The Battery Regulation: Timelines, Requirements and Preparation

A New Era for Batteries in the EU

The EU Battery Regulation (Regulation 2023/1542) marks a fundamental shift in the way batteries are regulated in Europe. The old Battery Directive from 2006 was not designed for a world of electric vehicles, energy storage and increasingly complex supply chains. The new regulation addresses this – and it has broad reach.

If your business manufactures, imports or distributes products containing batteries, this regulation is relevant to you. In this article, we review what the regulation covers, which deadlines you need to know, and how best to prepare.

What Does the Battery Regulation Cover?

The regulation applies to all batteries placed on the EU market – regardless of type, size or application. It divides batteries into five categories:

• Portable batteries – the small batteries in everyday products such as remote controls, toys and tools.
• Starting batteries (SLI) – used primarily in vehicles for starting, lighting and ignition.
• Traction batteries (EV) – the large battery packs in electric vehicles and electric scooters.
• Industrial batteries – batteries for energy storage, backup systems and industrial applications.
• Light means of transport batteries (LMT) – a new category covering batteries for e-bikes, electric scooters and similar.

It is important to understand that the regulation does not only apply to battery manufacturers. Importers, distributors and companies that incorporate batteries into their products also have obligations.

Timeline: The Most Important Deadlines from 2025 to 2027

The Battery Regulation is phased in gradually with staggered deadlines. Here are the key milestones you need to be aware of:

2025

• 18 February 2025: Carbon footprint declaration requirements for EV batteries and rechargeable industrial batteries with a capacity above 2 kWh come into force (provided the delegated acts have been adopted).
• 18 August 2025: New labelling requirements for all batteries, including general information requirements, separate collection symbol and hazardous substance labelling.
• 18 August 2025: Requirement that portable batteries in appliances must be replaceable by the end user (with certain exceptions).

2026

• 18 February 2026: Carbon footprint performance classes for EV batteries (delegated acts expected).
• 18 August 2026: Due diligence obligations for economic operators come fully into force.
• 18 August 2026: QR code requirement providing access to battery information.

2027

• 18 February 2027: Battery Passport requirement for EV batteries and industrial batteries above 2 kWh.
• 18 August 2027: Minimum recycled content requirements for lead, cobalt, lithium and nickel.
• 18 August 2027: Maximum carbon footprint limits for EV batteries.

The timeline is ambitious, and there are no signs that the EU will postpone deadlines. Preparation is therefore essential.

The Central Requirements in Detail

Carbon Footprint Declaration

For EV batteries and large industrial batteries, a carbon footprint declaration must be prepared covering the battery’s total climate impact from raw material extraction to production. The calculation must follow a standardised method set by the European Commission.

This requires you to have full visibility into your supply chain and be able to collect reliable data on energy consumption, materials and transport from your suppliers.

Recycled Content Requirements

From 2027, certain batteries must contain a minimum share of recycled materials. The preliminary requirements are:

• 16% cobalt from recycling
• 6% lithium from recycling
• 6% nickel from recycling
• 85% lead from recycling

These thresholds are expected to increase further from 2031. You must be able to document the recycled material content in your batteries.

Labelling and QR Code

All batteries must bear clear labelling with information about capacity, lifespan, chemical composition and separate collection. From 2026, batteries must also have a QR code providing access to additional product information digitally.

The QR code is a precursor to the broader Digital Product Passport concept that the EU is rolling out under several regulations. See all EU compliance changes in 2025 to understand how the Battery Regulation interacts with ESPR, GPSR and other regulatory frameworks.

Due Diligence in the Supply Chain

Economic operators placing batteries on the EU market must establish and implement a due diligence policy for their supply chain. The requirement is inspired by the OECD guidelines and covers:

• Identification and assessment of risks to human rights and the environment.
• Prevention and mitigation of identified risks.
• Publication of due diligence policies and results.
• Third-party verification of the due diligence system.

The requirement applies to the entire supply chain – from mining of raw materials to the finished battery cell. This places significant demands on supplier management and data sharing.

Battery Passport: The Digital Product Pass

The Battery Passport is one of the most groundbreaking elements of the regulation. From February 2027, EV batteries and industrial batteries above 2 kWh must have a digital passport containing detailed information about:

• The battery’s chemical composition and materials.
• Carbon footprint data.
• Recycled content.
• Lifespan and performance data.
• Disassembly and recycling instructions.
• Supply chain due diligence information.

The Battery Passport must be accessible via a unique identifier and stored in a decentralised data system. It is closely connected to the EU’s broader vision for the Digital Product Passport and will likely serve as a model for other product categories.

The relationship between batteries and other chemical substances is also worth being aware of. Read about RoHS and restricted substances to understand how substance restrictions affect battery production.

Who Is Responsible?

The regulation assigns responsibility at multiple levels:

• Manufacturers bear the primary responsibility for compliance, including labelling, documentation, carbon footprint declaration and Battery Passport.
• Importers must ensure that batteries from third-country manufacturers meet all requirements before they are placed on the EU market.
• Distributors must verify that the necessary labelling and information are present.
• Authorised representatives can be appointed by manufacturers outside the EU to handle certain compliance obligations.

Note that companies selling products with embedded batteries (e.g. electronics, tools or vehicles) may also have obligations under the regulation – particularly regarding battery replaceability and labelling.

How to Prepare: Concrete Steps

1. Map your battery products – Identify all products in your range that contain batteries and classify them according to the regulation’s categories.
2. Assess your supply chain – Do you have sufficient visibility into where your batteries come from and what materials they contain?
3. Prepare labelling changes – Review your current labels and packaging and plan updates well in advance.
4. Establish data infrastructure – The Battery Passport requires structured, digital data. Start building the necessary systems now.
5. Engage your suppliers – You will need data from your suppliers about carbon footprint, recycled content and due diligence. Start the dialogue early.
6. Monitor delegated acts – Many of the technical details are set out in delegated acts that are continuously issued by the European Commission. Stay up to date.

Conphora Helps You with the Battery Regulation

The Battery Regulation is complex, and the requirements evolve as delegated acts and implementing rules are published. Keeping track manually is a time-consuming task that easily leads to missed deadlines.

Conphora gives you a comprehensive overview of the Battery Regulation’s requirements and deadlines, tailored to your specific product categories. The platform updates automatically when new delegated acts are adopted or deadlines change, so you always know exactly what applies to you.

You can also use Conphora to structure your product documentation and prepare for the Battery Passport requirement – so you are not starting from scratch when the deadline arrives.

Start free with Conphora and see how the platform can help you navigate the Battery Regulation.

Make the Battery Regulation manageable. Conphora brings together deadlines, requirements and documentation in one place, so you can focus on your business instead of drowning in regulation. Try Conphora free – see pricing and plans →