Parliament and the Council by 31 December 2027, detailing its conclusions and assessing appropriate follow-up measures, including the possible adoption of new restrictions (note that the Batteries Regulation already provides for restrictions on mercury, cadmium, and lead in batteries under Annex I).

The consultation is primarily addressed to operators in the battery supply chain (manufacturers, importers, formulators, processors, distributors, downstream users), as well as recyclers and waste managers. Other stakeholders, such as scientific organizations, NGOs, national authorities, and international bodies, are also invited to participate. Furthermore, although the consultation concerns substances present in batteries placed on the EU market, non-EU entities may contribute if they hold relevant information.

It should be noted that all data can be submitted confidentially and will be treated as such by ECHA.