EU Batteries Regulation (EU) 2023/1542: deadlines and obligations by battery category

Status as of 22 October 2026: Regulation (EU) 2023/1542 as consolidated on 13 August 2026, and the acts listed below.

Most deadline lists print 18 February 2025 as the start of the EV carbon footprint declaration. The regulation actually sets 18 February 2025 or 12 months after the methodology or format act enters into force, whichever is the latest, and neither act exists yet. That gap between a printed date and an applicable date is what this guide tracks, with the article behind every line.

Which batteries are covered

Nearly every deadline is written per category, so classification comes first. Article 3 defines five categories; we quote only the criteria that move a date.

• Portable batteries. No passport. QR code, labels, collection targets and, for products that incorporate them, removability by the end user.
• LMT batteries (light means of transport). Defined by weight, not energy: "sealed, weighs 25 kg or less". No kWh threshold.
• SLI batteries (starter batteries). No passport, but grouped with EV and large industrial batteries for recycled content (Article 8).
• Industrial batteries. The only category where capacity decides the passport: above 2 kWh is in, 2 kWh or less is out. Stationary battery energy storage systems have their own rules, and batteries with exclusively external storage are carved out of several Article 7, 8 and 10 obligations.
• Electric vehicle batteries. Defined by traction use and, for L-category vehicles, a weight above 25 kg. No kWh threshold either.

Why dwell on 2 kWh? Because it is the most frequent misreading. In Article 77(1), "each" is repeated before every category and "with a capacity greater than 2 kWh" attaches only to "industrial battery". The German version reads the same way, and Article 13(6)(a) repeats the structure. A small LMT battery needs a passport; a 1.5 kWh industrial battery does not.

Deadlines at a glance

"Fixed" means the date is written in the regulation. "Floor" means the text gives a date or a period after an act enters into force, "whichever is the latest": without the act, the obligation is not yet applicable.

What applies on 18 February 2027

Three obligations land on the same day. They are often merged into "the passport deadline", which hides that two of them reach batteries that will never have a passport.

The battery passport (Article 77)

Each LMT battery, each industrial battery above 2 kWh and each EV battery "placed on the market or put into service" from that date must have an electronic record. The operator placing the battery on the market assigns the unique identifier (Article 77(3)), keeps the information "accurate, complete and up to date" and may authorise another operator in writing (Article 77(4)). Access is free of charge (Article 78(b)). The passport ceases to exist once the battery is recycled (Article 77(8)); a repurposed or remanufactured battery gets a new passport linked to the original (Article 77(7)).

Stock placed on the market before 18 February 2027? The text says nothing. A firm answer either way is an interpretation.

The DPP registry provided for in Article 13 of Regulation (EU) 2024/1781 also covers battery passport identifiers (Article 77(10) of Regulation 2023/1542). Its arrangements are set by Implementing Regulation (EU) 2026/1778, in force since 6 August 2026. Article 77(10) carries no date of its own; we read the upload duty as starting with the identifier on 18 February 2027, but that is our reading, not the text. Details in our EU battery passport guide.

The QR code on every battery (Article 13(6))

"From 18 February 2027, all batteries shall be marked with a QR code." Portable and SLI batteries included. For passport categories, the code leads to the passport. For the rest it opens the label information of Article 13(1) to (5), the EU declaration of conformity, the due diligence report and the waste information of Article 74(1)(a) to (f), plus recycled content for SLI batteries. It is printed or engraved on the battery, or placed on the packaging and accompanying documents if that is impossible (Article 13(7)).

Removability and replaceability (Article 11)

From 18 February 2027 (Article 96(2)(a)), portable batteries in products must be removable and replaceable by the end user, LMT batteries by an independent professional; spare parts must remain available for 5 years and software must not block replacement. Delegated Regulation (EU) 2026/1770, published in the Official Journal on 22 October 2026, replaces Article 11(2) and adds derogations (c) to (h), including electric toys until 31 July 2030. By our calculation it enters into force on 11 November 2026. The Commission notice C/2025/214 on Article 11 is interpretative only.

Battery passport data: the four access levels of Annex XIII

Three tiers is the usual picture. Article 77(2) actually produces four blocks: point 1 is public; points 2 and 3 are open to notified bodies, market surveillance authorities and the Commission; points 2 and 4 are open to persons with a legitimate interest.

1. Public, model level (point 1). Annex VI Part A data (manufacturer, category, place and date of manufacture, weight, capacity, chemistry), carbon footprint information, responsible sourcing from the due diligence report, rated capacity in Ah, expected lifetime in cycles, the EU declaration of conformity. EV batteries add the capacity threshold for exhaustion.
2. Model level, legitimate interest and Commission (point 2), plus notified bodies and market surveillance authorities through Article 77(2)(b). Detailed composition (cathode, anode, electrolyte), part numbers and spare sources, dismantling information such as exploded diagrams and disassembly sequences, safety measures.
3. Authorities only (point 3). Test reports proving compliance.
4. Individual battery, legitimate interest only (point 4). Article 10(1) performance values at placing on the market and on status changes, state of health under Article 14 (state of certified energy for EV batteries), status (original, repurposed, re-used, remanufactured, waste), and usage data such as charging cycles, accidents and temperature.

Two details most summaries miss. Point 1(q) was corrected on 10 April 2026 and now refers to the markings of Article 13(4) and (5). And who has a "legitimate interest" is for an implementing act under Article 77(9), due by 18 August 2026 and unpublished on 22 October 2026.

Some public fields rest on obligations not yet applicable on 18 February 2027 (carbon footprint, due diligence report, recycled content). Article 77(2) asks for information "to the extent applicable", so our reading is that those fields stay empty until their basis applies. No Commission text confirms it.

Obligations that are still floors

Four families of obligations carry a printed date that is not yet a real one. Once the act exists, you take the later of the two dates. Until it does, there is no date, only a minimum.

Carbon footprint (Article 7)

EV batteries: 18 February 2025 or 12 months after the delegated act (methodology) or implementing act (format), both due by 18 February 2024 and neither published. Industrial batteries above 2 kWh follow at 18 February 2026 or 18 months after, LMT at 18 August 2028. Classes and maximum thresholds stack on top. See our battery carbon footprint article.

Labels (Article 13(1) to (3))

18 August 2026 or 18 months after the implementing act under Article 13(10), due by 18 August 2025 and not published. So the printed date has passed, yet the labels do not apply. The collection symbol and the Cd and Pb symbols are separate and already apply.

Recycled content documentation (Article 8(1))

18 August 2028 or 24 months after the delegated act on the method, due by 18 August 2026 and not published. The minimum shares of 2031 and 2036, by contrast, are fixed (battery recycled content article).

Minimum performance (Articles 9 and 10)

Industrial batteries: 18 August 2027 or 18 months after a delegated act due on 18 February 2026, not published. LMT and portable floors come later.

A caveat on "not published": we checked Cellar with two independent queries. A delegated act adopted but still in its three-month objection period (Article 89(6)) would not appear yet.

Due diligence (Articles 47 to 53)

Operators placing batteries on the market with a net turnover of at least EUR 40 million (Article 47) need a due diligence policy, verification by a notified body and the annual public report of Article 52(3). Regulation (EU) 2025/1561 (OJ L of 30 July 2025) replaced the original 18 August 2025 with 18 August 2027 and moved the Commission guidelines deadline to 26 July 2026. We have not found those guidelines in Cellar. Several Commission proposals citing the regulation are pending; proposals are not law, and 2025/1561 is the only 2025 amending act published.

Compliance checklist by battery category

Common to all six categories:

• Substance restrictions and, above the thresholds, Cd and Pb symbols: 18 Feb 2024 (Art. 6, Annex I, 13(5))
• Conformity assessment, EU declaration of conformity, CE marking: 18 Aug 2024 (Art. 17(1), 18, 20)
• Collection symbol and producer registration: 18 Aug 2025 (Art. 13(4), Chapter VIII)
• QR code: 18 Feb 2027 (Art. 13(6))
• General label: floor, act not published (Art. 13(1))
• Due diligence if net turnover is at least EUR 40 million: 18 Aug 2027 (Art. 47, 48(1))

LMT batteries

• Performance document and read-only state of health: 18 Aug 2024 (Art. 10(1), 14)
• Passport: 18 Feb 2027 (Art. 77(1)); replaceable by an independent professional, same date (Art. 11)
• Floors: capacity label (Art. 13(2)); carbon footprint and minimum performance not before 18 Aug 2028 (Art. 7(1)(c), 10(3))
• Collection: 51% by 31 Dec 2028 (Art. 60(3)); recycled content documentation 18 Aug 2033, minimum shares 18 Aug 2036 (Art. 8(1), 8(3))

Industrial batteries above 2 kWh

• Performance document (rechargeable): 18 Aug 2024 (Art. 10(1)); stationary storage: safety and state of health, same date (Art. 12(2), 14)
• Passport: 18 Feb 2027 (Art. 77(1))
• Floors: carbon footprint not before 18 Feb 2026 (Art. 7(1)(b)); minimum performance not before 18 Aug 2027 (Art. 10(2)); recycled content documentation not before 18 Aug 2028 (Art. 8(1))
• Minimum recycled content: 18 Aug 2031 and 18 Aug 2036 (Art. 8(2)-(3))

Industrial batteries of 2 kWh or less

• No passport (Art. 77(1)); the QR code still applies on 18 Feb 2027
• Stationary storage systems under the Article 3 definition: Art. 12(2) and 14 since 18 Aug 2024
• External storage: check the scope of Art. 7(1)(d)

Electric vehicle batteries

• Performance document and read-only state of health: 18 Aug 2024 (Art. 10(1), 14)
• Passport: 18 Feb 2027 (Art. 77(1))
• Floors: carbon footprint declaration, class and threshold not before 18 Feb 2025, 18 Aug 2026 and 18 Feb 2028 (Art. 7); recycled content documentation not before 18 Aug 2028 (Art. 8(1))
• Minimum recycled content: 18 Aug 2031 and 18 Aug 2036 (Art. 8(2)-(3))

Portable batteries

• Lead restriction: 18 Aug 2024 (Annex I); no passport
• End-user removability in products: 18 Feb 2027 (Art. 11, Del. Reg. 2026/1770)
• Collection: 63% by 31 Dec 2027, 73% by 31 Dec 2030 (Art. 59(3))
• Floors: capacity and non-rechargeable labels (Art. 13(2)-(3)); minimum performance not before 18 Aug 2028 (Art. 9)

SLI batteries

• QR code also gives access to recycled content: 18 Feb 2027 (Art. 13(6)(c)); no passport
• Floors: capacity label (Art. 13(2)); recycled content documentation not before 18 Aug 2028 (Art. 8(1))
• Minimum recycled content: 18 Aug 2031 and 18 Aug 2036 (Art. 8(2)-(3))

Frequently asked questions

When does the EU battery passport become mandatory?

From 18 February 2027, for each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market or put into service (Article 77(1) of Regulation (EU) 2023/1542).

Does the 2 kWh threshold apply to LMT and EV batteries?

No. In Article 77(1) the threshold attaches only to industrial batteries. LMT and EV batteries need a passport whatever their capacity.

Do portable and SLI batteries need a QR code?

Yes. From 18 February 2027 all batteries must carry a QR code (Article 13(6)). For batteries without a passport it leads to the label information, the EU declaration of conformity, the due diligence report and waste information, plus recycled content for SLI batteries.

Do the battery labelling requirements already apply?

The separate collection symbol has applied since 18 August 2025. The labels of Article 13(1) to (3) apply from 18 August 2026 or 18 months after the implementing act under Article 13(10), whichever is the latest. That act was not published as of 22 October 2026, so these labels are not yet applicable.

When must EV batteries carry a carbon footprint declaration?

Article 7(1) sets 18 February 2025 or 12 months after the methodology or format act enters into force, whichever is the latest. Neither act was published as of 22 October 2026, so the declaration is not yet applicable.

When do battery due diligence obligations start?

On 18 August 2027, for operators placing batteries on the market with a net turnover of at least EUR 40 million. Regulation (EU) 2025/1561 moved the date from 18 August 2025.

Sources: CELEX 32023R1542 (OJ L 191, 28.7.2023); 02023R1542-20260813 (consolidated version of 13 August 2026); 32023R1542R(13) (corrigendum, Annex XIII point 1(q)); 32024R1781 (Articles 13 and 78); 32025R1561; 32026R1738; 32026R1770; 32026R1778; 52025XC00214 (notice C/2025/214). Read via Cellar, Publications Office of the European Union, on 22 October 2026.