“We're thrilled to be at the heart of this e-bike movement, crafting the lithium-ion batteries that power people’s rides,” explains Petr Grzegorz, head of business development & marketing at EMBS. “And this new regulation is a game-changer. It represents a comprehensive overhaul of the current system that will directly impact e-bikes, their batteries and the future of the entire industry.”
The goal of the new regulation is to ensure batteries are not just powerful and efficient, but also sustainable, ethical and safe throughout their entire lifecycle – from sourcing the raw materials required all the way through to the batteries’ eventual recycling or second usage.
Grzegorz emphasises: “This aim of creating a more responsible battery ecosystem presents both exciting opportunities and potential hurdles that could shape the future of e-biking in Europe.” This article describes the key changes on the horizon and explains what this regulation means for e-bike riders and the European battery industry.
Spotlight on due diligence
From 18th August 2025, due diligence obligations will come into force. This is a cornerstone of the new regulation and is all about tracing the journey of the raw materials used to create e-bike batteries – materials like lithium, cobalt, nickel and graphite. European battery manufacturers like EMBS will be legally required to establish robust systems to identify, assess and mitigate risks in our supply chains.
This means meticulously checking where these materials come from and ensuring they are not linked to conflict areas, child labour, environmental degradation or other unethical practices. This comprehensive approach aims to ensure batteries sold in the EU are sustainable, ethical and safe throughout their life cycle. “For e-bike users, this means more peace of mind,” explains Grzegorz. “They can be confident that the battery powering their ride is produced in a more ethical and sustainable way.”
A stronger reputation
“For the European battery industry, there is an opportunity to build a stronger reputation for responsibly sourced and sustainable products and to ensure a world-leading, ethical and resilient battery supply chain in Europe,” says Grzegorz. “This could potentially give European-made batteries a competitive edge in an increasingly eco-conscious market, as well as strengthening European-based sourcing of critical minerals like lithium, nickel, cobalt and graphite. For this reason, some industry groups and NGOs are advocating for the swift and full implementation of these due diligence obligations.”
For the European battery industry, there is an opportunity to build a stronger reputation for responsibly sourced and sustainable products”
Complex and costly implementation
On the other hand, however, there are significant challenges. “There is a strong movement within the EU to deregulate in certain areas, as regulations are seen as harming businesses and hindering EU competitiveness,” tells Grzegorz. “Implementing these due diligence systems is also complex and costly, requiring detailed documentation, audits and ongoing monitoring of often intricate global supply chains. Especially for smaller manufacturers, this could represent a considerable burden. If not carefully managed, these increased costs could potentially trickle down to the consumer, impacting the price of e-bikes.”
Grzegorz notes: “Some requirements are not yet settled, as there may be some overlap between the Battery Regulation and the recent Omnibus Regulations. The aim of the Omnibus Regulations is to streamline corporate sustainability requirements with a consistent package of measures across the EU. This includes due diligence requirements, covered within the Corporate Sustainability Due Diligence Directive (CSDDD). It is currently being discussed whether the due diligence requirements from the Battery Regulation will be covered by fulfilling the CSDDD.”
More transparent information
Over the next few years, the EU Battery Regulation will introduce enhanced marking requirements. “These new rules aim to improve the EU battery market by providing consumers with more transparent information to help them make informed purchasing decisions,” explains Grzegorz.
From 2026, consumers can expect to see information on performance and durability in the documentation accompanying their battery. This would include information on expected lifespan, capacity and other key performance indicators, allowing them to compare batteries more effectively and make informed purchasing decisions. The following year, this information will be available via QR code and will include the Battery Passport.
Then, from 2028, consumers can expect to see information related to the carbon footprint of their battery. Manufacturers will be required to declare the environmental impact of battery production, providing transparency on the energy consumed and emissions generated during manufacturing. “This is a significant step towards understanding the full environmental lifecycle of batteries,” Grzegorz emphasises.
These new rules aim to improve the EU battery market by providing consumers with more transparent information to help them make informed purchasing decisions”
Opportunities and challenges for the battery industry
For the European battery industry, there are once again opportunities and challenges. “The opportunity is to showcase the environmental performance of European batteries, potentially driving innovation towards greener manufacturing processes,” mentions Grzegorz. “However, the challenge lies in the cost and complexity of accurately measuring and declaring this information. Furthermore, if European manufacturers are held to stricter carbon footprint declarations than competitors in other regions, it could again put them at a competitive disadvantage, potentially leading to higher prices for European e-bikes.”
The single cell replacement debate
From 2027 onwards, Article 11 of the regulation will begin to apply. “This is perhaps one of the most debated changes, with potentially the highest impact, as it focuses on removability and replaceability,” says Grzegorz. The regulation aims to make batteries, including those in e-bikes, more easily repairable by mandating that both the entire battery and individual cells within the battery pack are designed to be removable and replaceable.
The intention is to extend battery lifespan, reduce waste, and promote a circular economy by avoiding entire battery packs being thrown away due to a single faulty cell. This is part of the EU's broader circular economy goals, aiming to make products more sustainable, resource-efficient and reusable.
Challenges in the context of e-bike batteries
“In theory, this sounds very positive,” states Grzegorz. “However, when we consider the specific context of high-performance e-bike batteries, some significant challenges and questions arise. For example, designing batteries in which individual cells can be easily replaced is not a trivial task. It typically requires:
- Larger, heavier batteries – more space would be required for access to individual cells and their replacements within the battery pack.
- More robust mechanical structures – including additional wiring and potentially more complex connection systems. This can also lead to bulkier and heavier batteries.
- Higher production costs – such batteries would potentially be more intricate and therefore more complex to design and manufacture.
- More complex battery management systems (BMS) – more readable information would be required and it would need to allow single cell exchange.”
High-quality lithium-ion batteries
“But here’s the crucial point for e-bike users: high-quality lithium-ion batteries used in reputable e-bikes are incredibly reliable,” comments Grzegorz. “Thanks to advanced BMS and rigorous quality control, single cell failures in these batteries are statistically very rare within their expected lifespan. When failures do occur, they are often due to broader issues like physical damage, deep discharge abuse, or end-of-life degradation across all cells, rather than isolated cell faults. Therefore, while Article 11 aims to improve repairability, the value it adds for premium e-bike batteries is questionable.”
For the European battery industry, Article 11 presents a significant design and cost challenge. “We are committed to sustainability, but we also need to ensure that regulations are practical and deliver tangible benefits,” warns Grzegorz. “There’s a risk that forcing manufacturers to design for single cell replacement may lead to larger, more expensive batteries, with reduced performance and minimal practical benefit in terms of extended lifespan or functionality for most e-bike riders. The cost increase may therefore outweigh the environmental gains, especially when considering the well-established and ever-improving recycling infrastructure for lithium-ion batteries. This could also put European manufacturers at a disadvantage compared to global competitors who may not face the same design constraints.”
Navigating the regulatory landscape
EU Regulation 2023/1542 is a complex and ambitious piece of legislation. It is a key element of the European Green Deal and aims to increase the security of supply for raw materials while enhancing the EU's strategic autonomy and market competitiveness. It represents a significant step towards a more sustainable and responsible battery industry. However, it also undoubtedly presents both benefits and challenges for e-bike users and the European battery industry.
“As a European battery manufacturer, EMBS is committed to embracing its goals and navigating the complexities of its implementation,” says Grzegorz. “However, it is crucial that the regulation is implemented in a way that is both effective and balanced, ensuring that it achieves its environmental and ethical objectives without inadvertently hindering innovation, unnecessarily increasing costs, or putting European manufacturers at a competitive disadvantage."
Grzegorz continues: "Some in the industry are urging to simplify regulations to maintain competitiveness, but others emphasise that dismantling green finance laws is no solution and that focus should be on improving implementation, not rolling back progress on sustainability. Open dialogue, collaboration between industry stakeholders and regulators, and a focus on practical and evidence-based implementation are essential. We must strive for a regulatory framework that fosters a truly sustainable e-bike market in Europe, one that delivers both environmental benefits and affordable, high-quality e-mobility solutions for all riders.”
The road ahead
“The road ahead is complex, but by working together, we can power a more sustainable future for e-bikes and beyond,” summarises Grzegorz. “In this evolving landscape, as a user or system supplier, you could use an experienced battery manufacturer by your side. One who can ensure compliance with upcoming complex requirements, but also contribute to developing future requirements, so that everybody in Europe can ultimately benefit, not just be burdened by unnecessary bureaucracy.”
Grzegorz concludes: “Partner with EMBS and gain a competitive edge. Our innovative, compliance-ready lithium-ion batteries streamline your design process while meeting evolving EU regulations. Enjoy enhanced performance, robust safety, and sustainable practices that empower you to focus on building exceptional e-bike systems.”
This article is sponsored by EMBS.
