Climate Delegated Act Manufacturing NACE C27.2NACE E38.32

Manufacture of batteries

Manufacture of rechargeable batteries, battery packs and accumulators for transport, stationary and off-grid energy storage and other industrial applications. Manufacture of respective components (battery active materials, battery cells, casings and electronic components).

Recycling of end-of-life batteries.

The economic activities in this category could be associated with NACE code C27.2 and E38.32 in accordance with the statistical classification of economic activities established by Regulation (EC) No 1893/2006.

Substantial contribution

This activity can make a substantial contribution to the following objective(s). The activity must also pass DNSH assessment against the remaining five objectives.

✓ Climate mitigation

The economic activity manufactures rechargeable batteries, battery packs and accumulators (and their respective components), including from secondary raw materials, that result in substantial GHG emission reductions in transport, stationary and off-grid energy storage and other industrial applications.The economic activity recycles end-of-life batteries.

✓ Climate adaptation

1. The economic activity has implemented physical and non-physical solutions (‘adaptation solutions’) that substantially reduce the most important physical climate risks that are material to that activity.2. The physical climate risks that are material to the activity have been identified from those listed in Appendix A of the applicable Delegated Act by performing a robust climate risk and vulnerability assessment with the following steps:screening of the activity to identify which physical climate risks from the list in Appendix A of the applicable Delegated Act may affect the performance of the economic activity during its expected lifetime;where the activity is assessed to be at risk from one or more of the physical climate risks listed in Appendix A of the applicable Delegated Act, a climate risk and vulnerability assessment to assess the materiality of the physical climate risks on the economic activity;an assessment of adaptation solutions that can reduce the identified physical climate risk.The climate risk and vulnerability assessment is proportionate to the scale of the activity and its expected lifespan, such that: for activities with an expected lifespan of less than 10 years, the assessment is performed, at least by using climate projections at the smallest appropriate scale;for all other activities, the assessment is performed using the highest available resolution, state-of-the-art climate projections across the existing range of future scenarios(104) consistent with the expected lifetime of the activity, including, at least, 10 to 30 year climate projections scenarios for major investments. 3. The climate projections and assessment of impacts are based on best practice and available guidance and take into account the state-of-the-art science for vulnerability and risk analysis and related methodologies in line with the most recent Intergovernmental Panel on Climate Change reports(105), scientific peer-reviewed publications and open source(106) or paying models.4. The adaptation solutions implemented:do not adversely affect the adaptation efforts or the level of resilience to physical climate risks of other people, of nature, of cultural heritage, of assets and of other economic activities;favour nature-based solutions(107) or rely on blue or green infrastructure(108) to the extent possible;are consistent with local, sectoral, regional or national adaptation plans and strategies;are monitored and measured against pre-defined indicators and remedial action is considered where those indicators are not met; where the solution implemented is physical and consists in an activity for which technical screening criteria have been specified in this Annex, the solution complies with the do no significant harm technical screening criteria for that activity.

Do No Significant Harm criteria

To be taxonomy-aligned, this activity must not significantly harm any of the five objectives it does not substantially contribute to.

Water and marine resources

The activity complies with the criteria set out in Appendix B of the applicable Delegated Act.

Circular economy

For manufacturing of new batteries, components and materials, the activity assesses the availability of and, where feasible, adopts techniques that support:reuse and use of secondary raw materials and reused components in products manufactured; design for high durability, recyclability, easy disassembly and adaptability of products manufactured;information on and traceability of substances of concern throughout the life cycle of the manufactured products.Recycling processes meet the conditions set out in Article 12 and in Annex III, Part B, of Directive 2006/66/EC, including the use of the latest relevant Best Available Techniques, the achievement of the efficiencies specified for lead-acid batteries, nickel-cadmium batteries and for other chemistries. These processes ensure the recycling of the metal content to the highest degree that is technically feasible while avoiding excessive costs.Where applicable, facilities carrying out recycling processes meet the requirements laid down in Directive 2010/75/EU.

Documentation typically required

  • Assessment report on availability and adoption of techniques for reuse, secondary raw materials, and design for durability, recyclability, and adaptability — Must cover techniques as described in the text.
  • Information and traceability documentation for substances of concern throughout the product life cycle — Must provide information on and traceability of substances of concern.
  • Compliance documentation with Article 12 and Annex III Part B of Directive 2006/66/EC — Includes demonstration of meeting recycling conditions and specified efficiencies.
  • Documentation of use of latest relevant Best Available Techniques (BAT) — Part of compliance with Directive 2006/66/EC recycling conditions.
  • Compliance documentation with Directive 2010/75/EU for recycling facilities — Required where applicable for facilities carrying out recycling processes.

Pollution prevention and control

The activity complies with the criteria set out in Appendix C of the applicable Delegated Act.Batteries comply with the applicable sustainability rules on the placing on the market of batteries in the Union, including restrictions on the use of hazardous substances in batteries, including Regulation (EC) No 1907/2006 of the European Parliament and of the Council(97) and Directive 2006/66/EC.

Biodiversity and ecosystems

The activity complies with the criteria set out in Appendix D of the applicable Delegated Act.

Criteria sourced from the EU Taxonomy Navigator. Applicable act: Climate Delegated Act (OJ L 442, 9.12.2021). Last verified: 19 July 2026.

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