Phase-two rules enter into force
The European Commission brought the second-phase implementing rules of the EU Battery Regulation (EU 2023/1542) into force on 2 July 2026, creating a fixed compliance date for battery energy storage systems placed on the EU market.
From 1 October 2026, all battery energy storage systems (BESS) imported into the EU must satisfy two requirements. Each system must carry a digital product passport (DPP) compliant with standard EN IEC 63454:2025, and each must be accompanied by a full life-cycle carbon footprint report verified by an accredited third-party body.
Customs clearance becomes the enforcement point
The consequences of non-compliance are operational rather than theoretical. Products that fail to meet the DPP and verified carbon footprint requirements may be refused customs clearance or removed from the EU market. For exporters — notably Chinese BESS suppliers, who dominate global shipments — the rule reshapes the product certification path, the construction of data management systems and delivery timelines.
Compliance evidence is now linked directly to shipment outcomes: no verified file, no market entry.
Four stakeholder groups under pressure
The rule affects several groups differently. Export-facing BESS manufacturers and project suppliers carry risk at the point of EU market entry. Procurement and commercial teams managing EU orders face a new dependency, because order acceptance, contract documentation and delivery scheduling now rest on compliance evidence. Certification, testing and documentation providers see their role become more operationally important as they prepare compliant files and coordinate validation. Logistics, customs and ancillary service providers must align their processes with documentation requirements that travel with the product.
What companies should review now
Firms with EU-facing BESS orders are being advised to review when compliance documents are created, who owns the underlying data, and whether internal timelines leave enough room for third-party verification. They should also assess whether data management systems can organise, retain and present product and life-cycle information in a form that supports a standards-based digital product passport.
Delivery planning and supplier coordination also need revisiting, because the regulation ties compliance records to shipment outcomes. A verification bottleneck discovered late in a project cycle cannot be resolved by accelerating logistics — which is why the DPP and carbon footprint requirements are being treated as a procurement issue as much as a regulatory one.
Source: MarketScopeLive
This article was assisted by AI analysis. Please refer to the original source for official information.