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.
(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.
| Date | Event | What it means |
|---|---|---|
| 17 Aug 2023 | Regulation enters into force | Implementation preparation begins |
| 18 Feb 2024 | Applies | CE, labelling, conformity and other main duties |
| 18 Aug 2024 | Article 17/Chapter VI, state-of-health data | BMS/state-of-health, labelling, etc. |
| 18 Aug 2025 | Due diligence, waste battery management | Policy, third-party verification, recycling registration |
| 18 Feb 2027 | Battery passport, QR, removability/replaceability | Passport 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.
| Category | Typical products | Passport/QR |
|---|---|---|
| Portable | Consumer electronics, tools, toys | QR (non-passport information) |
| LMT | E-bikes, e-scooters | Passport + QR |
| EV | Electric vehicles | Passport + QR |
| Industrial above 2 kWh | Energy storage, industrial equipment | Passport + QR |
| Industrial up to 2 kWh / SLI | Small industrial, starter batteries | QR (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.
| Item | Requirement | Evidence/action |
|---|---|---|
| Passport scope | LMT, industrial above 2 kWh, EV | Product list, category determination |
| Passport content | Model + individual battery; Annex XIII | Data model, field mapping |
| Access layers | Public/authorities/legitimate-interest parties | Permissions, API, audit |
| QR code | All batteries from 18 February 2027 | Label/engraving, link |
| Data update | Complete, up-to-date, accurate | Versioning, update process |
| State of health | BMS 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.
| Element | Requirement | Evidence |
|---|---|---|
| Scope | Economic operators placing batteries; EUR 40M/group rule | Turnover, group structure |
| Policy | Battery due diligence policy covering raw-material risks | Policy document, scope |
| Management/risk | Management system, risk identification and mitigation | Risk register, mitigation records |
| Third-party verification | Notified-body verification + periodic audit | Verification report, audit report |
| Public reporting | Public due diligence information | Report page, update log |
| Document retention | 10 years | Archive, 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.
| Topic | Key point | Check first |
|---|---|---|
| Carbon footprint | Article 7, staged; depends on delegated/implementing acts | Category, date, methodology |
| Recycled content | Cobalt/lead/lithium/nickel recovery content | Supply-chain data, verification |
| Performance/durability | Articles 9-10 and Annex IV | Test reports |
| Labelling/QR | Article 13; QR from 18 February 2027 | Label/engraving, link |
| CE/conformity | Conformity assessment, EU declaration, CE | Technical file, notified body if applicable |
| Recycling/producer responsibility | Registration, collection, recycling efficiency | Member State registration, PRO contract |
| Removability/replaceability | Article 11, from 18 February 2027 | Design 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.
| Phase | Action | Output |
|---|---|---|
| Weeks 1-2 | Inventory batteries/battery-containing products, category, capacity and EU placement date | Product list, category determination |
| Weeks 2-4 | Map passport data under Annex XIII (model/individual battery/access layers) | Data model, field list |
| Weeks 3-5 | Determine due diligence applicability (EUR 40M/group) and raw-material risks | Scope, risk register |
| Weeks 5-7 | Build/update due diligence policy; contact a notified body for verification | Policy, verification plan |
| Weeks 6-8 | Check carbon footprint/recycled content/performance tests and labelling | Test reports, label draft |
| Weeks 8-10 | CE/declaration of conformity, producer registration/PRO contract | CE file, registration record |
| Weeks 10-12 | QR/passport pilot and data-update drill | Pilot 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
- European Commission, Batteries: environment.ec.europa.eu/topics/waste-and-recycling/batteries_en. Regulation 2023/1542, five categories, entry into force 17 August 2023, application 18 February 2024, recycling/labelling/due diligence. Accessed 8 November 2026.
- EUR-Lex, Regulation (EU) 2023/1542 (consolidated 13 August 2026): eur-lex.europa.eu/eli/reg/2023/1542/oj. Articles 11/13/14/47-52/77/96 and Annex XIII. Accessed 8 November 2026.
- EUR-Lex, Batteries - official summary: eur-lex.europa.eu/legal-content/EN/LSU/?uri=CELEX:32023R1542. Key points, categories and timeline. Accessed 8 November 2026.
- European Commission, Commission publishes new waste batteries rules (4 July 2025): environment.ec.europa.eu/news/commission-publishes-new-waste-batteries-rules-2025-07-04_en. Recycling efficiency/material recovery calculation and verification rules. Accessed 8 November 2026.
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.