Regulation (EU) 2023/1542 — commonly called the EU Batteries Regulation — is the main EU law governing batteries throughout their life cycle. It introduces requirements covering sustainability, safety, labelling, conformity, recycled content, carbon footprint, supply-chain due diligence, waste management and the digital battery passport.
The Regulation entered into force on 17 August 2023 and has applied generally since 18 February 2024, although many individual obligations have later application dates.
For companies preparing for 2027, the most important upcoming milestone is 18 February 2027. From that date, certain EV, industrial and light means of transport batteries must have a battery passport, while all batteries must carry a QR code meeting Article 13 requirements.
There have also been important changes since the Regulation was originally adopted. Most notably, Regulation (EU) 2025/1561 postponed the battery due diligence application date from 18 August 2025 to 18 August 2027. In 2026, the EU also launched the Digital Product Passport Registry and published updated Commission guidance for preparing battery passport data.
Key 2026 takeaway: the battery passport deadline remains 18 February 2027. The due diligence deadline, however, is now 18 August 2027, not 2025.
What is Regulation (EU) 2023/1542?
Regulation (EU) 2023/1542 is the EU regulation concerning batteries and waste batteries. It replaced the older Batteries Directive 2006/66/EC and creates a directly applicable regulatory framework across EU Member States.
Its scope goes well beyond recycling. The Regulation establishes requirements covering:
- sustainability and restricted substances;
- carbon footprint;
- recycled content;
- battery performance and durability;
- removability and replaceability;
- safety;
- labelling and QR codes;
- conformity assessment and CE marking;
- obligations of manufacturers, importers and distributors;
- battery supply-chain due diligence;
- extended producer responsibility and waste management; and
- the digital battery passport.
The law covers the entire battery life cycle, from raw-material sourcing and manufacturing through use, second life and recycling.
The Regulation is directly applicable in EU Member States. That is different from a directive, which generally requires implementation through national legislation.
Who does it apply to?
The EU Batteries Regulation applies to all categories of batteries, regardless of their shape, volume, weight, chemistry, material composition, use or purpose.
The five main categories are:
| Battery category | Typical examples |
|---|---|
| Portable batteries | Consumer electronics, AA/AAA cells, small rechargeable batteries |
| SLI batteries | Starting, lighting and ignition batteries used in vehicles |
| LMT batteries | E-bike, e-scooter and similar light means of transport batteries |
| Electric vehicle batteries | Batteries providing traction for electric and hybrid vehicles |
| Industrial batteries | Industrial equipment, stationary storage, infrastructure and other industrial uses |
It also applies to batteries incorporated into other products.
The practical obligations depend on both the battery category and the role of the company in the supply chain.
Manufacturers
Manufacturers must ensure that batteries they place on the EU market comply with applicable design, sustainability, safety, labelling and information requirements. They are also responsible for technical documentation, conformity assessment, the EU declaration of conformity and CE marking where required.
Importers
Importers must verify that the manufacturer has completed the necessary conformity procedures and documentation before placing a battery on the EU market. They must also verify applicable labelling, CE marking and accompanying documentation.
Distributors
Distributors must exercise due care when making batteries available on the market and verify that relevant regulatory requirements have been met.
Other economic operators
Depending on the business model, obligations can also affect authorised representatives, fulfilment service providers, producers for extended producer responsibility purposes and companies carrying out repurposing or remanufacturing.
An importer or distributor may also be treated as a manufacturer if, for example, it markets a battery under its own name or trademark or modifies the battery in a way that may affect compliance.
2023/1542 compliance timeline
The Batteries Regulation does not have one single compliance date. Different provisions become applicable at different times.
The following table highlights the deadlines most relevant to companies planning compliance.
| Date | Requirement or milestone |
|---|---|
| 17 August 2023 | Regulation (EU) 2023/1542 entered into force |
| 18 February 2024 | Regulation began to apply generally |
| 18 August 2024 | Article 17 and Chapter VI obligations began to apply |
| 18 August 2025 | Chapter VIII on waste battery management and extended producer responsibility began to apply; separate collection marking became mandatory |
| 20 July 2026 | EU Digital Product Passport Registry became operational |
| 18 February 2027 | Battery passport required for EV, LMT and industrial batteries over 2 kWh; QR code required on all batteries |
| 18 February 2027 | Article 11 removability and replaceability rules begin to apply |
| 18 August 2027 | Battery due diligence obligations begin to apply to economic operators within scope |
| 18 August 2028 and later | Further recycled-content and carbon-footprint milestones begin, subject in several cases to secondary legislation |
| 2030–2033 | Additional recycled-content, carbon-footprint and performance requirements phase in |
This is not an exhaustive list of every date in Regulation 2023/1542. Companies should build a compliance calendar based on their battery categories and the individual Articles that apply to them. See our DPP deadlines guide to compare battery dates with the wider EU rollout.
A particularly important point is that several deadlines use wording such as “the specified date or X months after the relevant delegated or implementing act enters into force, whichever is later.” The date printed in the Regulation therefore does not always mean that an obligation automatically became operational on that date.
Battery Passport — Articles 77–78
Articles 77 and 78 establish the EU battery passport.
From 18 February 2027, a battery passport is required for:
- every electric vehicle battery;
- every LMT battery; and
- every industrial battery with a capacity greater than 2 kWh.
The passport is an electronic record containing both information about the battery model and information relating to the individual battery.
The economic operator placing the finished battery on the market is responsible for ensuring that passport information is accurate, complete and up to date.
The passport must be accessible through the QR code required by Article 13. The QR code links to a unique identifier assigned to the battery.
Article 78 also establishes important technical principles. Battery passport data must use open standards, support interoperability and be available without vendor lock-in. The system must provide appropriate access controls, data integrity, security and privacy.
The battery passport must also remain available if the economic operator responsible for it later ceases to exist or stops operating in the EU.
For a full explanation of the passport obligation, see our EU Battery Passport guide.
Battery passport data — Annex XIII
Annex XIII defines the information to be included in a battery passport.
The requirements are divided by access level rather than simply creating one public database containing every piece of battery information.
Public battery-model information
Publicly accessible information includes, where applicable:
- battery identification and general characteristics;
- battery chemistry and material composition;
- hazardous substances and critical raw materials;
- carbon-footprint information;
- responsible sourcing information;
- recycled-content information;
- rated capacity;
- voltage;
- original power capability;
- expected battery lifetime;
- energy-efficiency information;
- relevant marking information;
- the EU declaration of conformity; and
- waste prevention and management information.
Restricted battery-model information
Certain information is available only to authorised parties with a legitimate interest and, where applicable, the Commission.
This can include detailed composition, information on replacement parts, disassembly information and safety measures.
Compliance information
Test reports demonstrating compliance are restricted to notified bodies, market-surveillance authorities and the Commission.
Individual battery information
The passport can also contain data specific to an individual battery, including:
- performance and durability values;
- state of health;
- battery status, such as original, repurposed, reused, remanufactured or waste;
- charging and discharging cycles;
- relevant negative events; and
- operating-condition data.
In August 2026, the European Commission published updated practical guidance that consolidates 71 battery passport data points and indicates their applicability to EV, LMT and industrial batteries.
Importantly, this does not mean every battery passport must expose all 71 points publicly. Applicability and access rights differ by data point and battery category.
See our detailed Battery Passport Data Requirements guide for a field-by-field breakdown of Annex XIII and the 2026 Commission guidance.
QR code requirements
Article 13 introduces QR-code requirements separately from the battery-passport obligation.
From 18 February 2027, all batteries must be marked with a QR code.
What the QR code must provide depends on the battery type.
| Battery type | QR code must provide access to |
|---|---|
| EV battery | Battery passport |
| LMT battery | Battery passport |
| Industrial battery over 2 kWh | Battery passport |
| Other batteries | Applicable Article 13 information, conformity documentation, due diligence reporting where relevant, and waste-management information |
| SLI battery | Also relevant recycled-material information required under Article 8 |
This distinction is important:
Every battery needs a QR code from 18 February 2027, but not every battery needs a battery passport.
For passport batteries, Article 77 requires the QR code to link to the battery’s unique identifier.
The QR code and required labels must normally be printed or engraved on the battery in a way that is visible, legible and indelible. Where this is not possible or justified because of the nature or size of the battery, the Regulation allows placement on the packaging and accompanying documentation.
A QR code is therefore not itself the battery passport. It is the data carrier that provides access to the electronic record.
Carbon footprint requirements
Article 7 introduces life-cycle carbon-footprint requirements for:
- electric vehicle batteries;
- rechargeable industrial batteries with a capacity greater than 2 kWh; and
- LMT batteries.
The framework has three stages:
- a carbon footprint declaration;
- a carbon footprint performance class; and
- a maximum life-cycle carbon footprint threshold.
The carbon footprint declaration is prepared for each battery model per manufacturing plant.
It includes information such as the manufacturer, battery model, manufacturing location, calculated carbon footprint, life-cycle-stage breakdown and a public version of the supporting study.
Article 7 carbon footprint timeline
| Battery category | Carbon footprint declaration | Performance class | Maximum threshold |
|---|---|---|---|
| EV batteries | 18 Feb 2025 or 12 months after the relevant secondary acts enter into force, whichever is later | 18 Aug 2026 or 18 months after the relevant secondary acts, whichever is later | 18 Feb 2028 or 18 months after the relevant delegated act, whichever is later |
| Rechargeable industrial batteries >2 kWh, excluding exclusively external storage | 18 Feb 2026 or 18 months after the relevant secondary acts, whichever is later | 18 Aug 2027 or 18 months after the relevant secondary acts, whichever is later | 18 Feb 2029 or 18 months after the relevant delegated act, whichever is later |
| LMT batteries | 18 Aug 2028 or 18 months after the relevant secondary acts, whichever is later | 18 Feb 2030 or 18 months after the relevant secondary acts, whichever is later | 18 Aug 2031 or 18 months after the relevant delegated act, whichever is later |
| Rechargeable industrial batteries with external storage | 18 Aug 2030 or 18 months after the relevant secondary acts, whichever is later | 18 Feb 2032 or 18 months after the relevant secondary acts, whichever is later | 18 Aug 2033 or 18 months after the relevant delegated act, whichever is later |
Why the “whichever is later” wording matters
A common mistake is to quote 18 February 2025 as if the EV carbon-footprint declaration automatically became mandatory on that date.
Article 7 explicitly ties application to secondary legislation. The effective date can therefore move later than the base date in the Regulation.
As of September 2026, companies should verify the status and entry-into-force dates of the relevant delegated and implementing acts before determining their operational carbon-footprint deadline.
For compliance planning, do not build an implementation schedule from the headline dates in Article 7 alone.
Battery due diligence
Articles 47–53 establish battery-specific supply-chain due diligence requirements.
The regime covers raw materials including:
- cobalt;
- natural graphite;
- lithium;
- nickel; and
- certain chemical compounds based on those materials that are necessary for manufacturing battery active materials.
The requirements are intended to address environmental and social risks associated with sourcing, processing and trading these materials.
Who is subject to battery due diligence?
Under the current consolidated Regulation, Chapter VII does not apply to an economic operator that had net turnover below €40 million in the relevant financial year, provided it is not part of a group that exceeds the threshold on a consolidated basis.
For economic operators within scope, the Regulation requires a structured due diligence system.
Article 49 — management and traceability
Economic operators must establish a battery due diligence policy and integrate it into their internal management systems.
Requirements include:
- communicating the policy to suppliers and the public;
- assigning senior-management responsibility;
- maintaining records;
- establishing supply-chain controls and traceability;
- incorporating due diligence requirements into supplier contracts; and
- establishing grievance and remediation mechanisms.
Article 50 — risk management
Companies must identify and assess potential adverse impacts in their battery supply chains and implement a strategy to prevent, mitigate or otherwise address those risks.
This includes monitoring risk-mitigation measures and, where necessary, considering suspension or termination of relationships with suppliers where mitigation attempts fail.
Article 51 — third-party verification
Battery due diligence policies must be verified by a notified body.
Article 52 — disclosure
Economic operators must make information about their battery due diligence policies publicly available in accordance with the Regulation.
Article 53 — recognised schemes
The Regulation also provides a framework for Commission recognition of due diligence schemes that can support compliance.
The battery due diligence regime is therefore much broader than simply requesting a supplier declaration. It requires governance, supply-chain traceability, risk assessment, risk mitigation, independent verification and public reporting.
2025/1561 amendment: due diligence moved to 2027
One of the most important amendments to Regulation 2023/1542 is Regulation (EU) 2025/1561.
The original text required the battery due diligence obligations in Article 48 to apply from:
18 August 2025
Regulation 2025/1561 replaced that date with:
18 August 2027
The amendment therefore postponed the application of the battery due diligence regime by two years.
It also amended the deadline in Article 48(5) for Commission guidance on the application of the due diligence requirements, replacing 18 February 2025 with 26 July 2026.
The EU explained the postponement by pointing to practical implementation challenges, including the need for companies to analyse and adapt supply chains and the time required to establish sufficient third-party verification capacity.
For compliance teams, the practical conclusion is straightforward:
The current Article 48 due diligence application date is 18 August 2027. Any checklist still using 18 August 2025 is outdated.
What changed in 2026?
2026 has been particularly important for implementation of the battery passport because the EU moved from high-level legal requirements toward an operational Digital Product Passport infrastructure.
The DPP Registry became operational
Regulation 2023/1542 was amended by the Ecodesign for Sustainable Products Regulation so that the economic operator placing a passport-covered battery on the market must upload its unique identifier to the EU Digital Product Passport Registry.
In July 2026, the Commission adopted Implementing Regulation (EU) 2026/1778, setting out the implementation arrangements for that registry.
The DPP Registry became operational on 20 July 2026.
The Registry does not replace the battery passport database itself.
The EU DPP model is fundamentally decentralised: detailed passport information remains maintained by the responsible economic operator or an authorised service provider. The central EU Registry stores identifiers and other information required under the DPP framework to support functions such as market surveillance and customs controls.
This distinction matters when designing a battery passport architecture. Compliance does not mean uploading the entire passport dataset into one central EU database.
Commission battery passport guidance was updated
In August 2026, the European Commission published an updated version of its Digital Batteries Passport — data points by category guidance.
The document consolidates 71 data points and maps them against:
- electric vehicle batteries;
- LMT batteries; and
- industrial batteries.
For each data point, the guidance indicates whether it is mandatory, optional, conditionally applicable or not required to be completed or displayed as of February 2027.
The guidance is highly useful for implementation, but the Commission explicitly states that it does not create additional legal requirements and should be read together with Regulation 2023/1542 and applicable delegated and implementing acts.
DPP technical standards progressed
The Commission also progressed the common technical infrastructure supporting Digital Product Passports in 2026, including standards covering areas such as unique identifiers, data carriers, APIs, interoperability, data exchange and data storage.
This is important because Article 78 requires the battery passport to be interoperable with other EU Digital Product Passports.
The consolidated Batteries Regulation was updated again in 2026
The current consolidated version of Regulation 2023/1542 also incorporates Regulation (EU) 2026/1738, which amended Annex I in connection with new EU rules for vehicle circularity.
That amendment is separate from the core battery passport implementation and does not change the 18 February 2027 battery passport deadline.
Regulation 2023/1542 vs ESPR 2024/1781
Our DPP requirements guide explains the common technical requirements for identifiers, access, interoperability and data availability.
Regulation (EU) 2023/1542 and the Ecodesign for Sustainable Products Regulation — Regulation (EU) 2024/1781, or ESPR — are closely connected but they are not the same law.
This is particularly important when discussing Digital Product Passports.
| Topic | Regulation (EU) 2023/1542 | ESPR Regulation (EU) 2024/1781 |
|---|---|---|
| Main purpose | Sector-specific rules for batteries and waste batteries | Horizontal framework for ecodesign requirements across many physical product groups |
| Product scope | All battery categories | Broad range of physical goods, subject to exclusions and product-specific measures |
| DPP requirement | Directly requires battery passports for specified battery categories | Creates the general EU DPP framework and allows DPP requirements to be introduced through product-specific rules |
| Battery passport date | 18 February 2027 | Does not replace the Batteries Regulation deadline |
| Passport data | Primarily defined by Annex XIII and other battery-specific provisions | Product-specific delegated acts define data using the ESPR framework |
| Passport granularity | Battery-model information plus information specific to an individual battery | Model, batch or item level can be specified for each product group |
| Data carrier | QR code required by Article 13 | Data carrier determined under applicable DPP requirements |
| Responsible party | Economic operator placing the relevant finished battery on the market | Depends on applicable product-specific requirements |
| Technical architecture | Must be interoperable, machine-readable and based on open standards | Establishes the common technical DPP architecture |
| EU Registry | Battery unique identifier must be uploaded to the ESPR DPP Registry | Article 13 creates the central DPP Registry |
| Battery due diligence | Yes — Articles 47–53 | Not the source of battery-specific due diligence obligations |
| Battery carbon footprint | Yes — Article 7 | ESPR can establish sustainability requirements for other product groups |
A useful way to think about the relationship is:
Regulation 2023/1542 determines what the battery sector must do; ESPR increasingly provides the common Digital Product Passport infrastructure through which part of that system operates.
The battery passport is therefore not simply an “ESPR passport for batteries”. Its legal obligation and battery-specific data requirements come from the Batteries Regulation, while its technical implementation is connected to the wider ESPR DPP system.
Compliance checklist
For a company manufacturing, importing or placing batteries on the EU market, a practical Regulation 2023/1542 compliance programme should include at least the following steps.
- Classify each battery correctly as portable, SLI, LMT, EV or industrial.
- Determine your economic-operator role for each product and Member State.
- Map applicable Articles by battery category rather than assuming every requirement applies to every battery.
- Review design, sustainability and safety requirements, including restricted substances, performance and removability rules where applicable.
- Prepare technical documentation and conformity assessment processes required for placing batteries on the EU market.
- Confirm EU declaration of conformity and CE-marking requirements.
- Implement Article 13 labelling and marking requirements, including the separate collection symbol and other required battery information.
- Prepare for the 18 February 2027 QR-code requirement for all batteries.
- Determine whether the battery requires a passport: EV, LMT or industrial battery over 2 kWh.
- Map Annex XIII battery passport data and identify which systems and suppliers own each required data point.
- Assign unique battery identifiers and prepare integration with the EU DPP Registry.
- Ensure passport infrastructure supports open standards, interoperability, access rights and long-term availability.
- Assess Article 7 carbon-footprint requirements and verify the status of the relevant delegated and implementing acts before calculating an application date.
- Assess whether Chapter VII due diligence applies, including the current turnover threshold.
- Build raw-material traceability for cobalt, lithium, nickel and natural graphite where due diligence obligations apply.
- Prepare for third-party verification of battery due diligence policies before 18 August 2027 where applicable.
- Review extended producer responsibility and waste-battery registration obligations in each EU Member State where batteries are placed on the market.
- Monitor new delegated and implementing acts, because several operational details under Regulation 2023/1542 are still being phased in.
For battery passport projects in particular, waiting until early 2027 to collect data is risky. Annex XIII requires information coming from manufacturing, sustainability, compliance, supply-chain and in-use systems. Companies that do not already have a structured data model may need to change supplier data collection and internal system architecture before they can generate compliant passports at scale.
Official sources
For legal interpretation and compliance decisions, always check the current official EU texts. The most important sources for this topic are:
- EUR-Lex — Regulation (EU) 2023/1542 on batteries and waste batteries, including access to the current consolidated version.
- EUR-Lex — Regulation (EU) 2025/1561, which postponed the Article 48 due diligence application date to 18 August 2027.
- EUR-Lex — Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation.
- European Commission — DPP Registry launch, 20 July 2026, for the registry and testing environment.
- European Commission — Batteries, for implementation measures, delegated acts and regulatory updates.
- European Commission — Digital Product Passport for Batteries, for DPP implementation timelines and supporting material.
- European Commission — Digital Batteries Passport guidance, 21 August 2026, for the practical mapping of battery passport data requirements.
This page is a practical summary of Regulation (EU) 2023/1542 and related EU measures. It is not legal advice. Where there is any conflict or uncertainty, the applicable text published in the Official Journal of the European Union takes precedence.