EU Battery Regulation

The Battery Regulation has its own technical-documentation and EU Declaration of Conformity framework. The technical documentation established under the applicable Article 17 / Annex VIII conformity procedure must make it possible to assess the battery's conformity with the requirements concerned. Depending on the procedure and battery requirement, the file can include battery identification and intended use, design and manufacturing information, component information, technical specifications, standards or common specifications used, calculations, assessments, test evidence and labelling information.

Once conformity has been demonstrated, the manufacturer draws up the EU Declaration of Conformity under Article 18 using the structure in Annex IX. The declaration is kept up to date and the manufacturer assumes responsibility for the battery's compliance with the Regulation. The applicable technical documentation and EU Declaration of Conformity must be retained for ten years after the battery has been placed on the market or put into service.

Regulation (EU) 2023/1542 has applied generally since 18 February 2024, but its requirements are phased. Key milestones include:

The Regulation uses five principal battery categories:

Classification matters because requirements concerning carbon footprint, recycled content, performance and durability, removability, labelling and the Battery Passport differ by category and, in some cases, battery capacity or use. Where a battery could fall within more than one category for the sustainability and safety requirements in Chapter II, the Regulation applies the category carrying the strictest requirements.

A battery does not fall outside the Battery Regulation because it is incorporated into another product. A battery incorporated into electrical or electronic equipment remains subject to the applicable battery requirements, while the host equipment must separately be assessed under the Union product legislation and EEE/WEEE rules applicable to it.

The responsible economic operator and producer status therefore need to be assessed separately for the battery and for the host product.

Before placing a battery on the market or putting it into service, the manufacturer must complete or arrange the conformity-assessment procedure applicable under Article 17. The relevant procedures are set out in Annex VIII and differ according to the requirements being assessed. The Battery Regulation must therefore not be described as using one single conformity module for every obligation.

Where conformity has been demonstrated, the manufacturer draws up the EU Declaration of Conformity under Article 18 and affixes the CE marking in accordance with Articles 19 and 20.

The Battery Regulation uses CE marking as part of its conformity framework. Under Articles 19 and 20, the CE marking must be affixed before the battery is placed on the market or put into service. Where affixing it directly to the battery is not possible or justified because of the nature of the battery, it is placed on the packaging and accompanying documents.

A notified-body identification number accompanies the CE marking only where the applicable Annex VIII conformity procedure requires notified-body involvement.

The Regulation phases in several labelling and information requirements. The separate-collection symbol applies under Article 13 according to its specified timetable. Other general battery labels and capacity / duration information use implementation dates linked to the relevant implementing act and must therefore be checked against the applicable legal timetable rather than assumed from one fixed date alone.

From 18 February 2027, Article 13(6) requires batteries to carry a QR code. The information reached through that QR code depends on the battery category. For LMT batteries, industrial batteries with a capacity greater than 2 kWh and electric-vehicle batteries, the QR code provides access to the Battery Passport. For other batteries, the QR code provides access to the information specified by Article 13 rather than creating a Battery Passport obligation.

Article 11 applies from 18 February 2027 and establishes removability and replaceability requirements for defined portable batteries and LMT batteries incorporated into products. For portable batteries, the general rule is removability and replaceability by the end user, subject to the Regulation's specific conditions and derogations. For LMT batteries, the Regulation requires removability and replaceability by an independent professional. These requirements must be assessed together with the product design, safety conditions and the specific exceptions provided by Article 11.

Requirements concerning carbon footprint, recycled content, electrochemical performance and durability are category-specific and phased. They apply to defined battery categories and, in several cases, their effective dates depend on delegated or implementing acts in addition to dates stated in the Regulation. A compliance assessment must therefore identify:

From 18 February 2027, Article 77 requires a Battery Passport for LMT batteries, industrial batteries with a capacity greater than 2 kWh and electric-vehicle batteries. The Battery Passport does not apply to every portable battery or every SLI battery merely because those batteries also carry a QR code.

The Passport has its own data, access, identification and lifecycle requirements, which are covered on the dedicated Battery Passport page.

The Regulation also establishes battery supply-chain due-diligence obligations for economic operators that fall within the scope of Chapter VII. Regulation (EU) 2025/1561 amended the application date of those obligations. Article 48 now applies from 18 August 2027.

Whether an economic operator falls within the due-diligence regime must be assessed against the scope and exemptions in Article 47, including the applicable turnover and group criteria. Where the regime applies, the Regulation requires due-diligence policies and third-party verification and audit arrangements under the relevant provisions.

The Battery Regulation also contains an EU framework for extended producer responsibility, but compliance remains operationally linked to the Member State in which the producer makes batteries available on the market. Producer status, registration, authorised representation, fulfilment, collection, waste-battery management and reporting must therefore still be established for each relevant Member State.

An EU technical file, EU Declaration of Conformity, CE marking or Battery Passport does not replace national EPR registration or reporting.