What is the new EU Battery Regulation and when does it apply?

The EU Battery Regulation 2023/1542 is new EU legislation replacing the old Battery Directive 2006/66/EC. It entered into force in August 2023 with requirements phasing in through 2027 and beyond. It covers all batteries placed on the EU market including portable, automotive, industrial, EV, and light means of transport (LMT) batteries. The regulation introduces new labeling, sustainability, and due diligence requirements.

What types of batteries does the regulation cover?

The regulation covers five battery categories: (1) Portable batteries—sealed, under 5kg, not designed for industrial use (including batteries in consumer electronics), (2) LMT batteries—for light electric vehicles like e-bikes and scooters, (3) Starting, lighting, ignition (SLI) batteries—for vehicle starting/lighting, (4) Industrial batteries—for industrial use or energy storage, and (5) Electric vehicle batteries—for road vehicles. Requirements vary by category.

What are the new labeling requirements for batteries?

From February 2027, all batteries must be labeled with: (1) The name of the manufacturer, (2) Battery type and chemistry, (3) A QR code linking to battery passport information, (4) Capacity in Ah or Wh, (5) Separate collection symbol (crossed-out wheelie bin), (6) Chemical symbols for hazardous substances (Cd, Pb, Hg). Additional labels for carbon footprint and recycled content will apply to specific battery types on later timelines.

What is the Battery Passport and QR code requirement?

From February 2027, all batteries must carry a QR code linking to a digital Battery Passport containing detailed information about the battery including manufacturer, capacity, chemistry, carbon footprint, recycled content, expected lifetime, and supply chain due diligence information. The passport must be accessible via a public online database. Requirements are more extensive for EV and industrial batteries.

What are the carbon footprint requirements?

For EV batteries and rechargeable industrial batteries over 2kWh: From February 2025, carbon footprint declaration is required. From August 2026, carbon footprint performance classes apply. From 2028, maximum carbon footprint thresholds will be mandatory—batteries exceeding limits cannot be sold. Similar requirements for LMT batteries follow later timelines. The calculation methodology follows delegated acts.

What is Extended Producer Responsibility (EPR) for batteries?

Producers placing batteries on the EU market must join or establish EPR schemes in each member state. Obligations include: financing collection, treatment, and recycling of waste batteries; meeting collection rate targets (45% for portable batteries by 2023, rising to 73% by 2030); achieving recycling efficiency targets; and reporting to authorities. For products with embedded batteries, the product producer is usually responsible.

What due diligence requirements apply to battery supply chains?

From August 2025, economic operators placing batteries on the EU market must implement supply chain due diligence policies covering raw material sourcing. This includes policies for cobalt, natural graphite, lithium, and nickel. Requirements include risk assessment, third-party verification, and public reporting. The regulation aligns with OECD due diligence guidance for responsible supply chains.

How do I handle batteries embedded in products?

Products containing batteries must ensure batteries are removable and replaceable by end-users or independent professionals using readily available tools. This applies from February 2027. Limited exceptions exist for safety, functionality, or data integrity reasons. Products must include information on safe battery removal. The product producer is typically responsible for the embedded battery's compliance.

What are the recycled content requirements?

From August 2031, batteries must contain minimum levels of recycled cobalt, lead, lithium, and nickel from battery manufacturing waste or post-consumer waste. Initial targets: 16% cobalt, 85% lead, 6% lithium, 6% nickel. From 2036: 26% cobalt, 85% lead, 12% lithium, 15% nickel. Declaration of recycled content is required from August 2028. These apply to industrial, EV, LMT, and SLI batteries.

What happens to the old Battery Directive requirements?

The Battery Directive 2006/66/EC is repealed and replaced by the new regulation. However, some Directive provisions continue to apply during transition periods. Existing labeling requirements remain valid until new labeling requirements apply (February 2027). EPR schemes established under the Directive continue but must adapt to new requirements. Technical documentation from Directive compliance may need updating.

EU Regulation

New 2023

22 min read

EU Battery Regulation Guide

The new EU Battery Regulation 2023/1542 introduces comprehensive requirements for batteries and products containing batteries. This guide covers labeling, QR codes, battery passports, carbon footprint, EPR obligations, and due diligence—with a timeline of when each requirement applies.

Phased Implementation

The Battery Regulation has a complex timeline with requirements phasing in from 2024 through 2031. Key upcoming deadlines include carbon footprint declaration (February 2025), due diligence (August 2025), and new labeling with QR codes (February 2027). Plan now to meet these deadlines.

What is the EU Battery Regulation?

The EU Battery Regulation (2023/1542) is comprehensive EU legislation governing batteries throughout their entire lifecycle—from raw material sourcing through manufacturing, use, and end-of-life recycling. It replaces the outdated Battery Directive 2006/66/EC and reflects the EU's Green Deal objectives for a circular economy.

The regulation applies to all batteries placed on the EU market, regardless of their origin or whether they're sold separately or incorporated into products. This includes everything from button cells and power banks to e-bike batteries and electric vehicle battery packs. Five categories are defined, each with specific requirements.

Key innovations include mandatory carbon footprint declarations, minimum recycled content requirements, digital battery passports accessible via QR code, supply chain due diligence obligations, and enhanced extended producer responsibility (EPR) requirements. The regulation also mandates that batteries in products be removable and replaceable.

For e-commerce sellers, the regulation affects any product containing batteries—smartphones, laptops, toys, power tools, e-bikes, and countless other consumer electronics. Understanding the timeline and preparing early is essential to avoid compliance gaps.

Battery Categories

Portable Batteries

Sealed batteries under 5kg, not for industrial use

Examples:

Button cellsAA/AAA batteriesLaptop batteriesPower banksSmartphone batteries

Key Requirements:

LabelingQR codeEPR registrationRemovability

LMT Batteries

Batteries for light means of transport

Examples:

E-bike batteriesE-scooter batteriesElectric skateboard batteries

Key Requirements:

LabelingQR codeCarbon footprintEPRRecycled content

SLI Batteries

Starting, lighting, ignition batteries for vehicles

Examples:

Car starter batteriesMotorcycle batteriesTruck batteries

Key Requirements:

LabelingEPR registrationRecycled content

Industrial Batteries

Batteries for industrial applications or energy storage

Examples:

Forklift batteriesUPS batteriesGrid storageTelecom backup

Key Requirements:

LabelingQR codeBattery passportCarbon footprintDue diligence

EV Batteries

Batteries for electric road vehicles

Examples:

Electric car batteriesElectric bus batteriesElectric truck batteries

Key Requirements:

Full requirementsBattery passportCarbon footprint limitsDue diligenceState of health

Implementation Timeline

August 2023✓ Passed

Regulation Entry into Force

Regulation 2023/1542 enters into force, beginning transition from Battery Directive

August 2024✓ Passed

EPR Registration Deadline

Producers must be registered with EPR schemes in each member state where batteries are sold

February 2025Upcoming

Carbon Footprint Declaration (EV/Industrial)

EV batteries and industrial batteries >2kWh must declare carbon footprint

August 2025Upcoming

Due Diligence Requirements

Supply chain due diligence policies required for all batteries placed on market

August 2026Upcoming

Carbon Footprint Classes

Carbon footprint performance class labels required on EV and large industrial batteries

February 2027Upcoming

New Labeling & QR Code

All batteries must have new labels, QR codes, and battery passports

February 2027Upcoming

Removability Requirement

Portable batteries in products must be removable by end-users or professionals

August 2028Upcoming

Carbon Footprint Limits

Maximum carbon footprint thresholds for EV batteries—non-compliant batteries banned

August 2028Upcoming

Recycled Content Declaration

Batteries must declare recycled content of cobalt, lead, lithium, nickel

August 2031Upcoming

Recycled Content Minimums

Minimum recycled content requirements enter into force

Labeling Requirements

Battery labeling requirements are phasing in with the most significant changes coming in February 2027 when QR codes and new label formats become mandatory for all batteries. Plan label updates well in advance.

Manufacturer Identification

February 2027All

Name and registered trade name or trademark of the manufacturer

Battery Type & Chemistry

February 2027All

Indication of battery type and chemical composition

Capacity

February 2027All

Rated capacity in Ah (ampere-hours) or Wh (watt-hours)

QR Code

February 2027All

Link to battery passport with detailed product information

Separate Collection Symbol

Current (continuing)All

Crossed-out wheeled bin indicating separate collection requirement

Hazardous Substance Symbols

Current (continuing)All (if applicable)

Cd, Pb, Hg symbols if thresholds exceeded

Carbon Footprint Class

August 2026EV, Industrial >2kWh

Performance class label A-E based on carbon footprint

Recycled Content

August 2028Industrial, EV, LMT, SLI

Declaration of recycled cobalt, lead, lithium, nickel content

Battery Passport & QR Code

From February 2027, all batteries must carry a QR code linking to a digital Battery Passport. The passport must be accessible via an online system and contain comprehensive information about the battery. EV and industrial batteries have more extensive requirements.

General Information

Battery unique identifier
Manufacturer information
Manufacturing date and place
Battery weight
Battery category

Technical Specifications

Battery chemistry
Rated capacity (Ah/Wh)
Nominal voltage
Expected lifetime (cycles/years)
Temperature range for operation

Sustainability Data

Carbon footprint declaration
Recycled content percentages
Renewable energy share in manufacturing
Supply chain due diligence report
Hazardous substances content

End-of-Life Information

Dismantling and removal information
Safety instructions
Recycling information
Collection point information
Second-life possibility assessment

State of Health (EV batteries)

Remaining capacity
Remaining power
State of charge
Number of charging cycles
Negative events (accidents, damage)

Extended Producer Responsibility (EPR)

Producers (manufacturers, importers, distance sellers) placing batteries on the EU market must register with EPR schemes in each member state. For products with embedded batteries, the product producer is typically responsible for the battery.

Registration

Before placing on market (August 2024 deadline passed)

Applies to: All producers (manufacturers, importers, distance sellers)

Financial Responsibility

Ongoing

Finance collection, treatment, and recycling of waste batteries

Applies to: All producers

Collection Targets

Annual targets

Contribute to achieving collection rate targets (45% 2023 → 73% 2030 for portable)

Applies to: Portable and LMT battery producers

Reporting

Annual

Report batteries placed on market and waste batteries collected/recycled

Applies to: All producers

Take-back

Ongoing

Accept return of waste batteries at no charge

Applies to: Distributors and producers

Recycling Efficiency

Various by battery type

Ensure batteries are recycled meeting minimum efficiency targets

Applies to: All producers via EPR schemes

Important: EPR registration deadlines have passed in most member states. If you sell batteries or products containing batteries in the EU and haven't registered, you may be non-compliant. Each country has its own EPR scheme—registration in one doesn't cover others.

Supply Chain Due Diligence (August 2025)

From August 2025, economic operators placing batteries on the EU market must implement supply chain due diligence policies for raw materials—specifically cobalt, lithium, nickel, and natural graphite. This follows OECD guidance for responsible supply chains.

Establish Management System

Implement supply chain due diligence policy covering cobalt, lithium, nickel, and natural graphite sourcing.

Identify and Assess Risks

Map supply chain and assess risks related to social, environmental, and governance issues in raw material sourcing.

Implement Risk Management

Design and implement strategies to respond to identified risks, including engagement with suppliers.

Third-Party Verification

Have due diligence practices verified by an independent notified body.

Public Reporting

Publish annual due diligence report making policies and risk assessments available.

Grievance Mechanism

Establish mechanism to address concerns from supply chain workers and communities.

Carbon Footprint Requirements

EV batteries and rechargeable industrial batteries over 2kWh must declare their carbon footprint from February 2025. This will be followed by performance class labels (A-E) from August 2026 and maximum thresholds from August 2028.

Feb 2025