Manufacturing & Energy · EU Taxonomy Activity Guide

Batteries and energy storage under the EU Taxonomy

The Taxonomy covers the battery value chain twice: manufacturing (an enabling activity spanning batteries, their components and recycling) and electricity storage as an energy activity. Neither carries an emissions threshold; alignment turns on what the batteries are for and on DNSH, where sourcing, chemicals and end-of-life carry the scrutiny.

Activity ID

CCM 3.4 / 4.10

NACE code

C27.20 / D35

Objective

Climate change mitigation

Sector

Manufacturing

Battery manufacture is an enabling activity: it qualifies because batteries enable emissions reductions elsewhere, in vehicles, grids and renewables integration, rather than by meeting an emissions threshold of its own.

Why this activity matters

Batteries are the backbone of transport electrification and grid flexibility, and Europe has committed significant industrial policy to building the value chain, from gigafactories to recycling. The Taxonomy supports that by classifying the manufacture of batteries, components and recycling as enabling activities: their contribution is the emissions they unlock elsewhere.

For manufacturers, alignment supports the financing of plants and expansion CapEx and feeds Taxonomy KPIs. For storage developers and investors, grid-scale storage qualifies as its own energy activity. In both cases the assessment substance sits in DNSH: battery production involves chemicals management, significant energy and water use, and, increasingly, documented sourcing and end-of-life responsibilities under the EU Battery Regulation, which the Taxonomy assessment naturally intersects.

What alignment requires

As enabling activities, the substantial contribution tests are purposive rather than threshold-based. In summary:

Area	What is required (summarised)
Manufacture (3.4)	Manufacture of rechargeable batteries, battery packs, accumulators and their components (including recycling) that deliver substantial GHG reductions in transport, stationary storage and other applications.
Storage (4.10)	Construction and operation of electricity storage, including batteries, that stores and returns electricity; grid-connected storage supporting renewables integration is the paradigm case.
Recycling	Battery recycling qualifies within the manufacturing activity; process evidence and recovery rates support the assessment.

Summarised for orientation; the assessment itself applies the full criteria text of the Delegated Acts as amended.

Where DNSH scrutiny falls

Pollution & chemicals

Chemicals management is the heavyweight DNSH area for manufacture: restricted-substance compliance and safe handling of solvents and electrode materials.

Circular economy

Design for recyclability, recycled content, and end-of-life arrangements; the Battery Regulation’s requirements provide much of the evidence base.

Water

Manufacturing water demand and discharge, particularly for large plants in stressed catchments.

Climate adaptation

CRVA for facilities; thermal management and flood exposure are typical physical-risk items for storage sites.

Documentation that typically supports the assessment

Product and application description (what the batteries enable, or what the storage serves)
Chemicals compliance documentation (REACH, restricted substances) for manufacture
Recycled content and end-of-life / recycling arrangements
Environmental permits and BAT conformity for the plant
Climate risk and vulnerability assessment
For storage: grid connection, capacity and operating profile

How Censatim assesses it

Because these are enabling activities, our questioning first fixes what is actually being made or operated and for which application, then concentrates on the DNSH evidence, with chemicals and circularity carrying the most weight for manufacture and siting for storage. Assessments distinguish clearly between the manufacturing and storage activities, since reports are often used to support plant financing on one hand and project financing on the other.

Censatim is an expert-built EU Taxonomy assessment tool: describe the asset or activity in plain language, upload supporting documents, and answer a short set of targeted questions. The result is a criterion-by-criterion view with an In-line / Partial / Not aligned / Undetermined rating and a confidence level for each dimension. See the full methodology.

Frequently asked questions

Are batteries an enabling activity under the EU Taxonomy?

Yes. Battery manufacture (including components and recycling) is classified as an enabling activity: it qualifies because batteries enable substantial emissions reductions in vehicles, grids and renewable integration, rather than by meeting an emissions threshold of its own.

Does grid-scale battery storage qualify under the EU Taxonomy?

Yes, electricity storage is its own Taxonomy activity (CCM 4.10). Grid-connected battery storage that stores and returns electricity qualifies for substantial contribution, with the assessment focus falling on DNSH and siting evidence.

What DNSH issues matter most for battery manufacturing?

Chemicals management (restricted substances, solvent handling) and circular economy evidence (recycled content, design for recycling, end-of-life arrangements) carry the most weight, alongside standard permitting, water and climate-risk documentation.

How does the EU Battery Regulation relate to Taxonomy alignment?

They are separate frameworks, but the Battery Regulation’s requirements, on carbon footprint declarations, recycled content and end-of-life, generate much of the documentation a Taxonomy DNSH assessment asks for, so compliance work done for one substantially supports the other.

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