Economic Observer reporter Wang Yajie

In early September 2026, at the Port of Rotterdam in the Netherlands, a 40 foot dangerous goods container containing a Chinese made energy storage system had been piled up at the dock for about ten days.

The crux of the delay of the batch of goods at the port for several days lies in the fact that the sustainability compliance documents required by the EU Battery Regulation for energy storage batteries that accompanied the goods did not meet the EU access requirements: the carbon footprint statement (data file disclosing the carbon emissions of batteries throughout their lifecycle) was not calculated according to the unified methodology of the EU Battery Regulation; The green electricity usage certificate corresponding to the production process cannot be matched with the specific production batch; There are also gaps in the traceability materials of key minerals such as lithium, nickel, cobalt, and natural graphite. The above three types of documents cover the EU's sustainability compliance requirements for imported batteries in three dimensions: carbon footprint, green electricity, and traceability of key minerals.

On August 19th, the Jiangsu Energy Storage Industry Association disclosed that from August 2026, EU customs will officially enter the mandatory sampling stage for carbon footprint statements and battery passport data of imported power and energy storage batteries, shifting from the past "declaration and clearance" to substantive review, with a focus on verifying the compliance of raw material source codes and power mixing factors; Recently, several batches of battery products exported from China to the Port of Rotterdam in the Netherlands have been detained by customs due to non-standard data filling in battery passports or insufficient additional conditions for green power certificates.

What really caught companies off guard was the timetable outlined in the EU Battery Regulation (EU) 2023/1542. The deadline for requiring batteries to be equipped with a digital "battery passport" is February 18, 2027. But its pre threshold - carbon footprint declaration - has become a mandatory entry requirement for industrial batteries with a capacity exceeding 2 kWh, such as energy storage, since February 18, 2026.

The customs rely on this effective clause to conduct pre screening and early screening of supply chain data gaps for energy storage at the port. Although the legal deadline for mineral due diligence clauses has been postponed to August 18, 2027, downstream buyers have already included traceability requirements in the procurement threshold.

Pressure is being transmitted upstream along the chain from the port.

A Stuck Port

Zhou Haizhou is the head of the China region for a European freight forwarding company. Recently, the energy storage cabinets he handled have been stuck more than once. After the goods are shipped to the port of Rotterdam or Hamburg, the customs will open the container and first check the sustainability compliance documents accompanying the goods: whether the carbon footprint statement is calculated according to EU standards, and whether the green power usage certificate (a certificate proving that the electricity used in battery production comes from renewable energy sources such as wind power and photovoltaics) can match the production batch, all of which need to be verified one by one.

Zhou Haizhou estimates that since August 2026, more than 10% of incoming energy storage cabinets will trigger sustainability document reviews, and the probability of small and medium-sized integrators' shipments, new product models, and batches imported into the EU for the first time being selected for review is significantly higher. The proportion of top manufacturers selected for re evaluation will be much lower due to the completeness of relevant information in the early stage.

Once entering the re examination process, the faster one will be released within 7 to 14 working days. Once this batch of goods requires the exporter to return to China to replenish materials and a third party to issue a new report, it is not uncommon to see delays of three to four weeks.

Energy storage systems are transported by sea in containers and are classified as Class 9 dangerous goods by the International Maritime Organization (IMO). Zhou Haizhou said that the three sets of new materials are the easiest for domestic energy storage companies to "fall off the chain" in terms of procedures. The first is a carbon footprint statement that complies with EU accounting rules (based on EU product environmental footprint methodology, covering the entire life cycle from mining to factory production, and verified by third-party carbon data files). Many companies directly obtain accounting reports issued by domestic institutions, and if the electricity factor and boundary settings do not match EU standards, customs will not recognize them; The second is the green electricity usage certificate corresponding to the production process. Customs needs to check the binding relationship between the certificate and the production batch, and there are many cases where the certificate does not match the production time and production line; The third is the traceability materials for key minerals such as lithium, nickel, and cobalt. Although the legal deadline for due diligence obligations has been delayed, the complete traceability documents are the most difficult link for small and medium-sized enterprises to complete. Many upstream battery cell factories are unwilling to open up the original mining data.

Besides customs clearance, changes have also occurred at the bidding end.

Jiang Cong, the engineering supervisor stationed overseas by a leading domestic photovoltaic storage enterprise, has felt the changing trend of European project bidding since the middle of this year. He told the Economic Observer reporter that large energy groups and top EPC (Engineering General Contracting) companies have gradually included EU battery regulations and digital battery passport related clauses in their project bidding documents. The requirements for supply sections after February 2027 are particularly strict, and many have even set penalty clauses for breach of contract. Jiang Cong said, "This has become an unavoidable part of overseas bidding

Some companies are able to pass customs inspections smoothly. The head of a leading domestic energy storage company in the European region told Economic Observer reporters that the company's main shipments to Europe have not yet experienced substantial customs clearance detention, but have encountered situations where customs have increased document inquiries, disrupting the delivery pace. The enterprise has completed the compliance assessment of NB (Registered Body) and the supply chain data is relatively complete.

Zhou Haizhou told the Economic Observer reporter, "Customs is now training ahead of time, screening risk batches in advance, and avoiding large-scale mine explosions after the new regulations are implemented next year." He introduced that once a company's goods are stuck, the remedy path is very limited: the fastest way is to urgently supplement compliance documents domestically and submit them to customs through an authorized representative of the European Union; If the gap is too large, some shippers can only choose to return the goods, resulting in greater losses.

New Rules

With only six months left until the mandatory landing on February 18, 2027, the internal battery passport work for the aforementioned top domestic energy storage companies has already begun.

The person in charge of the European region of the top energy storage enterprise mentioned above told the Economic Observer reporter that the company has completed the compliance assessment of NB on the one hand, and on the other hand, built a specialized data management platform to connect battery cells, BMS (Battery Management System), and MES (Manufacturing Execution System) in the production process, collecting all the required fields for battery passports; Establish a cross departmental team internally to collaborate with overseas business, supply chain, legal, technology, compliance, and other departments to systematically review relevant data points, distinguishing between mandatory, mandatory, and optional items. The combination of software platform development, third-party certification, full supply chain certification, and personnel training cannot escape the tens of millions of investment at the group level, not to mention the increased procurement costs brought about by upstream transmission.

The head of the top energy storage company in Europe mentioned above said that the biggest bottleneck is not in the system integration end, but in the upstream. Many of the underlying data of minerals and materials are not in our hands, and we need to trace them up layer by layer. The chain is long, and if any link is broken, downstream cannot gather complete data. "This person said that since the second quarter of this year, the energy storage company has officially made mandatory requirements to upstream suppliers such as battery cells, cathodes, and lithium salts, requiring them to provide a complete set of materials including corresponding batch carbon footprint reports, due diligence on raw materials, and the proportion of recycled materials, and all data must be bound to specific production batches.

These requirements have been transmitted along the chain to the material end.

The ESG (Environmental, Social, and Governance) and supply chain compliance officer of a positive electrode material company told Economic Observer reporters that two or three years ago, downstream energy storage customers could purchase positive electrode materials as long as the composition, performance, physical and chemical indicators, and safety testing reports were sufficient. Now, each batch of products must be accompanied by full lifecycle carbon footprint results, proportion of recycled materials used, key metal sources, mineral supply chain due diligence documents, as well as energy consumption, green electricity usage certificates, and waste disposal records. The person in charge of the positive electrode material company mentioned above said, "More and more customers are demanding matching data according to production batches. In the past, we mostly collected data on an annual basis and could not break it down into individual batches

The person in charge of the positive electrode material enterprise mentioned above added that the difficulty lies in the long chain. Raw materials such as lithium, nickel, and cobalt have to pass through traders and smelters before reaching the mining end, with multiple layers of trade circulation in between. Information is easily fragmented, and related enterprises can control the smelters they directly cooperate with, and then trace back to the original mine. Many pieces of information are beyond control. The domestic mineral supply chain is relatively centralized, and on-site due diligence can be conducted. Overseas mining sites are located in complex areas with multiple layers of traders transferring ownership, and some mines do not even have standardized ESG ledgers, making traceability prone to breakpoints.

The head of the top energy storage company in the European region mentioned above stated that the truly tricky data points are the original supply chain information of the mineral end, such as the specific source of the mine and the process parameters of the smelting plant; The other type is business data such as energy consumption and process losses in the production process. The person in charge said, "These are all core business secrets of the enterprise

The approach of the top energy storage companies mentioned above is hierarchical desensitization: the EU requires standardized output fields to be disclosed to the public, and the original confidential underlying data is kept on domestic servers and not directly exported. The legal department compares each field with domestic data security laws to distinguish which fields can be exported to the public and which can only be operated domestically.

The same goes for the material side. The person in charge of the positive electrode material enterprise mentioned above explained that the specific supply share of the mine, the ratio of different mineral sources, the energy consumption and process loss parameters of each production line are all commercially sensitive information. The company only outputs standardized results after accounting, and shields core commercial data such as feeding ratio and purchase price.

Shen Yan, a foreign-related lawyer specializing in EU green trade and battery regulations, told Economic Observer reporters that there are several high-frequency legal prediction errors for domestic energy storage companies in response to this new regulation. The first major misconception is to equate NB's conformity assessment certificate with a battery passport. The two are two separate systems, with NB representing product conformity and battery passport representing dynamic data obligations. Obtaining the certificate does not necessarily mean complete compliance. Shen Yan pointed out that the due diligence clause for the supply chain has been officially postponed through legislation. The EU Regulation 2025/1561 was passed by the European Parliament and Council in July 2025 and will come into effect on July 31, 2025, extending the relevant obligations from the original August 18, 2025 to August 18, 2027. This is just a delay, not a cancellation.

Refactor

Li Zhenhua, the head of energy storage project development, recently reopened the calculation model for European projects and "stuffed" every cost brought by the battery passport into it. According to his estimation, the top enterprises have a large shipment scale, and fixed investment can be diluted by huge production capacity. The additional cost per MWh (megawatt hour) is about several thousand yuan; Small and medium-sized integrators have a small shipment volume, and the additional cost per MWh will be significantly higher. The revenue side accounts are also changing, and the benchmark IRR (internal rate of return) for European independent energy storage projects is mostly maintained between 8% and 11%. In the case where costs cannot be fully transmitted, IRR may decline by 0.5 to 1.5 percentage points.

Li Zhenhua said, "Many investment decisions for European projects are at the critical line of IRR, and with a slight decline in returns, some projects will directly become worthless for investment. ”

Li Zhenhua also found a common problem: in the past, when domestic energy storage companies calculated overseas projects, the vast majority only included explicit costs such as hardware procurement, maritime logistics, tariffs, and on-site construction and grid connection in their models. Soft costs such as data compliance, carbon accounting, and supply chain certification were generally not included. The calculation models of many small and medium-sized integrators still lack this aspect, and the quotations they made were inherently undervalued, which could easily lead to lower actual project profits than expected in the later stage.

The overseas business manager of a small and medium-sized energy storage integrator told Economic Observer reporters that the company still has several tens of MWh of European orders on hand. After completing the full compliance process of battery passport, NB agency evaluation, data system construction, third-party full chain LCA accounting, and supply chain due diligence and evidence collection, a one-time investment of several million yuan is required.

The person in charge of overseas business of the above-mentioned small and medium-sized energy storage integrators said, "The biggest practical obstacle is not just money, but the lack of discourse power in the supply chain." Top battery cell manufacturers prioritize serving big buyers such as top integrators, and only provide generic LCA reports to small and medium-sized buyers, which cannot match them one by one according to production batches. Many material data cannot be obtained, and it is difficult to promote compliance transformation even with money alone.

The situation of Manager Li, the person in charge of Jiangsu energy storage integrators, is similar. He told the Economic Observer reporter that the company has been exporting energy storage for European households and small businesses. After evaluation, the biggest pressure is the combination of funds, supply chain coordination, and data capabilities. However, the problem of upstream supply chain coordination is the most bottleneck. Even if one is willing to spend money, without the batch traceability and LCA data of upstream battery cell factories, the money cannot be spent, and some battery cell quotes have already risen.

In Manager Li's opinion, this round of impact is much greater than a price war. He said that in the era of price wars, as long as one dares to give up profits, there is still room for survival. Compliance barriers are different, and they cannot be solved simply by lowering prices. Even if one is willing to accept orders without making money, they cannot obtain upstream traceability data and still cannot meet the requirements of the European Union. The essence of this round of new regulations is to further widen the gap in the discourse power of the supply chain, and the survival space of small and medium-sized integrators will be significantly squeezed.

The road ahead for small and medium-sized enterprises is narrowing.

The overseas business manager of the above-mentioned small and medium-sized energy storage integrators said that some peers in the industry have already shifted their business to regions with lower compliance thresholds such as Southeast Asia, the Middle East, and Latin America. Some have shrunk their European business and only focused on stock closure, some have transferred to top manufacturers for OEM, and a few have tried to jointly share certification costs. But due to different supply chains and battery cell selection, it is difficult to share data. Li Zhenhua observed that the low price bidding model is gradually becoming ineffective in the European market, and compliance has become a hard threshold that cannot be ignored in the bidding process.

(At the request of the interviewee, Jiang Cong and Shen Yan are given pseudonyms)

(Author Wang Yajie)