Dates
| Date | What | Legal basis |
|---|---|---|
| 18 Feb 2024 | Substance restrictions (mercury, cadmium, lead; Annex I, replaced by Regulation (EU) 2026/1738 from 13 Aug 2026)Art. 6; Art. 96(2) | Art. 6; Art. 96(2) |
| 18 Aug 2024 | Performance and durability document for rechargeable industrial batteries above 2 kWh, LMT and EV batteriesArt. 10(1) | Art. 10(1) |
| 18 Aug 2024 | Conformity assessment, EU declaration of conformity and CE markingArts 17–20, Art. 38(3) and Art. 96(2)(b) | Arts 17–20, Art. 38(3) and Art. 96(2)(b) |
| 18 Aug 2024 | Safety of stationary battery energy storage systems and state-of-health data in the battery management systemArt. 12(2); Art. 14(1) | Art. 12(2); Art. 14(1) |
| 18 Aug 2025 | Extended producer responsibility and registration in the producer registerArts. 55–56 | Arts. 55–56 |
| 18 Aug 2025 | Separate collection symbol on all batteries and waste battery informationArt. 13(4); Art. 74 | Art. 13(4); Art. 74 |
| 18 Aug 2026 or later | Labelling with general information (Annex VI Part A), capacity and, for non-rechargeable portable batteries, minimum average duration. Applies from 18 Aug 2026 or 18 months after the Commission implementing act on labelling, whichever is later (the act has not been adopted).Art. 13(1)–(3) and (10) | Art. 13(1)–(3) and (10) |
| 18 Feb 2027 | Battery passport for LMT, industrial above 2 kWh and EV batteriesArt. 77(1) | Art. 77(1) |
| 18 Feb 2027 | QR code on all batteriesArt. 13(6) | Art. 13(6) |
| 18 Feb 2027 | Portable and LMT batteries in products must be removable and replaceable (the duty lies with whoever places the product on the market)Art. 11; Art. 96(2)(a) | Art. 11; Art. 96(2)(a) |
| 18 Aug 2027 | Battery due diligence policy (postponed by Regulation (EU) 2025/1561; does not apply to economic operators with net turnover below EUR 40 million, Art. 47)Arts 47–53; Art. 48(1) | Arts 47–53; Art. 48(1) |
| Pending Commission acts | Carbon footprint declaration for EV batteries (18 Feb 2025 or 12 months after the Commission acts; not yet adopted)Art. 7(1) | Art. 7(1) |
Some dates depend on Commission acts and may move later. The carbon footprint declaration (Art. 7(1)) applies from a fixed date or 12–18 months after the delegated act on the method or the implementing act on the format enters into force, whichever is the latest. Recycled content documentation (Art. 8(1)) applies from 18 Aug 2028 or 24 months after the delegated act, whichever is the latest. Labelling under Art. 13(1)–(3) awaits an implementing act.
Who is affected
The economic operator placing the battery on the market is responsible for the battery passport and for keeping its information accurate and up to date (Art. 77).
Which documents are required
- The battery passport contains information on both the battery model and the individual battery. It must be accessible through the QR code linking to a unique identifier assigned by the economic operator placing the battery on the market (Art. 77(2) and (3)). The QR code and identifier must comply with ISO/IEC 15459-1 to -6 or equivalent. In the system we combine the GTIN and the serial number (GS1 Digital Link).
- From 18 Feb 2027 all batteries must be marked with a QR code (Art. 13(6)). For batteries with a passport, the QR code gives access to the passport.
- The content is set out in Annex XIII. Point 1 is publicly accessible. Point 2 (including detailed composition, dismantling and safety) is accessible only to persons with a legitimate interest, notified bodies, market surveillance authorities and the Commission. Point 3 (test reports) is accessible only to notified bodies, market surveillance authorities and the Commission. Point 4 (data on the individual battery, such as state of health) is accessible only to persons with a legitimate interest (Art. 77(2)). Who has a legitimate interest is set by an implementing act (Art. 77(9)).
- The passport must remain available, including if the economic operator ceases to exist (Art. 78(e)). The unique identifier must be uploaded to the EU digital product passport registry (Art. 77(10)).
How we support it
- The battery module is live: fields under Annexes VI and XIII with access tiers, the EU declaration of conformity under Annex IX and the battery passport with QR code and access links per tier and per recipient. Each individual battery can be registered by serial number and gets its own passport with status, state of health and use data (Annex XIII point 4), and a repurposed or remanufactured battery can be linked to its new passport (Art. 77(7)). The access rules for point 4 await the Commission implementing act (Art. 77(9)). Reporting the passport's identifier to the EU registry for product passports (Art. 77(10)) is not automatic yet; you report it yourselves and can enter the registration number.
See what it means for your products
In a walkthrough we start from a few of your own products.
These pages are an overview, not legal advice. Always read the legal act in the Official Journal.