Question 1

What is the EU Battery Regulation and does it apply to Indian companies?

Accepted Answer

EU Battery Regulation 2023/1542 sets mandatory requirements for all batteries placed on the EU market — covering performance, durability, carbon footprint declarations, lifecycle data, due diligence, and end-of-life obligations. It applies to any company supplying batteries or battery-containing products (including electric vehicles) to EU customers, regardless of where that company is based. Indian EV manufacturers, battery suppliers, and component makers supplying into Europe are in scope now.

Question 2

What is CBAM and does it affect Indian manufacturers exporting to Europe?

Accepted Answer

CBAM (Carbon Border Adjustment Mechanism, EU 2023/956) is the EU's carbon levy on imports of carbon-intensive goods — currently covering steel, aluminium, cement, fertilisers, hydrogen, and electricity. From 2026, EU importers must purchase CBAM certificates corresponding to the embedded carbon in those goods. Indian manufacturers in these sectors exporting to EU buyers need to calculate and report embedded emissions. KaM assists with CBAM compliance assessments and declarations through its Kiwa authorisation.

Question 3

What is CSRD and does it reach Indian suppliers?

Accepted Answer

CSRD (Corporate Sustainability Reporting Directive, EU 2022/2464) requires large EU companies to report on their sustainability performance across their full supply chains. This means Indian suppliers to large EU companies may be required to provide sustainability data to their customers as part of CSRD compliance. KaM helps Indian suppliers understand their exposure and prepare the required data and disclosures.

Question 4

What is a Notified Body and why does it matter?

Accepted Answer

A Notified Body is an organisation formally designated under EU law to assess whether products and processes conform to EU regulations. Notified Body status is required for issuing certifications that carry legal weight in EU markets. Kiwa Netherlands is a globally recognised Notified Body. KaM's formal authorisation from Kiwa means KaM delivers services that carry Kiwa's Notified Body standing — directly, locally, without routing through a European firm.

Question 5

What is KaM's relationship with Kiwa Netherlands?

Accepted Answer

KaM is Kiwa's sole authorised representative for India and Southeast Asia. This is a formal authorisation — not a referral arrangement or commercial partnership — under which KaM delivers Kiwa-backed conformity assessments, certifications, and advisory services directly to clients in the region. Certifications issued through KaM carry Kiwa's Notified Body standing and are accepted by EU regulators and buyers.

Question 6

What is the EU Deforestation Regulation and does it affect automotive supply chains?

Accepted Answer

EU Deforestation Regulation 2023/1115 bans the import and sale in the EU of products linked to deforestation or forest degradation. It covers cattle, cocoa, coffee, palm oil, soya, wood, rubber, and derived products. Rubber is directly relevant to automotive supply chains — tyre manufacturers and rubber component suppliers exporting to EU markets must demonstrate supply chain traceability and due diligence. KaM manages EUDR compliance through its Kiwa authorisation.

Question 7

What is a Digital Product Passport?

Accepted Answer

A Digital Product Passport (DPP) is a structured digital record of a product's materials, components, environmental performance, and lifecycle data — required under the EU's Ecodesign for Sustainable Products Regulation. It allows regulators, businesses, and consumers to access standardised product information. DPPs are being phased in across product categories from 2026 onwards. KaM assists manufacturers in preparing and registering DPPs through its Kiwa authorisation.

Question 8

What is CSDDD and how does it affect Indian companies?

Accepted Answer

CSDDD (Corporate Sustainability Due Diligence Directive, EU 2024/1760) requires large EU companies to identify, prevent, and address adverse human rights and environmental impacts across their operations and supply chains. This obligation flows upstream to suppliers — Indian companies that are significant suppliers to large EU buyers may face audit requirements, data requests, and contractual obligations as a result. KaM helps Indian suppliers assess their exposure and prepare.

Question 9

What is an Environmental Product Declaration (EPD) and who needs one?

Accepted Answer

An Environmental Product Declaration (EPD) is a standardised, third-party verified document reporting the environmental impact of a product across its full lifecycle — based on a lifecycle assessment (LCA). EPDs are increasingly required by EU buyers, public procurement frameworks, and sustainability reporting obligations. KaM prepares LCAs, coordinates Kiwa third-party verification, and publishes EPDs to ISO 14025 standards.

Question 10

What is Ecodesign for Sustainable Products and which products does it cover?

Accepted Answer

The Ecodesign for Sustainable Products Regulation (EU 2024/1781) sets minimum requirements for the sustainability of products sold in the EU — covering durability, repairability, recycled content, energy efficiency, and end-of-life management. It is being rolled out category by category from 2026. Products in scope require conformity assessments, technical documentation, and Digital Product Passports. KaM handles Ecodesign assessments through its Kiwa authorisation.

Question 11

Does the EU Battery Regulation apply to EV traction batteries?

Accepted Answer

Yes. EU Battery Regulation 2023/1542 explicitly covers EV traction batteries. Requirements include carbon footprint declarations (phased in from 2025–2027), state of health and remaining useful life data, due diligence on raw materials (cobalt, lithium, nickel, natural graphite), recycled content thresholds (from 2030), and end-of-life take-back obligations. Indian EV manufacturers and battery suppliers exporting to EU markets need a compliance roadmap now.

Question 12

What is ETS and how does it link to CBAM?

Accepted Answer

ETS (Emissions Trading System, EU 2003/87/EC) is the EU's carbon market, requiring EU operators in covered sectors to hold allowances for their emissions. CBAM (the Carbon Border Adjustment Mechanism) extends equivalent carbon pricing to imports — Indian exporters in steel, aluminium, cement, fertilisers, and hydrogen sectors must report embedded emissions so EU importers can calculate CBAM obligations. The two systems are designed to work together to prevent carbon leakage.

Question 13

What sectors does KaM serve through its Kiwa authorisation?

Accepted Answer

KaM serves automotive, battery, rubber, energy industries, hydrogen, photovoltaic, and medical sectors through its Kiwa authorisation. For Indian manufacturers, the most immediately relevant sectors are automotive (EU Battery Regulation, CBAM, CSRD), rubber (EU Deforestation Regulation, CBAM), and energy (ETS, CBAM, sustainability directives). KaM tracks implementation timelines across all eight EU sustainability regulations and sequences client work accordingly.

Question 14

What is the General Product Safety Regulation and does it affect India?

Accepted Answer

The General Product Safety Regulation (EU 2023/988) sets baseline safety and traceability requirements for all consumer products sold in the EU. It requires manufacturers and importers to maintain technical documentation, establish recall procedures, and register certain products on the EU Safety Gate. Indian manufacturers of consumer products — including automotive accessories and components sold direct to EU consumers — are in scope.

Question 15

When does the EU Battery Regulation come into full force?

Accepted Answer

EU Battery Regulation 2023/1542 is already in force. Key milestones include: carbon footprint declaration requirements for EV batteries (from August 2025), industrial batteries (from February 2026), and performance classes (from 2027). Due diligence obligations are already active. Recycled content thresholds begin in 2030. Indian manufacturers need compliance programmes running now — not at the deadline.

Question 16

How do I find out if EU sustainability regulations apply to my company?

Accepted Answer

The starting point is understanding your exposure: which EU regulations cover your product category, whether your EU customers' supply chain obligations flow to you, and what your export volumes and product types trigger. KaM offers an initial scoping assessment to map your regulatory exposure across all eight EU sustainability frameworks — contact admin@kam-auto.in to request one.

Question 17

What is the EU Packaging and Packaging Waste Directive and does it affect Indian exporters?

Accepted Answer

The Packaging and Packaging Waste Directive (94/62/EC) sets requirements on recyclability, recycled content, labelling, and waste reduction for all packaging placed on the EU market. Any Indian manufacturer exporting packaged goods to Europe — across automotive, rubber, industrial, and consumer sectors — must ensure their packaging complies. Requirements are being tightened under a revised regulation currently moving through the EU legislative process. KaM delivers Packaging Directive compliance assessment through its Kiwa authorisation.

Question 18

Can a vehicle be blocked from EU market entry because of the Battery Regulation, even if it has full type approval?

Accepted Answer

Yes. Type approval and EU Battery Regulation compliance are separate legal obligations. A vehicle that has passed UNECE R100, holds valid EU type approval, and is otherwise fully certified can still be blocked from EU sale if its battery system does not meet EUBR requirements — including carbon footprint declarations, due diligence documentation, and state of health data. Indian EV manufacturers and battery suppliers need both compliance tracks running in parallel, not sequentially.

Question 19

What is the Digital Battery Passport and how is it different from the Digital Product Passport?

Accepted Answer

The Digital Battery Passport (DBP) is a specific requirement under EU Battery Regulation 2023/1542 — a QR-code-accessible data record for each EV battery containing state of health, remaining useful life, materials content, carbon footprint, and supply chain due diligence data. It is distinct from the Digital Product Passport (DPP) under the Ecodesign Regulation, which covers a broader range of product categories. The DBP applies to EV batteries from 2027. Indian EV manufacturers need to build the data infrastructure now — the battery must be able to generate and transmit the required data from the point of production.

Question 20

Why use KaM for EU sustainability compliance rather than going directly to a European firm?

Accepted Answer

Three practical reasons. First, KaM holds formal Kiwa authorisation — certifications carry the same Notified Body standing as a European firm, but are delivered locally. Second, KaM's engineers work in the same time zones as Indian and Southeast Asian clients — no 12-hour communication lag on critical compliance decisions. Third, KaM understands Indian manufacturing realities: supply chain structures, data availability constraints, and the regulatory gaps that matter most for Indian exporters specifically. This is not a referral to a European intermediary — it is direct, authorised service delivered in-region.

Question 21

Does KaM's Kiwa authorisation cover hydrogen and photovoltaic manufacturers?

Accepted Answer

Yes. KaM's Kiwa authorisation covers seven sectors: automotive, battery, rubber, energy industries, hydrogen, photovoltaic, and medical. For hydrogen manufacturers, the relevant frameworks include sustainability reporting, ETS, and product certification. For photovoltaic manufacturers, Ecodesign, GPSR, and sustainability directives are directly applicable. Indian companies in either sector exporting to EU markets can access Kiwa-backed compliance services through KaM without engaging a European firm.

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