Manufacture of Batteries
Manufacturing rechargeable battery cells, modules, and packs for energy storage and electric mobility applications.
Substantial Contribution to Climate Change Mitigation
The activity covers the manufacture of rechargeable batteries, battery modules, and battery packs, including lithium-ion, solid-state, sodium-ion, and other advanced chemistries used in electric vehicles, stationary energy storage, and grid-balancing applications. As an enabling activity, the manufactured batteries must facilitate the transition to low-carbon energy and transport systems.
The carbon footprint of battery manufacturing must be declared in accordance with the EU Battery Regulation (2023/1542), using the methodology defined in the Commission delegated acts. Starting from the applicable compliance dates, batteries must meet the maximum lifecycle carbon footprint thresholds: for EV batteries, this is set at class performance thresholds to be tightened progressively. The manufacturing process must align with BAT as described in relevant BREF documents, including energy efficiency benchmarks for electrode coating, cell formation, and aging processes.
Battery cells must meet minimum electrochemical performance standards including cycle life, energy density, and round-trip efficiency appropriate to the application. Supply chain due diligence for raw materials (lithium, cobalt, nickel, manganese, graphite) must comply with Regulation (EU) 2017/821 on conflict minerals and the due diligence requirements under the Battery Regulation.
Substantial Contribution to Climate Change Adaptation
A CRVA in accordance with Appendix A must cover the manufacturing facility and critical supply chain elements under both RCP 4.5 and RCP 8.5 climate projections.
DNSH: Climate Change Adaptation
Physical climate hazards affecting the manufacturing facility must be assessed, including risks from extreme heat (affecting dry room and formation processes), flooding, and water scarcity. Adaptation measures must be implemented for identified material risks.
DNSH: Water and Marine Resources
The activity must comply with the Water Framework Directive. Battery manufacturing water discharge (from electrode preparation, cell washing, and cooling systems) must meet BAT-AELs. Water recycling systems must be implemented where technically feasible.
DNSH: Circular Economy
Batteries must comply with the EU Battery Regulation recycling efficiency targets: 65% by weight for lithium-ion batteries by 2025, rising to 70% by 2030. Minimum recycled content requirements apply: 16% cobalt, 6% lithium, and 6% nickel from 2031, increasing to 26% cobalt, 12% lithium, and 15% nickel from 2036. Battery passport and QR code labelling must be implemented per regulatory timelines.
DNSH: Pollution Prevention and Control
The activity must comply with the Industrial Emissions Directive. Emissions of NMP (N-methyl-2-pyrrolidone) solvent, fluoride compounds, and metal dust must remain within BAT-AELs. Hazardous substance restrictions under REACH and RoHS apply. Electrolyte handling and storage must follow Seveso III Directive requirements where threshold quantities are exceeded.