EU Battery Regulation & Digital Battery Passport
The first mandatory Digital Product Passport in the EU. Timeline of obligations, from the Battery Passport deadline of 18 February 2027 to carbon footprint and recycled content rules that still await Commission acts.
Overview
The EU Battery Regulation (EU 2023/1542) establishes comprehensive lifecycle requirements for all batteries placed on the EU market. It introduces the first mandatory Digital Product Passport in the EU — the Digital Battery Passport — with phased obligations running from 2024 through 2036.
Legal basis
- Proposed: 10 December 2020
- Adopted: 12 July 2023
- Published in OJ: 28 July 2023
- Entered into force: 17 August 2023
- Applicable from: 18 February 2024
- Replaces: Battery Directive 2006/66/EC (fully repealed 18 August 2025)
Battery categories
| Category | Abbreviation | Definition |
|---|---|---|
| Portable | POR | Up to 5 kg, sealed, not industrial |
| Light Means of Transport | LMT | Up to 25 kg (e-bikes, e-scooters) |
| Starting/Lighting/Ignition | SLI | Automotive starter batteries |
| Electric Vehicle | EV | Traction batteries for cars, vans, trucks, buses and trailers (categories M, N, O) at any weight; for L-category vehicles, over 25 kg |
| Stationary Energy Storage | ESS | A type of industrial battery with internal storage, for grid or end-user energy storage |
| Industrial | IND | Designed for industrial uses (any weight), or any other battery over 5 kg that is not an EV, LMT or SLI battery |
Digital Battery Passport
Mandatory from: 18 February 2027 for all EV, LMT, and industrial batteries with capacity >2 kWh.
Each battery must carry a QR code linking to a digital passport containing:
- Unique identifier code
- Chemical composition by weight (active materials, electrolytes)
- Carbon footprint (by manufacturing plant)
- Recycled content percentages (cobalt, lead, lithium, nickel)
- State of health and remaining capacity data
- Expected and actual lifespan
- Recycling/repurposing instructions
- Supply chain traceability data
- Due diligence documentation references
- Safety information
Not every field applies from the start. According to the Commission's batteries passport FAQ, carbon footprint, recycled content and due diligence information "will not yet be required" when passports begin in February 2027. Each has its own application date, and passports carry that information only for batteries placed on the market once it applies.
The Commission's Digital Batteries Passport guidance of 21 August 2026 maps 71 data points across EV, LMT and industrial batteries, each flagged as mandatory, optional or conditional.
Registry. Battery passports are linked to the EU DPP registry set up under the ESPR. Implementing Regulation (EU) 2026/1778 on the registry entered into force on 6 August 2026. It requires each Member State to appoint a national registry administrator by 18 February 2027, the same day the first registrations for certain large batteries fall due.
Access rights. Part of the passport is public (Annex XIII, point 1) and part is reserved for notified bodies, market surveillance authorities and the Commission (point 3). It is still undecided who counts as a person with a legitimate interest, such as a repairer or recycler, and what they may see in points 2 and 4. The implementing act on access rights under Article 77(9) was due by 18 August 2026 and has not been adopted. The Commission expects to publish a draft for feedback in October or November 2026 and aims for a committee vote in December 2026 or early January 2027 (indicative). At its 30 September 2026 webinar it also announced technical specifications for developers by the end of October 2026 and DPP Registry API integration guidelines by the end of December 2026 (both indicative).
Standards. Article 77(3) requires the QR code and the unique identifier to comply with the ISO/IEC 15459 series (parts 1 to 6) "or their equivalent". On 16 September 2026, Implementing Decision (EU) 2026/2048 cited the first harmonised standard under the Battery Regulation, EN 18060:2025 on EV battery performance and durability. No harmonised standard yet covers the battery passport's technical design under Article 78.
Proposed, not law: a draft Commission delegated act, open for feedback from 29 September to 27 October 2026, would require the QR code to comply with EN 18220:2026 and the unique identifier with EN 18219:2026, "or their equivalent". The Commission says the currently referenced standards can still be used as equivalents, and it expects adoption and publication in 2027. The same draft sets the first minimum performance and durability values for rechargeable industrial batteries above 2 kWh, except those with exclusively external storage.
Proposed, not law: under a provisional agreement of 26 June 2026 on the digitalisation omnibus, instructions for stationary battery energy storage systems could be provided electronically, through a new public field in the battery passport, and batteries would show a "digital contact" for the manufacturer and importer. These changes would apply 30 months after the amending regulation enters into force. Parliament's plenary vote on procedure 2025/0134(COD) is indicatively set for 23 November 2026.
Carbon footprint requirements
The carbon footprint declaration (Art 7(1)) is not yet applicable. Each phase depends on two Commission acts: a delegated act setting the calculation and verification methodology, and an implementing act setting the format of the declaration. The declaration applies from the date below, or 12 months (EV batteries) or 18 months (other categories) after both acts have entered into force, whichever is later. As of 11 October 2026 neither act has been adopted for any category, so the dates below are the earliest possible dates, not obligations in force. The Commission's batteries passport FAQ confirms that this information "will not yet be required" in passports from February 2027.
| Earliest date | Batteries affected |
|---|---|
| February 2025 | EV batteries |
| February 2026 | Rechargeable industrial batteries >2 kWh, except those with exclusively external storage |
| August 2028 | LMT batteries |
| August 2030 | Rechargeable industrial batteries >2 kWh with external storage |
Batteries will also be sorted into carbon footprint performance classes, with class A the best, once the Commission sets the classes by delegated act. The Regulation leaves the number of classes to that act (Annex II, point 8).
Maximum thresholds. Article 7(3) adds a maximum life cycle carbon footprint threshold, set by a further delegated act. It applies from 18 February 2028 (EV batteries), 18 February 2029 (rechargeable industrial batteries, except those with exclusively external storage), 18 August 2031 (LMT batteries) and 18 August 2033 (industrial batteries with external storage), or 18 months after that delegated act enters into force, whichever is later.
Due diligence requirements
Mandatory from 18 August 2027. The original date of 18 August 2025 was postponed by two years by Regulation (EU) 2025/1561, which amended Article 48(1). The same act moved the deadline for the Commission's due-diligence guidelines to 26 July 2026.
Economic operators with a net turnover below €40 million in the financial year before last, and not part of a group above that limit, are exempt under Article 47. This is the threshold in force today.
Proposed, not law: a provisional agreement of 26 June 2026 on the small mid-cap omnibus would raise the threshold to €200 million and replace the yearly due diligence report with a review at least every five years. Parliament's plenary vote on procedure 2025/0130(COD) is indicatively set for 23 November 2026. The threshold stays at €40 million until the change is adopted and published in the Official Journal.
Required actions:
- Adopt and publicly communicate a due diligence policy (OECD Guidelines)
- Establish management system for supply chain risk identification
- Conduct risk assessment for: cobalt, lithium, nickel, natural graphite
- Implement risk mitigation strategies
- Undergo independent third-party audit
- Review and publish a report on the due diligence policy every year (Art 52(3))
Complete obligation timeline
2024
| Date | Obligation | Categories |
|---|---|---|
| 18 Feb | Regulation applicable; hazardous substance limits | All |
| 18 Aug | Safety requirements for stationary ESS | ESS |
| 18 Aug | CE marking mandatory | All |
| 18 Aug | Document with performance and durability values must accompany the battery (Art 10(1)) | LMT, EV, rechargeable IND >2 kWh |
2025
| Date | Obligation | Categories |
|---|---|---|
| 18 Feb | Carbon footprint declaration, earliest date; not yet applicable (see Carbon footprint requirements) | EV batteries |
| 18 Aug | Collection symbol labelling | All |
| 18 Aug | Extended Producer Responsibility schemes | All |
| 18 Aug | Old Battery Directive fully repealed | — |
2026
| Date | Obligation | Categories |
|---|---|---|
| 18 Feb | Carbon footprint declaration, earliest date; not yet applicable (see Carbon footprint requirements) | Rechargeable IND >2 kWh, except exclusively external storage |
2027
| Date | Obligation | Categories |
|---|---|---|
| 18 Feb | Digital Battery Passport mandatory | EV, LMT, IND >2 kWh |
| 18 Feb | QR code marking required | All |
| 18 Feb | Portable battery removability by end users | POR |
| 18 Aug | Due diligence obligations (Regulation (EU) 2025/1561) | Economic operators above the €40 million turnover threshold (Art 47) |
| 31 Dec | Material recovery targets: 90% Co/Cu/Ni/Pb, 50% Li (kept unchanged by COM(2026) 470) | Recyclers |
2028
| Date | Obligation | Categories |
|---|---|---|
| 18 Feb | Maximum carbon footprint threshold, or 18 months after its delegated act if later (Art 7(3)) | EV batteries |
| 18 Aug | Recycled content documentation (Art 8(1)), earliest date: applies 24 months after the methodology delegated act if later, and that act is not yet adopted | EV, IND >2 kWh (not exclusively external storage), SLI |
| 18 Aug | Carbon footprint declaration, earliest date; not yet applicable (see Carbon footprint requirements) | LMT batteries |
2029-2036
| Date | Obligation | Categories |
|---|---|---|
| 18 Feb 2029 | Maximum carbon footprint threshold, or 18 months after its delegated act if later (Art 7(3)) | Rechargeable IND >2 kWh, except exclusively external storage |
| 18 Aug 2030 | Carbon footprint declaration, earliest date; not yet applicable (see Carbon footprint requirements) | IND >2 kWh with external storage |
| Dec 2030 | Portable collection: 73% target | POR |
| 18 Aug 2031 | Minimum recycled content: 16% cobalt, 85% lead, 6% lithium, 6% nickel (Art 8(2)) | EV, IND >2 kWh (not exclusively external storage), SLI |
| 18 Aug 2031 | Maximum carbon footprint threshold, or 18 months after its delegated act if later (Art 7(3)) | LMT batteries |
| 18 Aug 2033 | Recycled content documentation extends to LMT batteries (Art 8(1)) | LMT batteries |
| 18 Aug 2033 | Maximum carbon footprint threshold, or 18 months after its delegated act if later (Art 7(3)) | IND >2 kWh with external storage |
| 18 Aug 2036 | Minimum recycled content: 26% cobalt, 85% lead, 12% lithium, 15% nickel (Art 8(3)) | EV, LMT, IND >2 kWh (not exclusively external storage), SLI |
Date not yet set
| When | Obligation | Categories |
|---|---|---|
| 18 months after the delegated act enters into force (draft published 29 Sep 2026; adoption expected in 2027) | Minimum performance and durability values (Art 10(2)); the values are proposed in a draft act, not yet adopted | Rechargeable IND >2 kWh, except exclusively external storage |
Recycling targets review
On 11 September 2026 the Commission concluded in report COM(2026) 470 that it is "not considered appropriate to revise" the recycling-efficiency and material-recovery targets in Annex XII, Parts B and C. It called the 50% lithium recovery target "well balanced". The next assessment is due by 18 August 2031.
Penalties
The Regulation sets no EU-wide maximum fine. Under Article 93, Member States had to lay down effective, proportionate and dissuasive penalties by 18 August 2025 and notify them to the Commission, so amounts differ by country. Additional enforcement consequences include:
- Market exclusion — non-compliant batteries cannot be placed on the EU market
- Product withdrawal or recall
- Criminal liability in member states with stricter national implementation
Who is affected
Primary obligations fall on the first company placing a battery on the EU market:
- Manufacturers of EV, LMT, and industrial batteries with capacity >2 kWh
- Importers — bear primary DPP and due diligence liability where the manufacturer is outside the EU
- Distributors — must verify compliance markings are present before making batteries available
Due diligence obligations (Arts 47–53, from 18 August 2027 under Regulation (EU) 2025/1561) apply to economic operators placing in-scope batteries on the EU market, subject to the net-turnover threshold noted above.
Key articles
| Article | Subject |
|---|---|
| Art. 13 | Labelling and marking: capacity, date of manufacture, collection symbol, QR code (Art 13(6)) |
| Arts 47–53 | Supply chain due diligence — cobalt, lithium, nickel, natural graphite; application date in Art 48(1), as amended by Regulation (EU) 2025/1561 |
| Art. 77 | Digital battery passport — general requirements |
| Art. 78 | Technical design and operation of the battery passport: interoperability, free access according to access rights, data storage, integrity and security |
| Art. 79 | Procedure at national level for batteries presenting a risk (corrective action, withdrawal, recall) |
| Art. 93 | Penalties: set by Member States; no EU-wide maximum |
| Annex XIII | Battery passport information requirements (the Commission's August 2026 guidance maps 71 data points) |
Source
- Regulation (EU) 2023/1542 — EUR-Lex
- Regulation (EU) 2025/1561 (due diligence postponement) — EUR-Lex
- Implementing Regulation (EU) 2026/1778 (DPP registry) — EUR-Lex
- COM(2026) 470 — Report on Annex XII recycling targets — EUR-Lex
- European Commission — Guidance to support preparations for the Digital Batteries Passport, 21 August 2026
- Implementing Decision (EU) 2026/2048 (harmonised standard EN 18060:2025), EUR-Lex
- European Commission, EU Digital Product Passport FAQ for Batteries
- European Commission, third webinar on the batteries DPP, 30 September 2026
- Have Your Say 14460: minimum performance and durability values for rechargeable industrial batteries (draft delegated act, proposed)
- Have Your Say 16473: implementing regulation on access rights to certain parts of the battery passport
- Provisional agreement on the small mid-cap omnibus, procedure 2025/0130(COD), European Parliament
- Provisional agreement on the digitalisation omnibus, procedure 2025/0134(COD), European Parliament
- Battery Pass Initiative