Direct answer: the EU Batteries Regulation (Regulation (EU) 2023/1542) has applied since 18 February 2024 and covers five categories: portable, LMT (e-bike/e-scooter), EV, industrial and SLI batteries. Three key dates: from 18 August 2025, larger economic operators must comply with battery due diligence (third-party verification, 10-year documentation); from 18 February 2027, LMT batteries, industrial batteries above 2 kWh and EV batteries need a battery passport, and all batteries need a QR code; the Article 11 removability/replaceability requirements also apply from that date. Carbon footprint declarations are staged under Article 7 and depend on delegated/implementing acts. For Chinese battery/product exporters, the 2026 task is not to "wait until 2027" but to connect passport data, due diligence, carbon footprint/labelling, CE and recycling registration.

This guide is for Chinese manufacturers exporting batteries, battery-containing products, e-bikes/e-scooters, energy storage and industrial equipment to the EU, and for their EU importers, distributors and producer responsibility organisations. Data cut-off: 8 November 2026; sources are the European Commission Batteries page, EUR-Lex Regulation (EU) 2023/1542 (consolidated 13 August 2026) and the EUR-Lex summary. Official facts, editorial interpretation and items to confirm are kept separate. This is not legal advice.

Three rules to remember

(1) The Batteries Regulation did not start in 2027: it has applied since 18 February 2024, due diligence since 18 August 2025, and 18 February 2027 is the passport/QR/removability milestone. (2) A passport is not "a PDF": it is an accessible electronic record with three access layers (public, authorities, legitimate-interest parties) under Annex XIII, linked to a QR code. (3) Due diligence has a threshold (EUR 40 million net turnover/group), but once it applies it requires third-party verification, risk management and 10-year documentation.

Timeline: applies in 2024, due diligence in 2025, passport/QR in 2027

The Batteries Regulation was adopted on 12 July 2023, published in the Official Journal on 28 July 2023, entered into force on 17 August 2023 and has applied since 18 February 2024. Article 96 also stages application: Article 11 (removability/replaceability) from 18 February 2027; Article 17 and Chapter VI from 18 August 2024 (with a separate date for Article 17(2)); Chapter VIII (waste battery management) from 18 August 2025; Article 48 due diligence also from 18 August 2025; the battery passport and QR code from 18 February 2027. Carbon footprint declarations are staged under Article 7, with different delegated/implementing act dates for EV, industrial, LMT and external-storage batteries.

DateEventWhat it means
17 Aug 2023Regulation enters into forceImplementation preparation begins
18 Feb 2024AppliesCE, labelling, conformity and other main duties
18 Aug 2024Article 17/Chapter VI, state-of-health dataBMS/state-of-health, labelling, etc.
18 Aug 2025Due diligence, waste battery managementPolicy, third-party verification, recycling registration
18 Feb 2027Battery passport, QR, removability/replaceabilityPassport data, QR, design changes

Sources: Regulation (EU) 2023/1542 Articles 96, 77 and 48; European Commission Batteries page (accessed 8 November 2026). Carbon footprint/recycled content dates follow the Regulation and delegated/implementing acts; this article does not conflate the application date with specific implementing-act dates.

Scope: five battery categories and battery-containing products

The Regulation covers all batteries placed on the EU market, regardless of origin, composition, whether sold separately or incorporated into products/vehicles: portable batteries, LMT batteries (light means of transport such as e-bikes/e-scooters), EV batteries, industrial batteries and SLI batteries (starting, lighting, ignition). Battery-containing products (appliances, tools, toys, vehicles) are also in scope; producer responsibility, CE, labelling, passport and recycling duties vary by category. The passport applies to LMT batteries, industrial batteries above 2 kWh and EV batteries; other batteries also need a QR code from 18 February 2027, but the QR points to different information.

CategoryTypical productsPassport/QR
PortableConsumer electronics, tools, toysQR (non-passport information)
LMTE-bikes, e-scootersPassport + QR
EVElectric vehiclesPassport + QR
Industrial above 2 kWhEnergy storage, industrial equipmentPassport + QR
Industrial up to 2 kWh / SLISmall industrial, starter batteriesQR (category-specific information)

Sources: Regulation (EU) 2023/1542 Articles 1-3, 13(6) and 77 and Annex XIII; European Commission Batteries page (accessed 8 November 2026). This is an editorial summary; category determination, capacity thresholds and battery-containing-product scope require product-specific analysis.

Battery passport and QR: from 18 February 2027

Article 77 requires each LMT battery, industrial battery above 2 kWh and EV battery placed on the market or put into service from 18 February 2027 to have a battery passport (an electronic record). The passport contains model and individual battery information (including information generated during use) and, under Annex XIII, is split into publicly accessible, accessible only to notified bodies/market surveillance authorities/the Commission, and accessible only to legitimate-interest parties (e.g. dismantling and composition details). Article 13(6) requires a QR code on all batteries from the same date; for LMT/industrial above 2 kWh/EV the QR links to the passport, while for other batteries it links to applicable information, the declaration of conformity and waste prevention/management information.

ItemRequirementEvidence/action
Passport scopeLMT, industrial above 2 kWh, EVProduct list, category determination
Passport contentModel + individual battery; Annex XIIIData model, field mapping
Access layersPublic/authorities/legitimate-interest partiesPermissions, API, audit
QR codeAll batteries from 18 February 2027Label/engraving, link
Data updateComplete, up-to-date, accurateVersioning, update process
State of healthBMS data (applicable categories)BMS/data interface

Sources: Regulation (EU) 2023/1542 Articles 13(6), 14 and 77 and Annex XIII (accessed 8 November 2026). This is an editorial summary; passport data fields, access rights and technical specifications follow the Regulation, implementing acts and competent authority requirements.

Due diligence: from 18 August 2025, EUR 40 million threshold and third-party verification

Article 48 requires economic operators placing batteries on the market to establish and implement a battery due diligence policy from 18 August 2025, covering social and environmental risks in the extraction, processing and trading of raw materials such as cobalt, natural graphite, lithium and nickel. The policy must be verified by a notified body and periodically audited; operators must establish a management system and risk management, report publicly, and keep verification/audit documentation for 10 years after the last battery manufactured under the policy is placed on the market. Article 47 sets the threshold: economic operators with net turnover below EUR 40 million in the preceding financial year, and not part of a group exceeding that threshold on a consolidated basis, are outside the chapter; batteries prepared for re-use/repurposing/remanufacturing that were already placed on the market are also exempt.

ElementRequirementEvidence
ScopeEconomic operators placing batteries; EUR 40M/group ruleTurnover, group structure
PolicyBattery due diligence policy covering raw-material risksPolicy document, scope
Management/riskManagement system, risk identification and mitigationRisk register, mitigation records
Third-party verificationNotified-body verification + periodic auditVerification report, audit report
Public reportingPublic due diligence informationReport page, update log
Document retention10 yearsArchive, retention schedule

Sources: Regulation (EU) 2023/1542 Articles 47-52 (accessed 8 November 2026). This is an editorial summary; threshold calculation, exemptions, verification bodies and reporting details follow the Regulation and competent authority requirements.

Carbon footprint, labelling, CE and recycling: staged, do not mix dates

Beyond the passport/due diligence, the Batteries Regulation includes carbon footprint declarations (Article 7, staged by EV/industrial/LMT/external storage and dependent on delegated/implementing acts), recycled content, performance and durability, labelling/QR, CE and conformity assessment, and producer responsibility/recycling. Article 11 removability/replaceability applies from 18 February 2027; Article 14 state-of-health/expected-lifetime data has applied since 18 August 2024 for stationary battery energy storage systems, LMT and EV batteries. Companies should manage the "application date", "implementing-act date" and "product placement date" separately, and not treat one carbon-footprint delegated act date as a universal deadline.

TopicKey pointCheck first
Carbon footprintArticle 7, staged; depends on delegated/implementing actsCategory, date, methodology
Recycled contentCobalt/lead/lithium/nickel recovery contentSupply-chain data, verification
Performance/durabilityArticles 9-10 and Annex IVTest reports
Labelling/QRArticle 13; QR from 18 February 2027Label/engraving, link
CE/conformityConformity assessment, EU declaration, CETechnical file, notified body if applicable
Recycling/producer responsibilityRegistration, collection, recycling efficiencyMember State registration, PRO contract
Removability/replaceabilityArticle 11, from 18 February 2027Design changes, derogations

Sources: Regulation (EU) 2023/1542 Articles 7-14, 17, 18 and 77 and Annexes IV/XIII; European Commission Batteries page (accessed 8 November 2026). This is an editorial summary; dates, test methods and derogations follow the Regulation, implementing acts and competent authority requirements.

90-day implementation checklist

Use the first 90 days to connect battery category, passport data, due diligence, carbon footprint/labelling, CE/registration and evidence. The order is: classification, data mapping, due diligence scope, carbon footprint/labelling, CE/registration, evidence and drills.

PhaseActionOutput
Weeks 1-2Inventory batteries/battery-containing products, category, capacity and EU placement dateProduct list, category determination
Weeks 2-4Map passport data under Annex XIII (model/individual battery/access layers)Data model, field list
Weeks 3-5Determine due diligence applicability (EUR 40M/group) and raw-material risksScope, risk register
Weeks 5-7Build/update due diligence policy; contact a notified body for verificationPolicy, verification plan
Weeks 6-8Check carbon footprint/recycled content/performance tests and labellingTest reports, label draft
Weeks 8-10CE/declaration of conformity, producer registration/PRO contractCE file, registration record
Weeks 10-12QR/passport pilot and data-update drillPilot report, remediation list

Editorial implementation advice, not an official template; specific classification, data fields, verification, testing and registration follow the Batteries Regulation, implementing acts and competent authority requirements.

FAQ

Does the Batteries Regulation apply now?

Yes. It has applied since 18 February 2024; due diligence has applied since 18 August 2025; the battery passport, QR code and removability/replaceability requirements apply from 18 February 2027. Carbon footprint and other requirements are staged under Article 7 and depend on delegated/implementing acts.

Which batteries need a passport?

From 18 February 2027, LMT batteries, industrial batteries above 2 kWh and EV batteries need a battery passport. Other batteries need a QR code from the same date, but the QR points to different information (applicable information, declaration of conformity, waste management, etc.).

What does the passport contain?

Under Annex XIII, it contains model and individual battery information (including information generated during use), split into public, authorities/notified bodies/Commission, and legitimate-interest-party access layers. Specific fields, access rights and technical specifications follow the Regulation/implementing acts.

What must Chinese manufacturers do?

As the economic operator/producer placing batteries on the EU market, complete category determination, CE/conformity, labelling/QR, passport data, due diligence (if applicable), producer registration/recycling responsibility, and clarify roles with importers/distributors. Manufacturers of battery-containing products must also confirm the battery part's compliance.

When does the carbon footprint apply?

Article 7 is staged by category (EV, industrial, LMT, external storage, etc.), and application depends on the adoption and entry into force of delegated/implementing acts. Do not treat one category's date as a universal deadline; check each product category.

What is the due diligence threshold?

Article 47: economic operators with net turnover below EUR 40 million in the preceding financial year, and not part of a group exceeding that threshold on a consolidated basis, are outside the chapter; batteries prepared for re-use/repurposing/remanufacturing that were already placed on the market are also exempt. Applicable operators need a policy, third-party verification/audit, risk management and 10-year documentation.

Must batteries be removable/replaceable?

Article 11 applies from 18 February 2027 and sets removability/replaceability requirements for portable batteries and other categories, with derogations. Check the specific scope, derogation process and design changes against the Regulation and Commission notices.

What are the fines?

The Regulation requires Member States to set effective, proportionate and dissuasive penalties; specific amounts/procedures are set by national law. Cross-border sales also involve national registration, producer responsibility and enforcement practice.

Research method and limitations

This article separates "official facts" from "editorial advice": the Batteries Regulation's adoption/publication/entry-into-force/application dates, five categories, Articles 11/13/14/47-52/77/96, passport/QR, due diligence threshold and third-party verification, and carbon footprint staging come from the European Commission Batteries page, EUR-Lex Regulation (EU) 2023/1542 (consolidated 13 August 2026) and the EUR-Lex summary (accessed 8 November 2026). The 90-day list and "evidence/action" columns are editorial.

Eight limitations: (1) this is not legal advice; (2) national producer registration, recycling schemes and enforcement are not checked country by country; (3) carbon footprint/recycled content/performance implementing-act dates may change; (4) battery category, capacity thresholds and removability/replaceability derogations are highly product-specific; (5) not all Annex fields and technical specifications are covered; (6) the article does not map every interaction with ESPR/ELV/WEEE/REACH; (7) no passport data model or test template is provided; (8) the Regulation/implementing acts may update, so recheck the official pages before publishing.

Sources and basis

Data cut-off 8 November 2026; based on official pages and the Regulation; not legal advice; specific obligations follow the Batteries Regulation, implementing acts and competent authority requirements.

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