Six Key Provisions Closely Relevant to Energy Storage Enterprises

Enterprises must submit carbon footprint declarations starting from February 2026. Products exceeding carbon emission limits will face a sales ban effective February 2029. Domestic lithium iron phosphate energy storage cells largely rely on high-energy-consumption thermal power smelting, resulting in generally high carbon footprints, leaving very limited preparation time.

Starting in 2031, recycled cobalt shall account for 16%, recycled lithium 6%, and recycled nickel 6% of the active materials in energy storage batteries. At present, large-scale supply of recycled lithium and cobalt for domestic energy storage cells is not yet available.

From February 2027 onwards, every energy storage battery must be marked with a durable QR code linked to a decentralized digital passport enabling full-lifecycle traceability. Products without valid digital passports will be barred from the EU market entirely.

Battery Management Systems (BMS) must disclose data including State of Health (SOH), remaining service life and cycle records. The traditional closed-data design model will no longer be compliant within the EU.

Enterprises with annual revenue exceeding 40 million euros are required to implement full-chain traceability for lithium, cobalt, nickel and natural graphite. Approximately 60% of China’s lithium resources depend on imports, while foreign reliance on cobalt ore hits as high as 97%, posing significant risks of broken traceability chains.

Manufacturers of energy storage equipment placed on the EU market shall bear all recycling costs throughout the product lifecycle. The overall recycling efficiency of lithium-based waste energy storage batteries must reach 65% by 2025 and 70% by 2030.