Two deadlines, six months apart
The Batteries Regulation – Regulation (EU) 2023/1542 – phases in its obligations over several years. Two of the biggest now fall in 2027, but not on the same day:
- 18 February 2027: the battery passport and the QR code on all batteries.
- 18 August 2027: the battery due diligence obligations, after a two-year postponement adopted in 2025.
Many compliance plans written before mid-2025 still show due diligence starting in August 2025. That date no longer applies. This guide sets out what each 2027 obligation covers and how to use 2026 to prepare. For the full regulation, see our Batteries Regulation guide and the glossary entry on the Batteries Regulation.
Which batteries need a passport (Article 77)
From 18 February 2027, Article 77(1) requires an electronic record – the battery passport – for each of the following when placed on the market or put into service:
- LMT batteries – batteries for light means of transport such as e-bikes and e-scooters;
- industrial batteries with a capacity greater than 2 kWh;
- electric-vehicle batteries.
Portable batteries and SLI (starter, lighting and ignition) batteries do not need a passport.
The passport contains information about the battery model and about the individual battery, including information resulting from its use, as listed in Annex XIII. Access is layered (Article 77(2)): some information is public, some is reserved for notified bodies, market surveillance authorities and the Commission, and some is available to persons with a legitimate interest such as repairers, remanufacturers, second-life operators and recyclers. The Commission must adopt implementing acts by 18 August 2026 specifying who counts as a person with a legitimate interest and what they can access (Article 77(9)).
Who is responsible? The economic operator placing the battery on the market must attribute a unique identifier to it and ensure that the passport information is accurate, complete and up to date. It may authorise another operator in writing to act on its behalf (Article 77(3) and (4)). When a battery is repurposed or remanufactured, a new passport is created and responsibility passes to the operator placing that battery on the market (Article 77(7)).
The data must be based on open standards, in an interoperable, machine-readable format, transferable without vendor lock-in (Article 77(5)). For the practical questions, see preparing a battery passport.
The QR code on every battery (Article 13(6))
The passport is reached through a QR code. From 18 February 2027, Article 13(6) requires all batteries – not only passport batteries – to be marked with a QR code:
- for LMT, EV and industrial batteries above 2 kWh, it gives access to the battery passport;
- for other batteries, it gives access to the label information, the declaration of conformity, information on waste prevention and management and, where applicable, the due diligence report under Article 52(3).
So even a producer of portable batteries, outside the passport scope, has a 2027 deadline for a data carrier and the information behind it.
Two other label dates are worth knowing. The separate collection symbol has been required on all batteries since 18 August 2025 (Article 13(4)). The general information label and the capacity labels apply from 18 August 2026 or 18 months after the Commission’s implementing act on labelling enters into force, whichever is later (Article 13(1)–(3)). See battery labelling for what goes on the label.
Due diligence postponed to 18 August 2027 (Article 48)
Article 48 obliges economic operators that place batteries on the market or put them into service to set up and implement battery due diligence policies covering the raw materials listed in Annex X – cobalt, natural graphite, lithium and nickel. The policies must be verified by a notified body and periodically audited (Article 48(2)), and the documentation must be kept for 10 years after the last battery manufactured under the policy is placed on the market (Article 48(3)).
The original start date was 18 August 2025. Regulation (EU) 2025/1561, adopted on 18 July 2025 and in force since 31 July 2025, replaced it with 18 August 2027. Its recitals give the reasons: battery manufacturers need time to analyse and adjust their supply chains, the designation of notified bodies for third-party verification was taking longer than expected, and recognised due diligence schemes still need to be developed.
The same amendment moved the Commission’s deadline for publishing guidelines on the due diligence requirements from 18 February 2025 to 26 July 2026 (Article 48(5)), aligning it with the guidance due under the Corporate Sustainability Due Diligence Directive.
Who is in scope? Under Article 47, the due diligence chapter does not apply to economic operators with a net turnover below EUR 40 million in the financial year preceding the last financial year, unless they are part of a group that exceeds that limit on a consolidated basis. It also does not apply to batteries that were already on the market before being prepared for re-use, repurposed or remanufactured. See battery due diligence for a scope check.
A 2026 preparation plan
The two deadlines need different kinds of work, and both depend on suppliers.
For the passport (February 2027):
- List every battery model you place on the market and classify it: LMT, EV, industrial above 2 kWh, or other.
- For passport batteries, map the Annex XIII data you hold, the data your cell or pack supplier holds, and the gaps.
- Decide who operates the passport – you or an operator acting on your written authorisation – and how unique identifiers will be attributed.
- Plan the QR code for every battery, including those outside the passport scope.
For due diligence (August 2027):
- Check the Article 47 turnover threshold for your company and group.
- Identify which of your batteries contain cobalt, natural graphite, lithium or nickel, and from which suppliers.
- Start supplier questionnaires and traceability requests now; verification by a notified body must be in place when the obligation starts.
- Watch for the Commission’s guidelines, due by 26 July 2026.
Batteries built into products bring the same questions to manufacturers of e-bikes, tools and electronics. If that is your situation, the battery in a product page explains how the obligations are shared.
How Conphora helps
Both 2027 obligations come down to structured data that has to be collected from suppliers, kept current and shown to the right people. Conphora helps you:
- Classify battery models by category and capacity, so you know which need a passport.
- Collect supplier data for Annex XIII and for the due diligence raw materials, with requests and answers stored per supplier.
- Keep due diligence documentation – policies, verification reports and audit reports – with the 10-year retention in view.
- Track the dates for the passport, the QR code, the labels and due diligence in one compliance calendar.
Eleven months to the battery passport. Start with the classification and the supplier data – they take the longest. See plans and pricing →