Knowledge
Deadlines of the Batteries Regulation
What applies from when: labelling, QR code, battery passport, carbon footprint, due diligence.
As of October 2026
The Batteries Regulation (EU) 2023/1542 has applied since 18 February 2024, but its obligations start in stages. Many dates depend on Commission acts that have not been adopted yet. This overview shows what already applies, what has a fixed date and what is still open.
Already in force
- Since 18 Aug 2024: performance and durability information for industrial, LMT and electric vehicle batteries (Art. 10, Annex IV), such as capacity, power, internal resistance and expected lifetime.
- Since 18 Aug 2024: battery management systems must give buyers and third parties acting on their behalf read access to state-of-health data (Art. 14, Annex VII).
- Since 18 Aug 2025: separate collection symbol (crossed-out wheeled bin) on all batteries (Art. 13(4)).
18 Feb 2027: battery passport and QR code
- Every LMT battery (e-bike, e-scooter), every industrial battery above 2 kWh and every electric vehicle battery placed on the market or put into service from that day needs a battery passport (Art. 77(1)).
- All batteries carry a QR code (Art. 13(6)). For batteries that need a passport, it leads to the battery passport.
- Portable batteries in appliances must be removable and replaceable by the end user (Art. 11).
The passport is the responsibility of the economic operator placing the battery on the market (Art. 77(4)). For goods from outside the EU this is usually the importer.
Labelling
The label with the general information under Annex VI (manufacturer, category, chemistry, weight, capacity and more) applies from 18 Aug 2026 or 18 months after the implementing act on labelling, whichever is later (Art. 13(1)). That act had not been adopted by October 2026, so the label requirement starts 18 months after its publication at the earliest.
Carbon footprint
The carbon footprint declaration and performance class (Art. 7) depend on a delegated act on the calculation method and an implementing act on the format. Neither had been adopted by October 2026. The declaration becomes mandatory 12 months after the respective act, the performance class 18 months after it, but not before:
- Electric vehicle batteries: declaration 18 Feb 2025, performance class 18 Aug 2026
- Rechargeable industrial batteries above 2 kWh (except external storage): declaration 18 Feb 2026, performance class 18 Aug 2027
- LMT batteries: declaration 18 Aug 2028, performance class 18 Feb 2030
- Industrial batteries with exclusively external storage: declaration 18 Aug 2030, performance class 18 Feb 2032
Because the acts are missing, the carbon footprint fields are not yet part of the mandatory passport scope from 18 Feb 2027. If you already have the values (for example from a PEF or ISO 14067 study), you can still enter them.
Supply chain due diligence
The obligations on raw materials such as cobalt, lithium, nickel and graphite (Art. 47–53) apply from 18 Aug 2027 after the postponement by the Omnibus IV Regulation (EU) 2025/1561. Companies with a net turnover below EUR 40 million are exempt. The related report becomes part of the battery passport only after that date.
Recycled content
Documentation of the shares of recycled cobalt, lead, lithium and nickel (Art. 8) applies from 18 Aug 2028 or 24 months after the related delegated act, whichever is later. Binding minimum shares follow from 2031: cobalt 16 %, lead 85 %, lithium 6 %, nickel 6 %.
Still open
- Implementing act under Art. 77(9): who counts as a person with a legitimate interest and which passport data they may see. The 18 Aug 2026 deadline has passed; it is expected at the end of 2026.
- Implementing act on labelling (Art. 13(10)) and the acts on carbon footprint and recycled content, see above.
Do you need a battery passport? Two or three questions and you know.
Take the obligation checkSources
- Regulation (EU) 2023/1542 (EUR-Lex)
- Regulation (EU) 2025/1561, Omnibus IV (EUR-Lex)
- European Commission: Digital product passport for batteries
This article summarises the legal situation in plain language and is not legal advice. The text of the regulation is authoritative.