EU Batteries Regulation (2023/1542) and Battery-Passport Pages on Changzhou Manufacturer Websites: How Should They Be Accepted?

Direct answer: The EU Batteries Regulation (Regulation (EU) 2023/1542) has applied since 18 February 2024 and covers portable, LMT (e-bike/e-scooter), EV, industrial and SLI batteries, including batteries embedded in products. A manufacturer's "EU Batteries Regulation / battery passport" page cannot just say "compliant with the EU Battery Regulation" or show a QR code. It should state the battery category, who places the battery on the EU market, the 18 February 2027 passport/QR requirement, the 18 August 2027 due diligence, the staged carbon-footprint declarations, the 2031/2036 recycled-content minimums, and which data customers receive. Otherwise, when a customer asks "where is the passport ID, who fills the 71 data points, which raw materials does due diligence cover, which category does the carbon-footprint declaration apply to," the answer becomes an ad-hoc explanation.

This guide is for battery, energy-storage, e-bike/e-scooter, power-tool, robotics and equipment manufacturers in Changzhou and nearby areas. It explains how to write and accept an EU Batteries Regulation/battery passport page. Information is current to 2026-11-03. It is a review of public rules and project practice, not EU legal, battery-safety, carbon-footprint or third-party verification advice; the specific category, obligations, data points and dates depend on the regulation, Commission guidance, delegated/implementing acts and the competent authority.

How does the battery page relate to lithium transport, CBAM, PPWR and machinery pages?

The lithium transport page answers "how to ship under UN38.3/dangerous-goods packaging"; the CBAM page answers "product carbon footprint/border carbon"; the PPWR page answers "packaging compliance"; the machinery page answers "machinery CE"; the battery page answers "sustainability, labelling, passport, due diligence and recycling responsibility after a battery is placed on the EU market." Transport compliance is not market-access compliance, and CBAM/PPWR do not replace the Batteries Regulation.

The usual breakpoints: treating a UN38.3 report as Batteries Regulation compliance; assuming "the battery is inside the product, so no passport"; treating a QR code as the passport itself; not realising the passport is per battery, not a company-level statement; writing due diligence as "mandatory since 2025" (it was postponed to 18 August 2027); treating a delegated-act deadline as the mandatory date for all batteries; saying recycled content is "already required." A page that states category, role, timeline, data, responsibility and red lines gives export, R&D and quality one playbook.

This page map is editorial; battery scope and obligations follow Regulation (EU) 2023/1542 and the European Commission batteries page.

Which batteries are in scope?

The regulation covers five categories: portable, LMT (light means of transport), EV, industrial (above 2 kWh or industrial use) and SLI (starting, lighting, ignition). It applies whether the battery is sold separately or embedded in a product/vehicle, regardless of origin. The test is the category, capacity, use and whether it is placed on the EU market/put into service—not what the product is called. Embedded batteries may still need a passport; the equipment maker and battery maker must divide responsibilities and cannot assume "the battery is not ours to handle".

Common misjudgements: treating all power-tool/robot batteries as "portable"; treating a >2 kWh storage cabinet as ordinary equipment; mixing SLI with industrial; excluding samples/after-sales spares; assuming cell-only exports are out of scope; limiting the passport to EV batteries. The category determines labelling, passport, carbon footprint, recycled content and recycling responsibility, so the page should distinguish category/model rather than say "all batteries comply".

This category split is editorial; definitions, capacity thresholds and embedded rules follow Article 3, the annexes and Commission guidance.

Timeline: what applies now, and what starts in 2027?

The regulation entered into force on 17 August 2023 and applies from 18 February 2024; the old Batteries Directive 2006/66/EC was repealed from 18 August 2025 (with transitional provisions). From 18 February 2027: every EV, LMT and industrial battery above 2 kWh needs a battery passport; all batteries need a QR code; removability/replaceability requirements for portable batteries apply. From 18 August 2027: in-scope operators must apply due diligence (Regulation (EU) 2025/1561 postponed it from 18 August 2025). Recycled-content minimums start on 18 August 2031, with higher levels in 2036. Carbon-footprint declarations phase in by category under delegated acts, so one date cannot cover all batteries.

The most common page errors: presenting "the regulation applies in 2024" as "all obligations are live"; presenting the original 2025 due-diligence date as current; treating a carbon-footprint delegated-act deadline as a mandatory declaration date; presenting "2027 passport" as "all 71 data points are mandatory in 2027" (some are not required in February 2027 under the Commission guidance). State the date together with the article/category and whether it depends on an act.

This timeline is editorial; specific dates, transitions and act dependencies follow Articles 7/8/48/77/95, Regulation (EU) 2025/1561 and Commission guidance.

What does the battery passport contain?

The battery passport is a digital record for each battery, accessed via QR, containing a unique identifier, manufacturer/importer, category/chemistry/capacity, materials and carbon footprint, due diligence, recycled content, performance/durability, state of health, dismantling/recycling information and more. The Commission's guidance updated on 21 August 2026 groups 71 data points by EV/LMT/industrial category and marks which are mandatory, optional, applicable only in specific circumstances, or not required to be completed/displayed as of February 2027. The passport is not a "certificate" or a company-level PDF; it is an accessible, updatable, access-controlled digital record.

The first February 2027 release does not require every field: carbon footprint, recycled content and other points depend on later acts and methods, and the guidance states some data points are not required yet. What companies should do now is build the battery BOM/data ledger: unique ID, model, chemistry, capacity, weight, materials, supply chain, test reports and software/health-data interfaces. The QR must resolve long-term, not point to an expiring campaign page; access rights should distinguish public/regulator/repair/recycler.

This data split is editorial; the specific 71 data points, mandatory/optional status and February 2027 applicability follow the Commission's "Digital Batteries Passport – data points by category" guidance.

Who is the operator placing the battery on the market?

The manufacturer, importer or distributor placing the battery on the EU market/putting it into service carries the relevant obligations; a non-EU manufacturer usually works through an EU importer/authorised representative. When a battery is embedded in a product/vehicle, the battery maker and equipment maker must agree who handles the passport, who holds the data, and who responds to customers/authorities. EPR (producer responsibility) registration/recycling responsibility may fall on the "producer" in each Member State and is not the same as passport responsibility. The contract should cover data ownership, updates, QR maintenance and audit cooperation.

Typical chain: cell maker supplies pack maker, pack maker supplies equipment maker/importer, importer places on the EU market; the passport duty usually sits with the operator placing it on the market, but data must be aggregated along the chain. An equipment maker exporting battery-containing equipment may simultaneously deal with machinery CE, the battery passport, UN38.3 transport and PPWR packaging. Do not use one "battery compliance statement" for all roles and countries.

This role split is editorial; specific duties follow Articles 38–48, Member State EPR rules and the customer contract.

Due diligence: who, what and when?

Battery due diligence addresses supply-chain risks for cobalt, natural graphite, lithium and nickel (child labour, forced labour, corruption, environment, etc.) and requires a policy, management system, risk identification/mitigation, third-party verification and disclosure. It has a turnover threshold (group net turnover above €40 million, subject to the regulation/amendments), was originally due on 18 August 2025, and was postponed by Regulation (EU) 2025/1561 to 18 August 2027; the Commission guidelines were moved from 18 February 2025 to 26 July 2026. Not every supplier is directly in scope, but customers/upstream will ask for data.

Common gaps: a "no child labour/no conflict" statement without the OECD five-step framework; not covering cobalt/graphite/lithium/nickel; no mapping to smelters/refiners; no risk grading/mitigation/corrective action; no third-party verification; treating a customer audit questionnaire as due diligence. The website can say "we have a due-diligence policy/summary available on request", but must not say "our supply chain has zero risk/100% compliant".

This due-diligence split is editorial; thresholds, raw materials, verification and disclosure follow Articles 47–52, Regulation (EU) 2025/1561 and Commission guidance.

How do carbon footprint, recycled content and labelling phase in?

Carbon-footprint declarations phase in by category: the delegated act for EV batteries is due by 18 February 2025; industrial batteries (except external storage) by 18 August 2026; LMT by 18 August 2028; industrial batteries with external storage by 18 August 2030; the declaration applies 12/18 months after the act enters into force, with classes/thresholds later. Recycled-content minimums start on 18 August 2031 (16% cobalt, 85% lead, 6% lithium, 6% nickel) and rise in 2036; they apply to EV, industrial >2 kWh (except external storage), SLI and others. Labelling/QR applies to all batteries from 18 February 2027; portable-battery removability/replaceability also starts then.

The page must separate the "delegated-act deadline", "declaration application date" and "threshold application date"; do not merge them into "everything in 2027". Carbon footprint needs an LCA method, functional unit (kWh over life), boundaries, data sources and verification; recycled content needs supply-chain evidence/mass-balance rules; labels need capacity/chemistry/separate-collection/QR. Build the BOM, supplier data and LCA model now rather than waiting for the acts.

This phased split is editorial; specific dates, shares, categories and verification follow Articles 7/8/13, the annexes and delegated acts.

Which battery compliance data will customers ask suppliers for?

EU customers/importers typically ask for: battery category/model/capacity/chemistry; unique ID/QR/passport link; manufacturer/importer details; DoC/CE (where applicable); UN38.3/transport documents; carbon-footprint declaration/class (where applicable); recycled content (where applicable); due-diligence policy/report; labels/instructions; EPR registration (where the factory is responsible); and change notification. The data must map to a specific model/batch, not a company-wide "battery compliance statement".

Deliver a "battery compliance data pack": cover (model/version/date/contact) + specification/category + passport ID/QR + test reports (safety/transport/performance) + carbon footprint/recycled content + due-diligence summary + labels/instructions + EPR/importer information + change log. What customers fear most is "the passport link does not open, the QR points to an old model, the data points do not match the physical battery, and the carbon footprint has no boundaries". Define versioning and update triggers (chemistry/supplier/capacity/software changes).

This data list is editorial; specific fields/formats follow the regulation, Commission guidance, customer contract and national systems.

How should the website battery/passport page be written?

A public page should include: applicable battery categories/models; manufacturer/importer role; the 2024/2027/2031 timeline; how the battery passport/QR is accessed; an explanation of the 71 data points (not necessarily listed publicly); how carbon footprint/recycled content/due diligence are provided; label/instruction languages; EPR/recycling information; change notification; and a contact. Write verifiably: state category, capacity, passport ID rules, version/date; do not just show a QR or "compliant with EU 2023/1542".

Separate "public information" from "controlled data": the public passport layer can show basic information, while regulator/repair/recycler layers are access-controlled; specific data packs are supplied per customer/contract. If the company only supplies a battery/equipment maker, state that it supports with cell/battery data and do not claim the final battery/whole machine is compliant. The QR must remain valid; website redesign/domain changes need redirects/migration.

This page structure is editorial; external claims must be truthful and verifiable, per the regulation, Commission guidance, customer contract and Member State rules.

What must not be written?

High-risk claims: "battery passport certified/certificate obtained" (a passport is a digital record, not a certification); "a QR code is the passport" (the QR is only an entry point; data/access/unique ID are the core); "one passport covers all models/batches"; "due diligence mandatory since 2025" (postponed to 18 August 2027); "all batteries must submit carbon footprint/recycled content in 2027" (phased by category/act); "recycled content already meets the target" (mandatory from 2031); "UN38.3 report = Batteries Regulation compliance"; "zero risk/100% compliant". These are inaccurate or misstate the responsibility boundary.

Safer wording: "EV/LMT/industrial >2 kWh batteries provide a passport from 18 February 2027"; "due diligence applies from 18 August 2027 under Regulation (EU) 2025/1561 for operators above the threshold"; "carbon-footprint declarations phase in by category/delegated act"; "recycled-content minimums start in 2031". External promotion must also comply with advertising/fair-competition law; customer names/cases need authorisation.

These red lines are editorial; whether a claim is false advertising/non-compliant is determined by regulators and the customer contract, and this is not legal advice.

Go-live acceptance checklist

Ten checks: category/model, role, timeline, passport/QR, data points, carbon footprint, recycled content, due diligence, labels/recycling, and page wording/version. Each needs an owner, evidence and review date. The pass condition is not "the page has a QR code", but that a customer can see which category the battery is, who is responsible, what is supplied in 2027, where the data comes from, and what is not yet mandatory.

Before go-live, run one real model through: category decision → unique ID/QR → data-point list → carbon footprint/recycled content → due-diligence summary → labels/instructions → customer data pack → page wording. Any step that fails is a gap in the page or the process.

This checklist is editorial; specific compliance requirements follow the regulation, Commission guidance, delegated acts and the competent authority.

Who should read this, who should not, and what decisions does it support?

It suits manufacturers in Changzhou and nearby areas that export batteries, energy storage, e-bikes/e-scooters, power tools, robots or battery-containing equipment to the EU—especially battery packs, storage systems, traction batteries, industrial batteries and equipment makers. It also suits export, R&D, quality, EHS, procurement, marketing and website teams assessing a battery/passport page. It does not suit businesses that do not sell to the EU, only make non-battery products, or want one page to replace the passport system/carbon-footprint calculation/due diligence.

Read it if EU customers are pressing you for passport/carbon-footprint/due-diligence data; you are preparing for 18 February 2027; you are building or revising a website battery compliance page; or you need to separate transport, CBAM, PPWR, machinery and battery rules. Skip it if you treat a QR as the passport, use one statement for all models, or present the first 2027 data points as all mandatory. It supports self-review of category, role, timeline, passport data, carbon footprint, recycled content, due diligence, data pack and page wording.

This role split is editorial; specific duties follow the company's export/R&D/quality/procurement policy.

FAQ

Is the battery passport a certificate?

No. The battery passport is a digital record for each battery, accessed via QR, containing a unique identifier, category/chemistry/capacity, materials/carbon footprint, due diligence, recycled content, performance/health and dismantling/recycling information; there is no "passport certificate". The QR is only the entry point; data, access and unique ID are the core.

What should be prepared before 18 February 2027?

Define the category/model and who places it on the market; build a unique ID/QR and data ledger; map the 71 data points under the Commission guidance and separate 2027 mandatory, optional and not-yet-required fields; prepare underlying carbon-footprint/recycled-content/due-diligence data; align labels/instructions/EPR information and the customer data pack. Do not wait for the system to start collecting data.

If the battery is inside equipment, who handles the passport?

The passport duty sits with the operator placing the battery on the EU market/putting it into service (usually the battery manufacturer or importer); embedded batteries may still need a passport. The equipment maker and battery maker must agree on data provision, passport ID/QR, updates and cooperation with customers/authorities; "the battery is the supplier's" does not mean no obligation.

Is the carbon-footprint declaration mandatory now?

Not for all batteries. It phases in by category: the EV delegated act is due by 18 February 2025, industrial (except external storage) by 18 August 2026, LMT by 18 August 2028, external storage by 18 August 2030; the declaration applies 12/18 months after the act enters into force, with classes/thresholds later. Follow the delegated act and Commission guidance; do not present the act deadline as "all batteries mandatory".

When does due diligence start, and who is in scope?

Originally 18 August 2025, postponed by Regulation (EU) 2025/1561 to 18 August 2027; it applies above a turnover threshold (group net turnover above €40 million, subject to the regulation) and covers cobalt, natural graphite, lithium and nickel. Even if not directly in scope, customers/upstream will ask for supply-chain data.

When does recycled content become mandatory?

Minimum shares start on 18 August 2031 (16% cobalt, 85% lead, 6% lithium, 6% nickel) and rise on 18 August 2036; they apply to EV, industrial >2 kWh (except external storage), SLI and other categories. Documentation/verification requirements apply earlier; do not claim "already met" without supply-chain evidence, and follow Article 8 and implementing rules.

One-sentence takeaway

A Changzhou manufacturer's EU Batteries Regulation/passport page should not be "a QR code". It should turn category/model, role, the 2024/2027/2031 timeline, the 71 passport data points, carbon footprint, recycled content, due diligence, labels/recycling and the customer data pack into a verifiable checklist—so a customer can see who is responsible, what is supplied in 2027 and what is not yet mandatory.

Method and limitations

This is a review of public rules and project practice, not an audit or legal opinion on any company's battery, passport system, carbon footprint, recycled content or due diligence. No undisclosed customer battery data, passport records or supply-chain information were used. The timeline, data list and acceptance items are editorial suggestions, not legal/compliance conclusions. Specific categories, obligations, data points, dates and verification depend on the regulation, Commission guidance, delegated/implementing acts and the competent authority.

Sources and scope

Information is current to 2026-11-03. The following are EU official/legal pages; their articles, annexes and dates control.

1. Regulation (EU) 2023/1542 concerning batteries and waste batteries, adopted 12 July 2023, OJ L 191, published 28 July 2023: EUR-Lex. Five battery categories, labelling/QR, carbon footprint, recycled content, due diligence, passport and EPR.
2. European Commission, Batteries topic page: European Commission. Entry into force/application, five categories, life-cycle scope and links to ESPR/REACH/WEEE.
3. Regulation (EU) 2025/1561 amending Regulation (EU) 2023/1542 as regards battery due diligence, adopted 18 July 2025, OJ L 2025/1561, published 30 July 2025: EUR-Lex. Due diligence postponed to 18 August 2027; guidelines deadline moved to 26 July 2026.
4. European Commission, "Guidance to support preparations for the Digital Batteries Passport", 21 August 2026: European Commission. The 18 February 2027 passport scope and 71 data points by category.