Position Paper
10 December 2025

EUROBAT position on provisions of data resulting from battery uses under Regulation (EU) 2023/1542

The new EUROBAT position paper clarifies that the EU Batteries Regulation (Regulation (EU) 2023/1542) adopts a technology-open approach, considering the specific characteristics of different battery chemistries. Industrial batteries based on those chemistries that do not require a BMS (e.g. lead-based or nickel-cadmium) are therefore exempt from the obligation to update data resulting from battery use.

EUROBAT notes that the obligation to keep this information up to date does not require continuous, frequent or real-time data transmission. Rather, our understanding is that updates are needed when there is a change in status of a battery affecting the information specified in Annex XIII. These data are those resulting from the different battery uses that vary over time and require regular - but not live or frequent- monitoring (e.g., state of charge).