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BattR Environment & Waste 10 min Changing in the next 12 months

BattR: EU Batteries Regulation (Regulation (EU) 2023/1542), explained

The Batteries Regulation sets sustainability, safety, labelling, due diligence and end-of-life rules for every battery placed on the EU market, from AA cells to electric vehicle packs. It has applied since 18 February 2024, replacing the 2006 Batteries Directive, with the battery passport due from 18 February 2027 and due diligence from 18 August 2027.

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Reviewed 24 September 2026 by Conphora compliance team · Next review 18 February 2027 · Not legal advice

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Who it applies to

Covered by the act

  • Portable batteries (sealed, 5 kg or less, not for industrial use)
  • Light means of transport (LMT) batteries (sealed, 25 kg or less, for e-bikes, e-scooters and similar)
  • Starting, lighting and ignition (SLI) batteries
  • Industrial batteries (designed for industrial use, or any other battery above 5 kg)
  • Electric vehicle batteries
  • Battery cells and modules made available for end use
  • Batteries incorporated into or added to products
  • Batteries prepared for re-use, repurposed or remanufactured

Derived and downstream products

  • Appliances and electrical and electronic equipment powered by portable batteries
  • Portable batteries of general use (AA, AAA, C, D, 9 V, button cells and similar formats)
  • E-bikes, e-scooters and other light means of transport
  • Hybrid and electric vehicles of categories L, M, N and O
  • Stationary battery energy storage systems
  • Vehicles, other means of transport and machinery with SLI batteries

Roles under the act

Manufacturer

Any natural or legal person who manufactures a battery or has a battery designed or manufactured, and markets it under its own name or trademark or puts it into service for its own purposes.

Source · Art. 3(1)(33)
Importer

Any natural or legal person established in the Union who places on the market a battery from a third country.

Source · Art. 3(1)(64)
Distributor

Any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes a battery available on the market.

Source · Art. 3(1)(65)
Fulfilment service provider

A service provider that warehouses, packages, addresses or dispatches batteries for others, as defined in Regulation (EU) 2019/1020.

Source · Art. 3(2)(b), Art. 43
Online platform

A provider of an online platform, as defined in Regulation (EU) 2022/2065, that allows consumers to conclude distance contracts with producers of batteries.

Source · Art. 3(1)(67), Art. 62(6)
Producer (extended producer responsibility)

Any manufacturer, importer, distributor or other person that, in a Member State, supplies batteries for the first time under its own name, resells others' unbranded batteries under its own name, supplies batteries from another country on a professional basis, or sells batteries by distance contract into that Member State from abroad, including batteries incorporated in appliances or vehicles.

Source · Art. 3(1)(47)
Re-use, repurposing or remanufacturing operator

An economic operator that places on the market or puts into service a battery that has been prepared for re-use, prepared for repurposing, repurposed or remanufactured; treated as the manufacturer and as the producer of that battery.

Source · Art. 38(11), Art. 56(2)

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Does BattR apply to your product?

Three questions, a first answer from the regulation’s own scope rules. No account needed.

The rules behind this check
  1. Product with a battery built in or supplied with it · Manufacturer, Importer, Re-use, repurposing or remanufacturing operator · any In scope Batteries incorporated into or added to products are covered as batteries, and from 18 February 2027 whoever places a product with a portable battery on the market must make that battery removable and replaceable by the end user, with LMT batteries replaceable by an independent professional. Source · Art. 1(3), Art. 11
  2. Product with a battery built in or supplied with it · Distributor, Fulfilment service provider, Online platform, Producer (extended producer responsibility) · any In scope The battery inside the product is in scope: distributors verify marking and producer registration, producers register and finance collection for batteries incorporated in appliances and vehicles, while the retail take-back duty does not extend to waste products containing batteries. Source · Art. 1(3), Art. 42, Art. 55(2), Art. 62(2)
  3. any · Manufacturer, Importer, Re-use, repurposing or remanufacturing operator · Large In scope All battery categories are covered regardless of shape, weight, chemistry or use; the product duties apply from 18 August 2024 and, from 18 August 2027, an operator whose net turnover reached EUR 40 million must also run a verified battery due diligence policy. Source · Art. 1(3), Art. 47, Art. 48(1), Art. 96(2)
  4. any · Manufacturer, Importer, Re-use, repurposing or remanufacturing operator · Small or medium (SME) In scope All battery categories are covered and the product, labelling and documentation duties apply in full; only the due diligence chapter is switched off for operators with a net turnover below EUR 40 million that are not part of a group above that limit. Source · Art. 1(3), Art. 47
  5. any · Manufacturer, Importer, Re-use, repurposing or remanufacturing operator · Micro In scope All battery categories are covered and the product, labelling and documentation duties apply in full; only the due diligence chapter is switched off for operators with a net turnover below EUR 40 million that are not part of a group above that limit. Source · Art. 1(3), Art. 47
  6. any · Manufacturer, Importer, Re-use, repurposing or remanufacturing operator · any In scope All battery categories are covered regardless of shape, weight, chemistry or use, and the manufacturer and importer duties apply from 18 August 2024; whether the due diligence chapter applies depends on a net turnover threshold of EUR 40 million. Source · Art. 1(3), Art. 47, Art. 96(2)
  7. any · Distributor · any In scope Distributors of every battery category must check producer registration, CE marking, labelling and documents before selling, and take back waste batteries of the categories they sell free of charge at or near the retail outlet. Source · Art. 42, Art. 62
  8. any · Producer (extended producer responsibility) · any In scope Whoever first makes a battery of any category available in a Member State is its producer and must register there and carry extended producer responsibility from 18 August 2025, whatever the company size. Source · Art. 3(1)(47), Art. 55, Art. 56, Art. 96(2)
  9. any · Fulfilment service provider · any In scope Fulfilment service providers must keep warehousing, packaging, addressing and dispatch from jeopardising compliance, cooperate with authorities and report batteries presenting a risk. Source · Art. 43
  10. any · Online platform · any In scope Online platforms that let consumers buy batteries from producers must obtain each producer's registration number and a self-certification that it meets its extended producer responsibility obligations. Source · Art. 62(6)
  11. any · any · any It depends The Regulation covers every battery category and every operator in the chain; the exclusions are batteries incorporated into equipment for Member States' essential security interests, arms, munitions and war material intended specifically for military purposes, and equipment designed to be sent into space, while Chapters III (labelling, marking and information) and IX (market surveillance) do not apply to equipment specifically designed for the safety of nuclear installations. Source · Art. 1(5)-(6)

Key dates

  1. Published in the Official Journal (OJ L 191) Source
  2. Entry into force, the twentieth day after publication Source · Art. 96(1)
  3. First collection target for waste portable batteries: 45 % Source · Art. 59(3)
  4. The Regulation applies, save for the provisions with their own dates Source · Art. 96(2)
  5. Regulation (EU) 2024/1781 (ESPR) in force: the unique identifier of each battery passport must be uploaded to the ESPR registry (new Art. 77(10)) Source · Art. 78, Art. 80
  6. Conformity assessment (Art. 17) and the obligations of manufacturers, importers, distributors and fulfilment service providers (Chapter VI) apply, except Art. 17(2) on the conformity assessment of the carbon footprint and recycled content requirements (Art. 7 and 8), which applies 12 months after the first publication of the list of notified bodies Source · Art. 96(2)(b), Art. 17(2), Art. 30(2)
  7. Performance and durability document for rechargeable industrial batteries above 2 kWh, LMT batteries and electric vehicle batteries; state-of-health data in the battery management system; safety documentation for stationary storage systems; lead limit of 0,01 % in portable batteries Source · Art. 10(1), Art. 12(2), Art. 14(1), Annex I
  8. Commission Delegated Regulation (EU) 2025/606 in force: methodology for recycling efficiency and material recovery rates Source · Art. 2
  9. Regulation (EU) 2025/1561 in force: due diligence obligations postponed to 18 August 2027 Source · Art. 1, Art. 2
  10. Chapter VIII (producer registration, extended producer responsibility, collection, treatment and reporting) applies; Directive 2006/66/EC repealed; separate collection symbol on all batteries; Member States' penalty rules due Source · Art. 96(2), Art. 95, Art. 13(4), Art. 93
  11. Deadline for the Commission's guidelines on battery due diligence Source · Art. 48(5)
  12. Regulation (EU) 2026/1738 (end-of-life vehicles) applies to BattR: Annex I substance restrictions replaced: the mercury, cadmium and lead limits are kept and new conditions on cadmium, lead and hexavalent chromium are added for batteries incorporated in M1 and N1 vehicles Source · Art. 53, Art. 59(2), Annex XII
  13. General information label on all batteries, capacity label on rechargeable portable, LMT and SLI batteries, and 'non-rechargeable' label, or 18 months after the implementing act if later Source · Art. 13(1)-(3)
  14. Portable batteries must be removable and replaceable by the end user and LMT batteries by an independent professional (Art. 11); QR code on all batteries; battery passport for LMT, industrial above 2 kWh and electric vehicle batteries Source · Art. 96(2), Art. 13(6), Art. 77(1)
  15. Battery due diligence obligations apply to economic operators with a net turnover of EUR 40 million or more Source · Art. 48(1), Art. 47
  16. Collection target for waste portable batteries: 63 % Source · Art. 59(3)
  17. Recycled content documentation for industrial batteries above 2 kWh, electric vehicle and SLI batteries (or 24 months after the delegated act if later); minimum performance for portable batteries of general use and LMT batteries (or 18 to 24 months after the delegated acts if later); lead limit applies to zinc-air button cells Source · Art. 8(1), Art. 9(1), Art. 10(3), Annex I
  18. Collection target for waste LMT batteries: 51 % Source · Art. 60(3)
  19. Collection target for waste portable batteries: 73 % Source · Art. 59(3)
  20. Minimum recycled content in active materials: 16 % cobalt, 85 % lead, 6 % lithium, 6 % nickel Source · Art. 8(2)
  21. Collection target for waste LMT batteries: 61 % Source · Art. 60(3)
  22. Recycled content documentation extends to LMT batteries Source · Art. 8(1)
  23. Minimum recycled content rises to 26 % cobalt, 85 % lead, 12 % lithium, 15 % nickel, LMT batteries included Source · Art. 8(3)

What you must do

Obligations by role

Manufacturer25
  • Design and make every battery to the substance, carbon footprint, recycled content, performance and durability, safety and state-of-health requirements of Art. 6 to 10, 12 and 14. Art. 38(1)
  • Mark and label every battery as Art. 13 requires (general information, capacity, separate-collection symbol, hazardous substances, QR code). Art. 38(1), Art. 13
  • Supply instructions and safety information with the battery in the language(s) of the Member State of sale. Art. 38(1)
  • Before placing a battery on the market, draw up the technical documentation of Annex VIII. Art. 38(2), Annex VIII
  • Carry out the conformity assessment procedure of Art. 17 (Module A, D1 or G — with a notified body for the carbon footprint and recycled-content requirements) before placing the battery on the market. Art. 38(2), Art. 17
  • Draw up the EU declaration of conformity of Art. 18 and keep it with the technical documentation. Art. 38(3), Art. 18
  • Affix the CE marking to the battery, or to its packaging and accompanying documents where the battery does not allow it, before placing it on the market. Art. 38(3), Art. 20
  • Keep the technical documentation and the EU declaration of conformity at the disposal of national authorities for 10 years after the battery was placed on the market. Art. 38(4)
  • Have procedures in place so that batteries that are part of series production remain in conformity, taking account of changes in design or characteristics and in the harmonised standards, common specifications or other technical specifications referenced. Art. 38(5)
  • Mark each battery with a model identification and batch or serial number, and with your name or trademark, postal address and a single contact point, or put this on the packaging or an accompanying document where the battery is too small. Art. 38(6)-(7)
  • From 18 August 2024, accompany rechargeable industrial batteries above 2 kWh, LMT batteries and electric vehicle batteries with a document stating the values of the Annex IV electrochemical performance and durability parameters. Art. 10(1)
  • Hold up-to-date state-of-health and expected-lifetime data in the battery management system of stationary battery energy storage systems, LMT batteries and electric vehicle batteries, with read-only access for anyone who has legally purchased the battery, including independent operators or waste management operators, or a third party acting on their behalf. Art. 14(1)-(2), Art. 38(8)
  • Draw up a carbon footprint declaration per battery model and manufacturing plant for electric vehicle batteries, rechargeable industrial batteries above 2 kWh and LMT batteries, staged from 18 February 2025 (electric vehicle), 18 February 2026 (rechargeable industrial) and 18 August 2028 (LMT), or 12 to 18 months after the Commission's methodology and format acts if that is later; performance classes and maximum thresholds follow on later dates. Art. 7(1)-(3)
  • From 18 August 2028 (or 24 months after the delegated act if later), document the share of recycled cobalt, lead, lithium and nickel in industrial batteries above 2 kWh, electric vehicle and SLI batteries, and meet minimum shares of 16 % cobalt, 85 % lead, 6 % lithium and 6 % nickel from 18 August 2031, rising to 26 %, 85 %, 12 % and 15 % from 18 August 2036. Art. 8(1)-(3)
  • From 18 August 2025 mark every battery with the separate collection symbol (and Cd or Pb where cadmium exceeds 0,002 % or lead 0,004 %); from 18 August 2026, or 18 months after the implementing act if later, add the general information and capacity labels; from 18 February 2027 add a QR code linking to the battery passport or to the conformity and waste information. Art. 13(1)-(6)
  • From 18 February 2027 give each LMT battery, industrial battery above 2 kWh and electric vehicle battery placed on the market a battery passport with the Annex XIII information, keep it accurate and up to date, and upload its unique identifier to the digital product passport registry. Art. 77(1), (3)-(4), (10)
  • If you place products with portable batteries on the market, from 18 February 2027 design them so that the battery is readily removable and replaceable by the end user with commercially available tools, and never use software to block its replacement; LMT batteries must be replaceable by an independent professional. Art. 11(1), Art. 11(5) and Art. 96(2)
  • From 18 February 2027, publish online the instructions for removing and replacing the portable batteries in the products you place on the market. Art. 11(1)
  • From 18 February 2027, keep the portable battery of a product available as a spare part for five years after the last unit of the product model was placed on the market. Art. 11(7)
  • If you consider or have reason to believe that a battery you placed on the market is not in conformity, immediately take the corrective measures to bring it into conformity, withdraw or recall it, and where it presents a risk inform the market surveillance authorities of the Member States where you made it available. Art. 38(9)
  • On a reasoned request from a competent national authority, provide all the information and documentation needed to demonstrate the conformity of the battery, in a language that authority can easily understand, and cooperate with it on any action to eliminate the risks posed by batteries you placed on the market. Art. 38(10)
  • From 18 August 2027, if your net turnover was EUR 40 million or more (alone or as part of a group), set up and implement a battery due diligence policy for cobalt, natural graphite, lithium and nickel, with the management system, risk management and disclosure the regulation requires. Art. 47, Art. 48(1), Art. 49 and Art. 50
  • Have your battery due diligence policy verified by a notified body and periodically audited by that body. Art. 48(2)
  • Review your battery due diligence policy every year and make a report on it publicly available, including on the internet. Art. 52(3)
  • Keep the documentation showing that you meet the due diligence obligations, including the verification report, the approval decision and the audit reports, for 10 years after the last battery manufactured under the policy was placed on the market. Art. 48(3)
Importer14
  • Only place batteries on the market that comply with Art. 6 to 10, 12, 13 and 14, and first verify that the manufacturer has drawn up the EU declaration of conformity and technical documentation, carried out the conformity assessment, affixed the CE marking and labels, supplied the required documents and instructions and put its name and address on the battery. Art. 41(1)-(2)
  • Put your own name or trademark, postal address and a single contact point on the battery, its packaging or an accompanying document. Art. 41(3)
  • While a battery is under your responsibility, keep its storage and transport conditions from jeopardising its compliance. Art. 41(4)
  • Where the risks presented by a battery warrant it, sample-test marketed batteries, investigate complaints and keep a register of complaints, non-conforming batteries and recalls, and keep distributors informed. Art. 41(5)
  • Where a battery you placed on the market is not in conformity, take the corrective measures to bring it into conformity, withdraw it or recall it, and immediately inform the market surveillance authorities of the Member States where you made it available where it presents a risk. Art. 41(6)
  • Keep a copy of the EU declaration of conformity at the disposal of the market surveillance authorities for 10 years after the battery was placed on the market, and ensure the technical documentation can be made available to them on request. Art. 41(7)
  • Provide a competent national authority, on reasoned request, with all the information and documentation needed to demonstrate the battery's conformity, in a language the authority can easily understand, and cooperate on corrective action. Art. 41(8)
  • If you sell under your own name or trademark, or modify a battery or its purpose, you take on the full manufacturer obligations of Art. 38. Art. 44
  • As the economic operator placing an LMT battery, industrial battery above 2 kWh or electric vehicle battery on the market, from 18 February 2027 attribute the unique identifier behind its QR code and keep its battery passport accurate, complete and up to date. Art. 77(3)-(4)
  • From 18 August 2027, if your net turnover reached EUR 40 million (alone or as part of a group), meet the battery due diligence obligations as the operator placing the batteries on the market. Art. 47, Art. 48(1)
  • If you are established in a Member State and supply batteries from a third country for the first time in that Member State on a professional basis, or sell by distance contract directly to end users in a Member State where you are not established, you are the producer of those batteries there. Art. 3(1)(47)(c)-(d)
  • As producer, register in the register of producers of that Member State before you first make the batteries available there. Art. 55(2)
  • As producer, carry extended producer responsibility for the batteries you make available in that Member State. Art. 56(1)
  • Be able to identify, for 10 years, every economic operator that supplied you with a battery and every operator you supplied, with quantities and models. Art. 46
Distributor8
  • Before making a battery available, verify that the producer is registered in the register of producers, that the battery bears the CE marking and the Art. 13 labels, that the required documents and instructions accompany it and that the manufacturer and importer have put their identification on it. Art. 42(1)-(2)
  • Do not make available a battery you consider or have reason to believe is not in conformity until it has been brought into conformity, and where it presents a risk inform the manufacturer or importer and the market surveillance authorities. Art. 42(3)
  • While a battery is under your responsibility, keep its storage and transport conditions from jeopardising its compliance. Art. 42(4)
  • If a battery you made available is not in conformity, make sure the corrective measures to bring it into conformity, withdraw or recall it are taken, and where it presents a risk immediately inform the market surveillance authorities of the Member States where you made it available. Art. 42(5)
  • Take back waste batteries of the categories you sell from end users free of charge and without any purchase obligation, at or near the retail outlet, and hand them over to the responsible producer, producer responsibility organisation or selected waste management operator. Art. 62(1)-(3)
  • If you sell by distance contract, provide enough collection points across the Member State; if you deliver, offer to take back waste batteries free of charge at the point of delivery or a local collection point and tell the end user so when they buy. Art. 62(4)-(5)
  • Display the producers' end-user information on prevention, separate collection, safety and label meanings permanently in the shop and online, and show the extended producer responsibility costs separately at the point of sale. Art. 74(4)-(5)
  • Be able to identify, for 10 years, every economic operator that supplied you with a battery and every operator you supplied, with quantities and models. Art. 46
Fulfilment service provider3
  • Make sure that warehousing, packaging, addressing and dispatching do not jeopardise the batteries' compliance with Art. 6 to 10, 12, 13 and 14. Art. 43
  • Cooperate with national authorities on any action to eliminate risks from the batteries you handle and inform the market surveillance authorities immediately where a battery presents a risk. Art. 43, Art. 40(3)(c), Art. 40(4)
  • Be able to identify, for 10 years, every economic operator that supplied you with a battery and every operator you supplied. Art. 46
Online platform1
  • Before a producer may offer batteries to consumers on your platform, obtain its register-of-producers details and registration number and a self-certification that it only offers batteries meeting the extended producer responsibility requirements of Art. 56 to 58; where a national register of producers is not public, the Member State must grant you free access to it for this check. Art. 62(6), Art. 55(13)
Producer (extended producer responsibility)8
  • Register in the register of producers of every Member State where you first make batteries available, including batteries built into appliances or vehicles, before selling there; the authority issues a registration number within 12 weeks of a complete application. Art. 55(2)-(3), (9)
  • Carry extended producer responsibility from 18 August 2025 and finance separate collection, transport and treatment, the compositional survey, end-user information and data reporting for the batteries you make available. Art. 56(1), (4), Art. 96(2)
  • If you sell by distance contract into a Member State from another country, appoint an authorised representative for extended producer responsibility there by written mandate. Art. 56(3)
  • Obtain an authorisation from the competent authority, either individually or through an authorised producer responsibility organisation, and provide a guarantee covering the waste management costs. Art. 57(1), Art. 58(1)-(2), (7)
  • For portable batteries, run a nationwide take-back and collection system and reach collection rates of 45 % by 31 December 2023, 63 % by 31 December 2027 and 73 % by 31 December 2030; for LMT batteries, 51 % by 31 December 2028 and 61 % by 31 December 2031. Art. 59(1)-(3), Art. 60(1)-(3)
  • For SLI, industrial and electric vehicle batteries, take back all waste batteries free of charge from distributors, remanufacturers, treatment facilities and public collection points and deliver them to permitted facilities for treatment. Art. 61(1), (3)
  • Inform end users and distributors about waste prevention, separate collection, take-back points, safety and label meanings, give waste operators free dismantling and safety information, and run awareness campaigns. Art. 74(1)-(3), (6)
  • Report to the competent authority each calendar year, within six months of year end, the amounts placed on the market, collected, treated, exported and prepared for re-use, and the collection rate reached. Art. 75(1)-(2), (7)
Re-use, repurposing or remanufacturing operator5
  • An economic operator that places on the market a battery prepared for re-use, repurposed or remanufactured is treated as its manufacturer and carries the manufacturer obligations. Art. 38(11)
  • Carry out an additional Module A conformity assessment for the prepared-for-re-use, repurposed or remanufactured battery before placing it on the market. Art. 17(3)
  • Apply new labels to the battery that show its change of status. Art. 13(9)
  • Carry out the examination, performance testing, packing and shipment of the battery and of its components following adequate quality control and safety instructions. Art. 45(1)
  • The same operator becomes the producer of that battery for extended producer responsibility and takes over responsibility for the battery passport; the carbon footprint and recycled content requirements do not apply to a battery that had already been placed on the market or put into service before the operation, and the performance and durability requirements do not apply where the operator demonstrates that the battery was placed on the market or put into service before the dates on which those requirements became applicable. Art. 56(2), Art. 77(7), Art. 7(5), Art. 8(4), Art. 10(4)

BattR in plain terms

The Batteries Regulation lays down the requirements a battery must meet before it can be placed on the market or put into service in the Union: sustainability, safety, labelling, marking and information (Art. 1(1)). It also sets minimum rules for extended producer responsibility, the collection and treatment of waste batteries and reporting, imposes battery due diligence obligations on the operators that place batteries on the market and adds green public procurement rules (Art. 1(2)). Because it is a regulation, it applies directly in every Member State; the old Batteries Directive 2006/66/EC is repealed with effect from 18 August 2025 (Art. 95).

What makes it different from the directive it replaces is that most of the duties now sit at the design and sourcing stage rather than at disposal. A carbon footprint declaration, minimum recycled content, performance and durability values, removable and replaceable batteries, a QR code and a digital battery passport, and third-party-verified due diligence on cobalt, natural graphite, lithium and nickel all phase in on dates spread from 2024 to 2036 (Art. 7 to 11, 13, 48, 77, 96). The dates differ by battery category and several are tied to Commission delegated or implementing acts, so the applicable date for a given battery is the later of the date in the text and the period after the act.

Official text: Regulation (EU) 2023/1542 concerning batteries and waste batteries, consolidated text on EUR-Lex

Scope

The Regulation applies to all categories of batteries, namely portable batteries, SLI batteries, LMT batteries, electric vehicle batteries and industrial batteries, regardless of shape, volume, weight, design, material composition, chemistry, use or purpose, and to batteries incorporated into or added to products or designed to be (Art. 1(3)). A battery that fits more than one category is treated as belonging to the one with the strictest requirements, and cells or modules sold for end use count as batteries of the most similar category (Art. 1(3) to (4)). The exclusions are batteries built into equipment for Member States’ essential security interests, arms, munitions and war material intended specifically for military purposes, and equipment designed to be sent into space (Art. 1(5)); in addition, Chapters III (labelling, marking and information) and IX (market surveillance) do not apply to equipment specifically designed for the safety of nuclear installations (Art. 1(6)).

The categories are defined by weight and purpose: a portable battery is sealed and weighs 5 kg or less; an LMT battery is sealed, weighs 25 kg or less and powers wheeled vehicles such as e-bikes; an industrial battery is designed for industrial use or is any other battery above 5 kg; an electric vehicle battery powers traction in category L vehicles above 25 kg or in M, N and O vehicles; an SLI battery supplies starting, lighting or ignition power (Art. 3(1)(9) to (14)).

Duties follow the role, and one company often holds several. A manufacturer markets a battery under its own name (Art. 3(1)(33)); an importer places a third-country battery on the Union market (Art. 3(1)(64)); a distributor makes it available further down the chain (Art. 3(1)(65)); an importer or distributor that sells under its own brand or modifies a battery becomes the manufacturer (Art. 44). Separately, whoever first makes a battery available in a Member State, including by distance selling from abroad and including batteries built into appliances or vehicles, is its producer for extended producer responsibility (Art. 3(1)(47)). Operators that prepare batteries for re-use, repurpose or remanufacture them are treated as manufacturers and producers of the resulting battery (Art. 38(11), Art. 56(2)). Chapter VII on due diligence applies only to operators with a net turnover of EUR 40 million or more, alone or as part of a group (Art. 47).

What you must do

Substances, carbon footprint and recycled content

Batteries may not contain mercury above 0,0005 %, portable batteries may not contain cadmium above 0,002 %, and from 18 August 2024 portable batteries may not contain lead above 0,01 %, with zinc-air button cells exempt until 18 August 2028 (Art. 6(1), Annex I). Regulation (EU) 2026/1738 replaced the Annex I table from 13 August 2026, adding conditions for batteries incorporated in M1 and N1 vehicles (2026/1738, Art. 53 and Annex XII). Electric vehicle batteries, rechargeable industrial batteries above 2 kWh and LMT batteries need a carbon footprint declaration per model and manufacturing plant, staged by category from 18 February 2025, 18 February 2026 and 18 August 2028 or 12 to 18 months after the Commission’s methodology and format acts if later; performance classes and maximum thresholds follow (Art. 7). Recycled content documentation for cobalt, lead, lithium and nickel starts on 18 August 2028 or 24 months after the delegated act, with minimum shares from 18 August 2031 and higher shares from 18 August 2036 (Art. 8).

Performance, safety and state of health

From 18 August 2024, rechargeable industrial batteries above 2 kWh, LMT and electric vehicle batteries must be accompanied by a document with the Annex IV performance and durability values, and minimum values follow by delegated act (Art. 10). Portable batteries of general use, button cells excluded, must meet minimum electrochemical performance from 18 August 2028 or 24 months after the delegated act (Art. 9). Stationary battery energy storage systems must be safe in normal use and, by 18 August 2024, documented and tested against the Annex V safety parameters (Art. 12). Stationary storage, LMT and electric vehicle batteries must hold up-to-date state-of-health data in the battery management system with read-only access for the owner, independent operators and waste operators (Art. 14).

Removability and replaceability

From 18 February 2027, anyone placing products with portable batteries on the market must make the battery readily removable and replaceable by the end user with commercially available tools, publish removal and safety instructions online, keep the battery available as a spare part for at least five years after the last unit of the model, and may not use software to block replacement; LMT batteries and their cells must be replaceable by an independent professional (Art. 11, Art. 96(2)). Derogations exist for appliances designed for wet environments and for professional medical imaging, radiotherapy and in vitro diagnostic devices, and where a permanent connection is needed for safety or data integrity (Art. 11(2) to (3)).

Labelling, QR code and the battery passport

From 18 August 2025 all batteries carry the separate collection symbol, with Cd or Pb printed beneath it where cadmium exceeds 0,002 % or lead 0,004 % (Art. 13(4) to (5)). From 18 August 2026, or 18 months after the implementing act if later, batteries carry the general information label, rechargeable portable, LMT and SLI batteries a capacity label and non-rechargeable portable batteries a duration label (Art. 13(1) to (3)). From 18 February 2027 every battery carries a QR code (Art. 13(6)), and each LMT battery, industrial battery above 2 kWh and electric vehicle battery placed on the market has a battery passport with the Annex XIII information, kept accurate by the operator placing it on the market, whose unique identifier is uploaded to the digital product passport registry (Art. 77).

Conformity assessment, documentation and operator duties

Manufacturers draw up the Annex VIII technical documentation, run the Art. 17 conformity assessment (Module A, D1 or G, with a notified body for carbon footprint and recycled content), sign the EU declaration of conformity, affix the CE marking, identify the battery and themselves on it, keep the records for 10 years and take corrective action when something is wrong (Art. 17 to 20, Art. 38). Importers verify all of this before placing a battery on the market and add their own name and address (Art. 41); distributors check registration, marking and documents before selling (Art. 42); fulfilment service providers keep handling from jeopardising compliance (Art. 43); and every operator can identify its suppliers and customers for 10 years (Art. 46). These chapters apply from 18 August 2024, except Art. 17(2) on the conformity assessment of the carbon footprint and recycled content requirements, which applies 12 months after the first publication of the list of notified bodies (Art. 96(2)(b), Art. 30(2)).

Battery due diligence

From 18 August 2027, economic operators placing batteries on the market with a net turnover of EUR 40 million or more must adopt and publish a battery due diligence policy on cobalt, natural graphite, lithium and nickel, run a management system with chain-of-custody documentation and a grievance mechanism, identify and manage supply chain risks, have the policy verified and periodically audited by a notified body, publish an annual report and keep records for 10 years (Art. 47 to 52, as amended by Regulation (EU) 2025/1561). Recognised due diligence schemes can support compliance (Art. 53).

Producer registration, take-back and collection

From 18 August 2025, producers register in every Member State where they first make batteries available, obtain an authorisation individually or through a producer responsibility organisation, provide a guarantee and finance collection, treatment, information and reporting (Art. 55 to 58, Art. 96(2)). Producers of portable batteries must reach collection rates of 45 % by end 2023, 63 % by end 2027 and 73 % by end 2030, producers of LMT batteries 51 % by end 2028 and 61 % by end 2031, and producers of SLI, industrial and electric vehicle batteries must take back all waste batteries free of charge (Art. 59 to 61). Distributors take back waste batteries of the categories they sell at or near the shop, or at the point of delivery for distance sales (Art. 62). Collected waste batteries may not be disposed of or used for energy recovery and must be treated in permitted facilities meeting the Annex XII recycling efficiency and material recovery targets (Art. 70 to 71). End users must discard batteries separately (Art. 64), and producers report volumes, collection rates and treatment data to the competent authority every year (Art. 75).

Enforcement and penalties

Each Member State designates the competent authorities that monitor producers and producer responsibility organisations and run the register of producers (Art. 54), while market surveillance authorities handle the product rules. Where a battery presents a risk or is non-compliant, they require corrective action, may prohibit or restrict it on their market and ensure withdrawal or recall, with a Union safeguard procedure when Member States disagree (Art. 79 to 81). Formal failures such as a missing CE marking, declaration of conformity, technical documentation or contact details must be corrected, or the battery is restricted, withdrawn or recalled (Art. 83), and persistent breaches of the due diligence duties can lead to an operator’s batteries being restricted or prohibited (Art. 84). Penalties themselves are national: Member States had to adopt effective, proportionate and dissuasive rules by 18 August 2025 and notify them to the Commission (Art. 93).

How Conphora helps

Conphora monitors BattR and maps your batteries against its requirements, flagging gaps in carbon-footprint, recycled content, labelling, the QR code, the battery passport, due diligence and EPR before they become enforcement problems. The platform helps you generate and keep the right documentation, and alerts you as the Regulation’s phased obligations take effect so your compliance stays current.

See how Conphora works · See plans and pricing

Sources

This guide is for general information and is not legal advice.

Penalties

Member States had to lay down effective, proportionate and dissuasive penalties for infringements by 18 August 2025 and notify them to the Commission; the amounts are set nationally. Alongside penalties, market surveillance authorities must require corrective action for any non-compliant battery, may prohibit or restrict it on their market and must ensure withdrawal or recall, formal failures such as a missing CE marking, declaration of conformity or technical documentation must be corrected or the battery restricted, and persistent breaches of the due diligence duties can lead to the operator's batteries being restricted or prohibited.

Source · Art. 93, Art. 79, Art. 83, Art. 84

What changed

Entry into force, amendments and Compliance Radar entries for BattR, newest first.

  1. Amendment

    Annex I substance restrictions replaced by Regulation (EU) 2026/1738

    The end-of-life vehicles Regulation replaces the Annex I table, carrying over the existing mercury, cadmium and lead limits (including the 0,01 % lead limit for portable batteries and the zinc-air button cell exemption to 18 August 2028) and adding new limits on cadmium, lead and hexavalent chromium for batteries incorporated in M1 and N1 vehicles.

    Source · Art. 53, Art. 59(2), Annex XII
  2. Applies

    Waste management chapter applies; Batteries Directive repealed

    Producer registration, extended producer responsibility, collection, treatment and reporting (Chapter VIII) apply, Directive 2006/66/EC is repealed with transitional provisions, all batteries must bear the separate collection symbol and Member States' penalty rules are due.

    Source · Art. 96(2), Art. 95, Art. 13(4), Art. 93
  3. Amendment

    Due diligence postponed by Regulation (EU) 2025/1561

    The battery due diligence obligations in Art. 48(1) now apply from 18 August 2027 instead of 18 August 2025, and the Commission's guidelines are due by 26 July 2026.

    Source · Art. 1, Art. 2
  4. Guidance

    Delegated Regulation (EU) 2025/606 on recycling efficiency in force

    The Commission's methodology for calculating and verifying recycling efficiency and material recovery rates, and the documentation format, supplement Art. 71(4).

    Source · Art. 2
  5. Applies

    Economic operator obligations and conformity assessment apply

    The duties of manufacturers, importers, distributors and fulfilment service providers (Chapter VI) and the conformity assessment procedures (Art. 17) apply, except Art. 17(2) on the conformity assessment of the carbon footprint and recycled content requirements (Art. 7 and 8), which applies 12 months after the first publication of the list of notified bodies; the performance document, state-of-health data, stationary storage safety documentation and the lead limit for portable batteries apply on the same date.

    Source · Art. 96(2)(b), Art. 17(2), Art. 30(2), Art. 10(1), Art. 12(2), Art. 14(1), Annex I
  6. Amendment

    Regulation (EU) 2024/1781 adds the passport registry duty

    The Ecodesign for Sustainable Products Regulation adds Art. 77(10): the unique identifier of each battery passport must be uploaded to the digital product passport registry.

    Source · Art. 78, Art. 80
  7. Applies

    The Batteries Regulation applies

    General date of application, save for the provisions with later dates.

    Source · Art. 96(2)
  8. In force

    Entry into force

    Regulation (EU) 2023/1542 entered into force on the twentieth day after its publication in the Official Journal on 28 July 2023.

    Source · Art. 96(1)

Tools and training

What Conphora offers for BattR.

Start from the problem

A new regulation applies and nobody knows what changes

GPSR, the Battery Regulation and the DPP each affect different parts of your catalogue.

Regulation guides → Compliance Radar → Product validation

A marketplace asks for battery information on the listing

Marketplaces ask sellers of batteries and battery-powered products for a producer registration number. What the Battery Regulation requires and why.

Regulation guides → Product validation

Our product contains a battery and we sell it as before

The Battery Regulation (EU) 2023/1542 covers batteries built into products: the CE-marked battery, producer registration and removability from 2027.

Regulation guides → Product validation

We heard batteries must be removable by the user

Battery Regulation Article 11: from 18 February 2027 portable batteries in products must be removable and replaceable by the end-user. The exceptions.

Regulation guides → Compliance Radar

A customer asks about the battery passport

Which batteries need a battery passport from 18 February 2027, what it contains, who keeps it accurate, and what other batteries need behind their QR code.

Regulation guides → Compliance Radar

We are asked about battery due diligence

Battery due diligence under Regulation (EU) 2023/1542: who is in scope, the 18 August 2027 start, the raw materials covered and what to tell a customer.

Regulation guides → Knowledge & insights

All problems for BattR →

Questions people ask about BattR

Does the Batteries Regulation apply to batteries built into my product?

Yes. The Regulation applies to all battery categories regardless of shape, weight, chemistry or use, and expressly to batteries incorporated into or added to products. From 18 February 2027 anyone placing a product with a portable battery on the market must also make the battery readily removable and replaceable by the end user, with LMT batteries replaceable by an independent professional.

Source · Art. 1(3), Art. 11, Art. 96(2)
When did the Batteries Regulation start to apply?

It entered into force on 17 August 2023 and applies from 18 February 2024. The obligations of manufacturers, importers, distributors and fulfilment service providers and the conformity assessment rules apply from 18 August 2024, except Art. 17(2) on the conformity assessment of the carbon footprint and recycled content requirements, which applies 12 months after the first publication of the list of notified bodies; the waste management and producer responsibility chapter applies from 18 August 2025, and the removability rules from 18 February 2027.

Source · Art. 96, Art. 17(2), Art. 30(2)
What is the difference between a portable and an industrial battery?

A portable battery is sealed, weighs 5 kg or less, is not designed specifically for industrial use and is not an electric vehicle, LMT or SLI battery. An industrial battery is designed for industrial use, or is any other battery above 5 kg that is not an electric vehicle, LMT or SLI battery. Where a battery could fall under more than one category, the category with the strictest requirements applies.

Source · Art. 3(1)(9), (13), Art. 1(3)
Which batteries need a battery passport, and from when?

From 18 February 2027 each LMT battery, each industrial battery with a capacity above 2 kWh and each electric vehicle battery placed on the market must have an electronic battery passport, reached through the QR code on the battery. The economic operator placing the battery on the market keeps the passport accurate and up to date and uploads its unique identifier to the digital product passport registry.

Source · Art. 77(1), (3)-(4), (10), Art. 13(6)
Who must carry out battery due diligence, and when?

Economic operators placing batteries on the market must set up and implement a verified battery due diligence policy from 18 August 2027, after Regulation (EU) 2025/1561 postponed the original date of 18 August 2025 by two years. The chapter does not apply to operators with a net turnover below EUR 40 million that are not part of a group above that limit, nor to batteries that were already on the market before being prepared for re-use, repurposed or remanufactured.

Source · Art. 47, Art. 48(1)Source · Art. 1(a)
What recycled content must batteries contain?

From 18 August 2028, or 24 months after the Commission's methodology if later, industrial batteries above 2 kWh, electric vehicle and SLI batteries containing cobalt, lead, lithium or nickel must document their recycled share. From 18 August 2031 the active materials must contain at least 16 % recycled cobalt, 85 % lead, 6 % lithium and 6 % nickel, rising to 26 %, 85 %, 12 % and 15 % from 18 August 2036, when LMT batteries are included as well.

Source · Art. 8(1)-(3)
What must a shop do with waste batteries?

Distributors must take back waste batteries of the categories they sell from end users free of charge, without requiring a purchase, at or near the retail outlet, and hand them over to the responsible producer, producer responsibility organisation or selected waste operator. Distance sellers must provide collection points across the Member State, and deliveries must come with a free take-back offer at the point of delivery.

Source · Art. 62(1)-(5)
Is the old Batteries Directive still in force?

No. Directive 2006/66/EC was repealed with effect from 18 August 2025. A few of its provisions continue for a transition: Article 11 on removal of waste batteries until 18 February 2027, Article 12(4) and (5) on recycling efficiency reporting until 31 December 2025 (except the provision on transmission of data to the Commission, which continues until 30 June 2027), and Article 21(2) on labelling until 18 August 2026.

Source · Art. 95

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Related

Related regulations

ELVDEUDRONDPPWDPVDWEEE

Sources

  1. Regulation (EU) 2023/1542 concerning batteries and waste batteries, consolidated text of 31 July 2025 (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1542-20250731
  2. Regulation (EU) 2023/1542, original text as published in OJ L 191 of 28 July 2023 (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1542
  3. Regulation (EU) 2024/1781 on ecodesign for sustainable products, amending Art. 77 (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R1781
  4. Commission Delegated Regulation (EU) 2025/606 on recycling efficiency and material recovery rates (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0606
  5. Regulation (EU) 2025/1561 postponing the battery due diligence obligations (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R1561
  6. Regulation (EU) 2026/1738 on end-of-life vehicles, amending Annex I (EUR-Lex) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026R1738
  7. Batteries: the European Commission's page on the Batteries Regulation https://environment.ec.europa.eu/topics/waste-and-recycling/batteries_en

About this guide

Reviewed by
Conphora compliance team, Compliance editors, Conphora
Reviewed
24 September 2026
Next review
18 February 2027

Written from the official text on EUR-Lex and the Commission’s guidance, with a source for every fact. It is not legal advice.

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Cite this page 
Conphora (2026). BattR: EU Batteries Regulation (Regulation (EU) 2023/1542), explained. Retrieved 13 October 2026 from https://www.conphora.com/regulations/battr/
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