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. First declaration, then classes A–G, later maximum thresholds.
- 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, mandatory carbon footprint declarations, 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
EV makers must declare a Product Carbon Footprint — kg CO₂-eq per kWh over the life cycle.
Supply-chain due diligence
Companies with revenue above € 40m must audit their supply chain for cobalt, lithium, nickel and natural graphite.
Digital battery passport becomes mandatory
For LMT, industrial (> 2 kWh) and EV batteries — every battery needs a QR code with publicly accessible data.
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 to carbon footprint.
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, carbon footprint, safety and recycling instructions.
Repair shops & recyclers
Disassembly instructions, material composition, diagnostic interfaces.
Authorities
Full supply-chain data, evidence on conflict minerals.
Your CO₂ footprint becomes measurable
Manufacturers must declare per model how much CO₂ a battery causes over its life cycle — from the mine to the factory gate.
Classes A – G
Similar to the energy label on a fridge. Later come maximum thresholds — batteries above the limit may no longer be sold in the EU.
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 August 2025 manufacturers with revenue above € 40m need a documented due-diligence policy following the OECD guidance — for cobalt, lithium, nickel and natural graphite.
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
- 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.