The EU Battery Regulation - finally clear
What the new regulation actually demands from manufacturers, importers and distributors - without the legal jungle. In 10 minutes you'll know what's coming, and when.
- One regulation instead of 27 laws. It applies directly - no national transposition needed.
- Every battery gets a digital passport. QR code on it, public data accessible - from February 2027.
- Carbon footprint becomes measurable, but not yet. First declaration, then classes A to G, later maximum thresholds - the starting signal is the delegated act that has not been adopted yet.
- Recycled content becomes mandatory. From 2031 cobalt, lithium and nickel must contain minimum recycled shares.
What is it about?
Regulation (EU) 2023/1542 on batteries and waste batteries replaces the old Battery Directive. It applies to every battery placed on the EU market since August 2023 - from button-cell hearing aids to 3 MWh industrial storage.
Goal: make batteries more sustainable across the whole life cycle - from raw-material extraction through manufacturing to recycling. To get there the regulation introduces three new tools: the digital battery passport, carbon footprint declarations (mandatory only 12 months after the delegated act on the calculation enters into force; that act is still pending), and supply-chain due diligence.
Key dates at a glance
Obligations are phased in over time, not all at once. Companies that start documenting early will find 2027 considerably easier.
Regulation enters into force
The old Directive 2006/66/EC is replaced. Transition periods start running.
Core obligations apply
Labelling, end-user information, registration duties - most general requirements take effect.
Carbon footprint for EV batteries - not yet applicable
Article 7 names this date for the Product Carbon Footprint of EV batteries, but adds "or 12 months after entry into force of the delegated act, whichever is later". That act has still not been adopted, so there is no date for the carbon footprint declaration in any category.
Digital battery passport becomes mandatory
For LMT, industrial (> 2 kWh) and EV batteries - every battery needs a QR code with publicly accessible data.
Supply-chain due diligence
Companies with net turnover above € 40m need a due-diligence policy for cobalt, lithium, nickel and natural graphite. Originally planned for August 2025, postponed by Regulation (EU) 2025/1561.
Minimum recycled content
New industrial, EV and SLI batteries must contain minimum shares of recycled materials - even stricter in 2036.
Which batteries are affected?
The regulation explicitly distinguishes five categories. Whether you need a passport depends on which bucket your battery falls into.
The digital battery passport
QR code on every battery - data in the cloud
From February 2027 every affected battery carries a QR code. Scanning it opens a public web page with all legally required information - from manufacturer and chemistry to performance and durability. The yardstick is the European Commission's official list of 71 data points (Version 2.0, 15 August 2026); it marks carbon footprint and recycled content as "not to be filled" in February 2027.
The passport must remain accessible for at least 10 years after the last sale - even if the manufacturer goes bankrupt. That requires a technical infrastructure with interoperable standards (Catena-X, AAS).
- Publicly accessible via QR scan
- 10 years minimum availability
- Three access levels depending on role
For everyone
Manufacturer, model, capacity, chemistry, safety and recycling instructions; the carbon footprint once it applies.
Repair shops & recyclers
Disassembly instructions, material composition, diagnostic interfaces.
Authorities
Full supply-chain data, evidence on conflict minerals.
Which documents carry these levels - and why only three of them sit in the passport itself - is explained in what evidence the battery passport requires.
Your CO₂ footprint becomes measurable
Manufacturers will have to declare per model how much CO₂ a battery causes over its life cycle - from the mine to the factory gate. Today this applies to no category: the delegated act on the calculation has not been adopted, and the Commission lists the field in the battery passport for February 2027 as "not to be filled".
Classes A – G
Similar to the energy label on a fridge - but only after the declaration, through a separate delegated act. After that come maximum thresholds - batteries above the limit may no longer be sold in the EU.
The base dates of these three stages, the "whichever is the later" clause and the calculation in kg CO2e per kWh are set out in Battery carbon footprint.
Reused instead of newly mined
From 2031 new industrial, EV and SLI batteries must contain minimum shares of recycled raw materials. In 2036 the values rise again.
Supply-chain due diligence
From 18 August 2027 manufacturers with net turnover above € 40m need a documented due-diligence policy following the OECD guidance - for cobalt, lithium, nickel and natural graphite.
Originally 18 August 2025 was planned; Regulation (EU) 2025/1561 moved the date of application to 18 August 2027. In the battery passport the Commission requires the public due diligence report from August 2027. Scope, Annex X and the link to the battery passport are covered in Battery supply chain due diligence.
Collection & recycling targets rise
The EU raises collection targets step by step - measured against the weight of batteries sold per year.
What happens in case of breaches?
Fines reach six-figure amounts
The regulation requires "effective, proportionate and dissuasive" penalties. In Germany the Batterierecht-Durchführungsgesetz (BattDG) sets the actual amounts - per breach, six-figure Euro fines are possible.
- Missing or incomplete battery passport after February 2027
- Incorrect or missing carbon footprint declaration, once this duty applies
- Missing registration in the national producer register
Sources & further reading
Specific questions about your obligation?
Our compliance team replies within 24 hours on business days - from passport specification to supplier audits.