The EU Batteries Regulation (EU) 2023/1542 introduces comprehensive requirements for batteries throughout their entire life cycle which includes the sourcing, manufacturing, use, collection and recycling.
The Regulation entered into force on 17 August 2023 and has generally applied since 18 February 2024. Further requirements are being introduced gradually over several years. One of the next major milestones is 18 February 2027, when QR code requirements will apply to all batteries and the Digital Battery Passport will become mandatory for certain battery categories.
For companies placing batteries or battery-containing products on the EU market, early preparation is important. As the new requirements affect product information and data throughout the supply chain, having the required information available in good time can help avoid additional clarification and potential delays in the logistics process.
Scope of regulation
The Regulation applies to all main battery categories:
- Portable batteries
- Starting, lighting and ignition (SLI) batteries
- Light means of transport (LMT) batteries, such as batteries for e-bikes and e-scooters
- Electric vehicle (EV) batteries
- Industrial batteries
Importantly, the Regulation also covers batteries incorporated into or added to other products. The requirements can therefore also be relevant for companies placing machinery, equipment, vehicles or other battery-containing products on the EU market.
The specific obligations depend on the battery category and on the role of the respective economic operator. The Regulation covers areas including sustainability, safety, labelling and information requirements, extended producer responsibility, waste management and battery due diligence.
Key Regulatory Milestones
17 August 2023: Entry into force
The EU Batteries Regulation entered into force, establishing a regulatory framework covering the entire battery life cycle.
18 February 2024: General application
The Regulation generally started to apply, while a number of specific requirements were assigned later application dates.
18 February 2027: QR codes and Digital Battery Passport
From this date, all batteries must be marked with a QR code.
For LMT batteries, industrial batteries with a capacity greater than 2 kWh and electric vehicle batteries, the QR code will provide access to a Digital Battery Passport linked to a unique identifier for the individual battery.
Depending on the battery category and applicable requirements, the Battery Passport will contain information relating to areas such as:
- Battery and manufacturer identification
- Material composition and battery chemistry
- Carbon footprint and recycled content
- Responsible sourcing
- Capacity, performance and expected lifetime
- EU Declaration of Conformity
- End-of-life and waste-management information
Not all information contained in the Battery Passport will be publicly accessible. Access to certain technical and commercially sensitive information will be restricted in accordance with the Regulation.
For affected companies, the Digital Battery Passport therefore involves more than simply introducing a QR code. The required battery, product and supply-chain information needs to be available, structured and maintained in accordance with the Regulation.
Requirements concerning the removability and replaceability of portable and LMT batteries will also apply from 18 February 2027, subject to specific exemptions.
18 August 2027: Battery due diligence requirements
The battery due diligence requirements will apply from 18 August 2027 following a two-year postponement adopted by the EU in 2025.
The requirements address environmental and social risks related to the sourcing, processing and trading of raw materials including cobalt, natural graphite, lithium and nickel used for battery manufacturing.
Chapter VII of the Regulation does not apply to economic operators that had a net turnover below EUR 40 million in the financial year preceding the last financial year, if they are not part of a group exceeding EUR 40 million on a consolidated basis.
This threshold applies specifically to the battery due diligence requirements and not to the EU Batteries Regulation as a whole.
From 2028 onwards: Further sustainability requirements
Further requirements relating to recycled content, carbon footprint, performance and durability will continue to be introduced depending on the battery category.
Important Takeaways
- The EU Batteries Regulation covers all battery categories and also applies to batteries incorporated into or added to other products.
- From 18 February 2027, all batteries must be marked with a QR code.
- The Digital Battery Passport applies to LMT batteries, EV batteries and industrial batteries with a capacity greater than 2 kWh.
- Requirements concerning the removability and replaceability of portable and LMT batteries will also apply from February 2027, subject to specific exemptions.
- Battery due diligence requirements will apply from 18 August 2027. Economic operators below the EUR 40 million net-turnover threshold are exempt where the conditions set out in the Regulation are met.
- Further requirements relating to areas such as carbon footprint and recycled content will be introduced progressively.
- Companies should identify the battery categories relevant to their products, determine their respective obligations and ensure that the necessary information can be obtained from manufacturers and suppliers in good time.
- Further delegated and implementing acts are still being developed under the Regulation and should be monitored.
How can we support you?
Bertling will continue to monitor developments under the EU Batteries Regulation that are relevant to international logistics and global supply chains.
Feel free to contact sustainability@berting.com if you have any questions.
Extract of available EU sources for further information
- Regulation (EU) 2023/1542 concerning batteries and waste batteries
- Regulation (EU) 2025/1561 concerning battery due diligence obligations
- Environmental requirements of Batteries by European Commission
- European Commission guidelines on the removability and replaceability of portable and LMT batteries