---
title: "EU Batteries Regulation Timeline, Decision Flow, and Compliance Guides"
canonical_url: "https://www.sorena.io/artifacts/eu/batteries-regulation"
source_url: "https://www.sorena.io/artifacts/eu/batteries-regulation"
author: "Sorena AI"
description: "Use this Batteries Regulation hub to classify battery categories, map the exact dates in Regulation (EU) 2023/1542."
published_at: "2026-02-21"
updated_at: "2026-02-21"
keywords:
  - "EU Batteries Regulation"
  - "Regulation (EU) 2023/1542"
  - "battery passport"
  - "QR code batteries"
  - "battery carbon footprint declaration"
  - "battery due diligence"
  - "Article 11 removability"
  - "Article 14 state of health"
  - "recycled content batteries"
  - "collection targets portable batteries"
  - "collection targets LMT batteries"
  - "recycling efficiency targets"
  - "producer responsibility batteries"
  - "Article 7"
  - "Article 48"
  - "Producer responsibility"
---
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# EU Batteries Regulation Timeline, Decision Flow, and Compliance Guides

Use this Batteries Regulation hub to classify battery categories, map the exact dates in Regulation (EU) 2023/1542.

![EU Batteries Regulation artifact preview](https://cdn.sorena.io/cdn-cgi/image/format=auto/cheatsheets/prod/sorena-ai-eu-batteries-timeline-small.jpg?v=cheatsheets%2Fprod)

*EU Batteries* *Free Resource*

## EU Batteries Regulation Timeline, Decision Flow & Guides

Use this artifact to classify batteries as portable, LMT, SLI, industrial, or EV, then route each model to the right obligations for battery passport, carbon footprint, due diligence, labels, state of health data, recycled content, and waste battery management.

The dates matter: the Regulation applies from 18 February 2024, Article 14 and Chapter VI timing start from 18 August 2024, due diligence and penalties readiness start from 18 August 2025, broader labels start from 18 August 2026, and QR plus battery passport and Article 11 removability start from 18 February 2027.

[Get a batteries readiness review](/contact.md)

## What you can decide faster

- **Category and scope**: Classify portable, LMT, SLI, industrial, and EV batteries using the legal definitions and thresholds.
- **Product and data duties**: Route the model to Article 7, Article 8, Article 11, Article 13, Article 14, and Article 77 where they apply.
- **Lifecycle and waste duties**: Plan due diligence, producer responsibility, collection, recycling, and reporting with the right dates and evidence.

By Sorena AI | Updated 2026 | No signup required

### Quick scan

*Batteries*

- **Category route**: Decide the legal battery category before you build labels, passport, or due diligence controls.
- **Date map**: Track the 2024, 2025, 2026, and 2027 milestones that change what must be operational.
- **Evidence path**: Move from product requirements to supplier evidence and waste reporting without splitting the model record.

Use the decision flow first, then open the page specific guides to build the right controls and records.

| Value | Metric |
| --- | --- |
| 18 Feb 2024 | Applies |
| 18 Aug 2025 | Due diligence |
| 18 Aug 2026 | Labels |
| 18 Feb 2027 | Passport |

**Key highlights:** Classify battery | Build passport | Plan waste duties

## Topic Guides

- [Battery Carbon Footprint Declarations | Article 7 Implementation Guide](/artifacts/eu/batteries-regulation/carbon-footprint-declarations.md): Implement the carbon footprint declaration requirements in Article 7 of Regulation (EU) 2023/1542 with plant specific battery model declarations.
- [Battery Due Diligence Program | Articles 48 to 52 Implementation Guide](/artifacts/eu/batteries-regulation/due-diligence-program.md): Build a battery due diligence program for Regulation (EU) 2023/1542 with an Article 48 policy, Article 49 management system and traceability.
- [Battery Due Diligence Supplier Questionnaire | EU Batteries Regulation](/artifacts/eu/batteries-regulation/battery-due-diligence-supplier-questionnaire.md): Use a practical supplier questionnaire for the battery due diligence obligations in Articles 48 to 52 of Regulation (EU) 2023/1542.
- [Battery Labeling and Consumer Information | Article 13 and Article 74 Guide](/artifacts/eu/batteries-regulation/labeling-and-consumer-information.md): Implement battery labeling, QR code, and consumer information duties under Regulation (EU) 2023/1542, including the separate collection symbol.
- [Battery Passport Data Model Template | Annex XIII Ready Structure](/artifacts/eu/batteries-regulation/battery-passport-data-model-template.md): Design a battery passport data model for Regulation (EU) 2023/1542 using the Annex XIII access tiers for public model data, legitimate interest data.
- [Battery Passport Implementation | Article 77 and Article 78 Guide](/artifacts/eu/batteries-regulation/battery-passport-implementation.md): Implement the EU battery passport for LMT batteries, industrial batteries above 2 kWh, and EV batteries with a compliant QR resolver, Annex XIII data model.
- [Battery Recycled Content and Recovery Targets | Article 8 and Annex XII Guide](/artifacts/eu/batteries-regulation/recycled-content-and-recovery-targets.md): Understand the recycled content roadmap in Article 8 and the recycling efficiency and material recovery targets in Annex XII.
- [EU Batteries Regulation Applicability Test | Category, Scope, and Obligation Routing](/artifacts/eu/batteries-regulation/applicability-test.md): Run a grounded applicability test for Regulation (EU) 2023/1542 by checking whether the battery is portable, LMT, SLI, industrial, or EV.
- [EU Batteries Regulation Battery Categories and Scope | Portable, LMT, SLI, Industrial, EV](/artifacts/eu/batteries-regulation/battery-categories-and-scope.md): Use the legal category definitions in Regulation (EU) 2023/1542 to classify batteries as portable, LMT, SLI, industrial, or EV.
- [EU Batteries Regulation Checklist | Practical Compliance Checklist by Battery Category](/artifacts/eu/batteries-regulation/checklist.md): Use a detailed checklist for Regulation (EU) 2023/1542 covering battery classification, labeling, QR, battery passport, carbon footprint declarations.
- [EU Batteries Regulation Compliance Program | Build an Operational Batteries Program](/artifacts/eu/batteries-regulation/compliance.md): Build a practical compliance program for Regulation (EU) 2023/1542 covering battery classification, technical documentation, carbon footprint declarations.
- [EU Batteries Regulation Deadlines and Compliance Calendar | Exact Dates and Workplan](/artifacts/eu/batteries-regulation/deadlines-and-compliance-calendar.md): Track the exact dates in Regulation (EU) 2023/1542, including application from 18 February 2024, Article 14 and Chapter VI timing from 18 August 2024.
- [EU Batteries Regulation FAQ | Dates, Categories, Passport, Due Diligence, and Waste Duties](/artifacts/eu/batteries-regulation/faq.md): Get grounded answers to common questions on Regulation (EU) 2023/1542, including the main application date, when battery passport starts.
- [EU Batteries Regulation Penalties and Enforcement | Article 93 Guide](/artifacts/eu/batteries-regulation/penalties-and-fines.md): Understand the penalty and enforcement structure in Regulation (EU) 2023/1542.
- [EU Batteries Regulation Requirements | Article by Article Requirement Map](/artifacts/eu/batteries-regulation/requirements.md): Get a practical map of the main requirements in Regulation (EU) 2023/1542, including category rules, carbon footprint, recycled content, removability.
- [EU Batteries Regulation vs ESPR | Battery Passport vs Digital Product Passport](/artifacts/eu/batteries-regulation/batteries-regulation-vs-espr.md): Compare the battery passport in Regulation (EU) 2023/1542 with the broader ESPR Digital Product Passport model.

## Key dates for battery compliance

*Batteries Timeline*

Track the phased dates for state of health, due diligence, labels, QR, passport, recycled content, collection targets, and recycling performance.

## Which obligations apply to your batteries

*Batteries Decision Flow*

Use the decision flow to classify the battery and route it to the right product, data, due diligence, and waste obligations.

*Next step*

## Turn EU Batteries Regulation Timeline, Decision Flow & Guides into an ESG delivery workflow

EU Batteries Regulation Timeline, Decision Flow & Guides should be the shared entry point for your team. Route execution into ESG Compliance for live work and into SSOT when the artifact needs deeper research, evidence governance, or supporting analysis.

- Start from EU Batteries Regulation Timeline, Decision Flow & Guides and route the work by entity, product, team, or control owner.
- Use ESG Compliance to manage cross team sustainability work, reporting, and evidence from one workflow.
- Use SSOT to keep documents, evidence, and control records in one governed system.
- Move from artifact reading to accountable execution without rebuilding the guidance in separate files.

- [Open ESG Compliance](/solutions/esg-compliance.md): Manage cross team sustainability work, reporting, and evidence from one workflow for EU Batteries Regulation Timeline, Decision Flow & Guides.
- [Open SSOT](/solutions/ssot.md): Keep documents, evidence, and control records in one governed system from the same artifact.
- **Download decision flow**: Share the category and obligation logic internally.
- **Download timeline**: Align packaging, digital, supplier, and waste work with the legal dates.
- [Talk through EU Batteries Regulation Timeline, Decision Flow & Guides](/contact.md): Review your current process, evidence model, and next steps for EU Batteries Regulation Timeline, Decision Flow & Guides.

## Decision Steps

### STEP 1: Do you place batteries on the EU market or put them into service?

*Reference: Art. 1, Art. 3(16)-(18)*

- This Regulation lays down requirements on sustainability, safety, labelling, marking and information to allow the placing on the market or putting into service of batteries within the Union.
- It applies to all categories of batteries, including batteries incorporated into or added to products.
- Placing on the market means the first making available of a battery on the Union market; making available on the market means any supply for distribution or use in the course of a commercial activity; putting into service means the first use for the intended purpose in the Union.

- **YES** Which battery category applies?
- **NO** Not Subject to Batteries Regulation

### STEP 2: Which battery category applies?

*Reference: Art. 3(9)-(14)*

- Portable battery: sealed, weighs 5 kg or less, not designed specifically for industrial use, and neither an EV, LMT, nor SLI battery.
- LMT battery: sealed, weighs 25 kg or less, designed to provide traction power for wheeled vehicles powered by an electric motor alone or by a combination of motor and human power (including category L vehicles), and not an EV battery.
- SLI battery: designed to supply electric power for starting, lighting or ignition, and can also be used for auxiliary or backup purposes.
- EV battery: designed for traction in hybrid or electric vehicles of category L that weigh more than 25 kg, or in hybrid or electric vehicles of categories M, N or O.
- Industrial battery: designed for industrial uses, or intended for industrial uses after preparation for repurposing or repurposing, or any other battery that weighs more than 5 kg and is neither an EV, LMT, nor SLI battery.

- -> What is your role as an economic operator?

### STEP 3: What is your role as an economic operator?

*Reference: Art. 3(22), (33), (63)-(65)*

- Manufacturer: natural or legal person who manufactures a battery or has a battery designed or manufactured, and markets that battery under the manufacturer's name or trademark.
- Importer: natural or legal person established in the Union who places a battery from a third country on the Union market.
- Distributor: natural or legal person in the supply chain, other than the manufacturer or importer, who makes a battery available on the market.
- Authorised representative: natural or legal person established in the Union with a written mandate from the manufacturer to act on the manufacturer's behalf.
- Each role has specific obligations under the Regulation.

- -> Do sustainability requirements apply to your battery?

### STEP 4: Do sustainability requirements apply to your battery?

*Reference: Art. 6-10*

- Carbon footprint declaration and performance classes apply to: rechargeable industrial batteries >2 kWh, LMT batteries, and EV batteries (Art. 7).
- Recycled content requirements apply to: industrial batteries >2 kWh, EV batteries, and certain SLI and LMT batteries containing cobalt, lead, lithium, or nickel in active materials (Art. 8).
- Performance and durability requirements apply to: portable batteries of general use, rechargeable industrial batteries, LMT batteries, and EV batteries (Art. 9-10).
- Restrictions on hazardous substances apply to all batteries (Art. 6).

- -> Have you met labelling and information requirements?

### STEP 5: Have you met labelling and information requirements?

*Reference: Art. 13-14, 77*

- Separate collection symbol: from 18 Aug 2025, all batteries must be marked with the separate collection symbol (Art. 13(4)).
- General labels and capacity labels: apply from 18 Aug 2026 (or later depending on the implementing act) (Art. 13(1)-(3), Art. 13(10)).
- Heavy metal marking: batteries containing more than 0.002% cadmium or more than 0.004% lead must be marked with Cd or Pb (Art. 13(5)).
- QR code: from 18 Feb 2027, all batteries must be marked with a QR code providing access to required information (Art. 13(6)).
- Battery passport: from 18 Feb 2027, LMT batteries, industrial batteries over 2 kWh and EV batteries must have a battery passport accessible via the QR code (Art. 77(1), Art. 13(6)(a)).
- State of health and expected lifetime data: for stationary battery energy storage systems, LMT and EV batteries, up-to-date data must be contained in the battery management system from 18 Aug 2024; read-only access must be provided to legitimate purchasers (Art. 14).

- -> Does your battery meet removability and replaceability requirements?

### STEP 6: Does your battery meet removability and replaceability requirements?

*Reference: Art. 11, Art. 96(2)(a)*

- Article 11 applies from 18 Feb 2027 (Art. 96(2)(a)).
- Products incorporating portable batteries: batteries must be readily removable and replaceable by the end-user using commercially available tools (Art. 11(1)).
- Derogations: certain products can be designed so the portable battery is removable/replaceable only by independent professionals (Art. 11(2)); and Article 11 does not apply where continuity of power supply is necessary and a permanent connection is required for safety or data integrity reasons (Art. 11(3)).
- Products incorporating LMT batteries: LMT batteries and individual cells in the pack must be readily removable and replaceable by an independent professional (Art. 11(5)).
- Spare parts and software: portable and LMT batteries must be available as spare parts for at least five years, and software must not impede replacement (Art. 11(7)-(8)).

- -> Do you need a battery due diligence policy?

### STEP 7: Do you need a battery due diligence policy?

*Reference: Arts. 47-52*

- From 18 August 2025: economic operators that place batteries on the market or put them into service must set up and implement battery due diligence policies covering raw materials listed in Annex X (Arts. 48-50, 52).
- Chapter VII does not apply to economic operators with net turnover < EUR 40 million (and not part of a group exceeding EUR 40 million consolidated) (Art. 47).
- Based on OECD Due Diligence Guidance, UN Guiding Principles on Business and Human Rights, ILO standards.
- Policies are risk-based and cover the supply chain for the relevant raw materials and secondary raw materials.
- Does not apply (as a due diligence obligation) to batteries that were already placed on the market or put into service before being prepared for re-use/repurposed/repurposing/remanufactured (Art. 47).

- -> Which conformity assessment procedure applies?

### STEP 8: Which conformity assessment procedure applies?

*Reference: Arts. 17-20, Annex VIII-IX*

- Articles 6, 9, 10, 12, 13 and 14: conformity assessment is Module A (internal production control) or Module D1 (quality assurance of the production process) for series production; or Module A or Module G (unit verification) for non-series production (Art. 17(1), Annex VIII).
- Articles 7 and 8 (carbon footprint and recycled content): conformity assessment is Module D1 for series production or Module G for non-series production (Art. 17(2), Annex VIII).
- Repurposed/remanufactured and similar batteries: an additional conformity assessment is required using Module A, taking into account requirements in Articles 6, 9, 10, 12, 13 and 14 (Art. 17(3), Annex VIII).
- EU declaration of conformity: the manufacturer draws up the EU declaration of conformity; the model structure is in Annex IX (Art. 18).
- CE marking: affixed before the battery is placed on the market or put into service; where required, it is followed by the notified body identification number (Arts. 19-20).

- -> Are you subject to Extended Producer Responsibility (EPR)?

### STEP 9: Are you subject to Extended Producer Responsibility (EPR)?

*Reference: Arts. 55-60*

- Producers have extended producer responsibility for batteries they make available on the market for the first time in a Member State (Art. 56(1)).
- Producers must register in each relevant Member State register before placing batteries on that Member State market (Art. 55(2)).
- Producers finance key waste-management costs (separate collection, treatment, compositional surveys, information to end-users, and reporting/data gathering) (Art. 56(4)).
- Producers may fulfil EPR obligations collectively via a producer responsibility organisation (Art. 57).
- Collection and take-back obligations and targets apply for portable and LMT batteries (Arts. 59-60).

- -> Does your battery undergo repurposing or second life?

### STEP 10: Does your battery undergo repurposing or second life?

*Reference: Art. 3(30)-(32), Art. 13(9), Art. 17(3), Art. 38(11), Art. 73, Art. 77(7)*

- Preparation for repurposing applies to waste batteries (or parts) prepared for a different purpose than originally designed; repurposing applies to non-waste batteries (or parts) used for a different purpose; remanufacturing restores capacity and keeps the same purpose (Art. 3(30)-(32)).
- If you place on the market or put into service a battery that has been prepared for re-use/repurposing, repurposed or remanufactured, you are considered a manufacturer for the purposes of this Regulation (Art. 38(11)).
- An additional conformity assessment is required (Module A) for batteries that have undergone these operations, taking into account applicable requirements (Art. 17(3), Annex VIII).
- Batteries that have undergone these operations must bear new labels or markings, including change-of-status information accessible through the QR code (Art. 13(9)).
- For waste LMT/industrial/EV batteries prepared for re-use or prepared for repurposing, documentation is required to demonstrate that the battery is no longer waste; detailed technical requirements for ceasing to be waste may be set by implementing act (Art. 73).
- Battery passport responsibilities transfer to the operator placing the repurposed/remanufactured battery on the market, and a new passport is required (Art. 77(7)).

- **YES** Is it a portable battery?
- **NO** Is it a portable battery?

### STEP 11: Is it a portable battery?

*Reference: Art. 3(9)*

- Portable battery: sealed, weighs 5 kg or less, not designed specifically for industrial use, and neither an EV, LMT, nor SLI battery.

- **YES** Portable Battery Compliance
- **NO** Is it an LMT battery?

### STEP 12: Is it an LMT battery?

*Reference: Art. 3(11)*

- LMT battery: sealed, weighs 25 kg or less, designed to provide traction power for wheeled vehicles powered by an electric motor alone or by a combination of motor and human power (including category L vehicles), and not an EV battery.

- **YES** LMT Battery Compliance
- **NO** Is it an SLI battery?

### STEP 13: Is it an SLI battery?

*Reference: Art. 3(12)*

- SLI battery: designed to supply electric power for starting, lighting, or ignition and can also be used for auxiliary or backup purposes in vehicles, other means of transport or machinery.

- **YES** SLI Battery Compliance
- **NO** Is it an EV battery?

### STEP 14: Is it an EV battery?

*Reference: Art. 3(14)*

- EV battery: designed to provide traction power for hybrid or electric vehicles of category L (above 25 kg) or for hybrid or electric vehicles of categories M, N or O.

- **YES** EV Battery Compliance
- **NO** Industrial Battery Compliance

## Reference Information

### Battery Categories Overview

- Portable: sealed, 5 kg or less, not industrial and not EV/LMT/SLI (for example, consumer device batteries).
- LMT: sealed, 25 kg or less, traction for wheeled vehicles powered by motor alone or motor plus human power (including category L), and not an EV battery.
- SLI: starting, lighting and ignition, including auxiliary or backup uses.
- EV: traction for hybrid or electric vehicles (category L above 25 kg, or categories M/N/O).
- Industrial: designed for industrial uses, or any other battery above 5 kg that is neither EV/LMT/SLI.

### Carbon Footprint Requirements

- Applies to: EV batteries, rechargeable industrial batteries with capacity greater than 2 kWh, and LMT batteries (Art. 7).
- Carbon footprint declaration applies (earliest): EV from 18 Feb 2025; rechargeable industrial (except exclusively external storage) from 18 Feb 2026; LMT from 18 Aug 2028; rechargeable industrial with external storage from 18 Aug 2030 (Art. 7(1)).
- Carbon footprint performance class labelling applies (earliest): EV from 18 Aug 2026; rechargeable industrial (except exclusively external storage) from 18 Aug 2027; LMT from 18 Feb 2030; rechargeable industrial with external storage from 18 Feb 2032 (Art. 7(2)).
- Maximum life cycle carbon footprint threshold applies (earliest): EV from 18 Feb 2028; rechargeable industrial (except exclusively external storage) from 18 Feb 2029; LMT from 18 Aug 2031; rechargeable industrial with external storage from 18 Aug 2033 (Art. 7(3)).
- Declaration content includes: carbon footprint per kWh over expected service life; carbon footprint by life cycle stage; and a public web link to a supporting study (Art. 7(1)).
- These requirements do not apply to a battery that was already placed on the market or put into service before being prepared for re-use/repurposing/repurposed/remanufactured (Art. 7(5)).

### Recycled Content Requirements

- Applies to: industrial batteries over 2 kWh (except exclusively external storage), EV batteries, and SLI batteries that contain cobalt, lead, lithium or nickel in active materials; LMT batteries have later start dates for documentation and targets (Art. 8).
- Recycled content share documentation accompanies batteries (earliest): industrial/EV/SLI from 18 Aug 2028; LMT from 18 Aug 2033 (Art. 8(1)).
- Minimum recycled content shares (technical documentation) apply from 18 Aug 2031 for industrial/EV/SLI: cobalt 16%, lead 85%, lithium 6%, nickel 6% (Art. 8(2)).
- Increased minimum recycled content shares apply from 18 Aug 2036 for industrial/EV/LMT/SLI: cobalt 26%, lead 85%, lithium 12%, nickel 15% (Art. 8(3)).
- These requirements do not apply to batteries that were already placed on the market or put into service before being prepared for re-use/repurposing/repurposed/remanufactured (Art. 8(4)).

### Performance and Durability Requirements

- Portable batteries of general use: minimum values for electrochemical performance and durability parameters apply from 18 Aug 2028 (or later depending on delegated act timing) (Art. 9).
- Rechargeable industrial batteries over 2 kWh, LMT batteries and EV batteries: must be accompanied by a document with values for electrochemical performance and durability parameters (from 18 Aug 2024) (Art. 10(1), Annex IV).
- Minimum values: rechargeable industrial (except exclusively external storage) apply from 18 Aug 2027 (or later depending on delegated act timing); LMT apply from 18 Aug 2028 (or later depending on delegated act timing) (Art. 10(2)-(3), Art. 10(5)).
- Repurposed/remanufactured batteries: certain performance obligations do not apply if the battery was already placed on the market or put into service before the relevant obligation became applicable and the operator demonstrates that (Art. 10(4)).

### Labelling and Information

- From 18 Aug 2025: separate collection symbol marking applies to all batteries (Art. 13(4), Annex VI Part B).
- From 18 Aug 2026 (or later depending on implementing act timing): batteries must bear labels containing general information, and certain categories must bear capacity labels; non-rechargeable portable batteries also bear a minimum average duration label and a 'non-rechargeable' label (Art. 13(1)-(3), Art. 13(10)).
- From 18 Feb 2027: all batteries must be marked with a QR code. For LMT/industrial over 2 kWh/EV, the QR code gives access to the battery passport; for other batteries it gives access to applicable information including the EU declaration of conformity and required waste information; for SLI it also includes recovered materials information calculated in accordance with Art. 8 (Art. 13(6)).
- Batteries that have been prepared for re-use/repurposing/repurposed/remanufactured must bear new labels or markings and include change-of-status information accessible through the QR code (Art. 13(9), Annex XIII).
- State of health and expected lifetime data must be contained in the battery management system for stationary battery energy storage systems, LMT and EV batteries from 18 Aug 2024, with read-only access to purchasers and certain third parties (Art. 14, Annex VII).
- Accessibility: the Regulation highlights that labels and QR codes should be accessible to persons with disabilities (recital (44)).

### Battery Passport

- Required from 18 February 2027 for: EV batteries, LMT batteries, and industrial batteries with a capacity greater than 2 kWh (Art. 77).
- Information requirements are set out in Annex XIII and include battery model information and information specific to the individual battery, including resulting from use (Art. 77(2)).
- The battery passport is accessed through the QR code and a unique identifier attributed by the economic operator placing the battery on the market (Art. 77(3), Art. 13(6)(a)).
- Access is tiered (public, authorities/notified bodies/Commission, and legitimate-interest users) and is regulated under the essential requirements in Art. 78 and Annex XIII (Art. 77(2), Art. 77(6)).
- For batteries that have been prepared for re-use/repurposing/repurposed/remanufactured, responsibility for keeping passport information accurate and up to date transfers to the operator placing the battery on the market, and a new passport is required (Art. 77(7)).

### Removability and Replaceability

- Portable batteries (in products): readily removable by the end-user if they can be removed with commercially available tools and without requiring specialised tools (unless provided free of charge), proprietary tools, thermal energy, or solvents (Art. 11(1)).
- Instructions and safety information: products incorporating portable batteries must be accompanied with instructions and safety information on use, removal and replacement, and those instructions must be permanently available online (Art. 11(1)).
- Derogations and exclusions: certain water-exposed appliances and certain medical devices may allow removal only by independent professionals; and there is an exclusion where continuity of power supply requires permanent connection for safety or data integrity reasons (Art. 11(2)-(3)).
- LMT batteries: must be readily removable and replaceable by an independent professional; replacement must not affect functioning, performance or safety (Art. 11(5)-(6)).
- Spare parts availability and software: batteries must be available as spare parts for at least five years, and software must not be used to impede replacement (Art. 11(7)-(8)).

### Battery Due Diligence Policy

- Scope and exemptions: this Chapter does not apply to economic operators with net turnover < EUR 40 million (and not part of a group exceeding EUR 40 million consolidated) (Art. 47).
- Start date: from 18 August 2025, economic operators placing batteries on the market or putting them into service must set up and implement battery due diligence policies (Art. 48(1)).
- Due diligence covers raw materials listed in Annex X and associated social and environmental risk categories (Art. 49(1)(a)-(b) and Annex X).
- Core elements include a management system and supply-chain controls/traceability, risk assessment and mitigation, third-party verification by a notified body, and annual public reporting (Arts. 49-52 and 51).
- Recordkeeping: keep relevant documentation (including verification/audit reports) for 10 years after the last battery manufactured under the policy has been placed on the market (Art. 48(3)).

### Conformity Assessment and CE Marking

- Technical documentation: manufacturers draw up technical documentation and carry out the relevant conformity assessment procedure before placing a battery on the market or putting it into service (Art. 38(2), Annex VIII).
- Module A, Module D1, Module G: the Batteries Regulation uses Module A (internal production control), Module D1 (quality assurance of the production process) and Module G (unit verification) as set out in Annex VIII, depending on the requirements and whether production is in series (Art. 17(1)-(2)).
- EU declaration of conformity: states that compliance with the relevant requirements has been demonstrated; follows the model structure in Annex IX and includes elements specified in Annex VIII modules (Art. 18(1)-(2)).
- CE marking: affixed visibly, legibly and indelibly to the battery (or packaging/documents when not possible) before placing on the market or putting into service; may be followed by the notified body identification number where required (Art. 20).
- Notified bodies: required for certain modules; notified bodies are designated and monitored by Member States under Chapter V (Arts. 21-37).

### Extended Producer Responsibility (EPR)

- EPR obligation: producers have extended producer responsibility for batteries they make available on the market for the first time in a Member State (Art. 56(1)).
- Registration: producers register in each Member State where they first make batteries available; registration is a precondition for placing batteries on that Member State market (Art. 55(2)).
- Financed costs: separate collection and subsequent transport/treatment, compositional surveys (Art. 69(5)), information to end-users (Art. 74), and reporting/data gathering (Art. 75) (Art. 56(4)).
- Collective compliance: producers may appoint a producer responsibility organisation; Member States may mandate PRO appointment for certain categories (Art. 57(1)).
- Portable battery collection targets: 45% by 31 Dec 2023, 63% by 31 Dec 2027, and 73% by 31 Dec 2030 (Art. 59(3)).
- LMT battery collection targets: 51% by 31 Dec 2028 and 61% by 31 Dec 2031 (Art. 60(3)).

### Waste Battery Collection Targets

- Portable batteries collection targets: 45% by 31 Dec 2023; 63% by 31 Dec 2027; 73% by 31 Dec 2030 (Art. 59(3)).
- LMT batteries collection targets: 51% by 31 Dec 2028; 61% by 31 Dec 2031 (Art. 60(3)).
- SLI, industrial and EV batteries: producers (or producer responsibility organisations) must take back and ensure separate collection, free of charge and without an obligation to buy a new battery (Art. 61(1)).
- Collection systems must cover the whole territory of the Member State and may include collection points in cooperation with distributors, public authorities, and certain treatment facilities (Art. 59(2), Art. 60(2), Art. 61(1)-(2)).
- Distributors have take-back obligations for waste batteries from end-users (Art. 62(1)-(3)).
- Collection rates are calculated in accordance with Annex XI (Art. 59(3), Art. 60(3)).

### Recycling Efficiency and Material Recovery Targets

- Disposal and energy recovery are prohibited for collected waste batteries (Art. 70(1)).
- Treatment must comply, as a minimum, with Part A of Annex XII and best available techniques (Art. 70(2)).
- Recycling efficiency targets (Part B of Annex XII): by 31 Dec 2025, lead-acid 75%, nickel-cadmium 80%, lithium-based 65%, other 50%; by 31 Dec 2030, lead-acid 80% and lithium-based 70%.
- Material recovery targets (Part C of Annex XII): by 31 Dec 2027, cobalt/copper/lead/nickel 90% and lithium 50%; by 31 Dec 2031, cobalt/copper/lead/nickel 95% and lithium 80%.
- Permitted facilities must accept waste batteries and ensure they undergo preparation for re-use, preparation for repurposing or recycling (Art. 71(1)).
- Methodology and verification: the Commission must adopt a delegated act establishing calculation and verification methodology and documentation format (Art. 71(4)).
- Shipments: exported waste batteries count towards targets only if the exporter provides approved evidence of equivalent treatment conditions (Art. 72(3)).

### Repurposing and Second Life

- Definitions: preparation for repurposing (waste battery prepared for different purpose), repurposing (non-waste battery used for different purpose), and remanufacturing (restores capacity and keeps the same purpose) are defined in Art. 3(30)-(32).
- Economic operators that place on the market or put into service batteries that have undergone these operations are treated as manufacturers (Art. 38(11)).
- Conformity: an additional conformity assessment is required using Module A (Art. 17(3), Annex VIII).
- Labelling and marking: batteries that have undergone these operations must bear new labels or markings and include change-of-status information accessible through the QR code (Art. 13(9)).
- Waste batteries and ceasing-to-be-waste documentation: Article 73 sets documentation requirements for waste LMT/industrial/EV batteries prepared for re-use or prepared for repurposing and provides for an implementing act on detailed requirements for ceasing to be waste (Art. 73(1)-(4)).
- Battery passport: a new battery passport is required and responsibility for accuracy transfers to the operator placing the battery on the market after the operation (Art. 77(7)).

### Economic Operator Obligations

- Manufacturers: ensure compliance with applicable requirements, carry out conformity assessment, draw up EU declaration of conformity, affix CE marking, mark and label batteries, and keep documentation for 10 years (Art. 38(1)-(4)).
- Authorised representatives: perform tasks specified in the written mandate (for example, keep documentation available and cooperate with authorities) (Art. 40).
- Importers: verify that the manufacturer has carried out conformity assessment and drawn up documentation, ensure CE marking and required labelling, add importer contact details, and keep documentation available for 10 years (Art. 41).
- Distributors: act with due care and verify key compliance elements (including producer registration, CE marking and labelling) before making batteries available (Art. 42).
- Fulfilment service providers: ensure that warehousing/packaging/addressing/dispatching conditions do not jeopardise compliance (Art. 43).
- Repurposing and similar operations: operators placing on the market or putting into service batteries that have been prepared for re-use/repurposing, repurposed or remanufactured are considered manufacturers (Art. 38(11), Art. 45).

### Market Surveillance and Enforcement

- National procedure: where authorities believe a battery presents a risk, they evaluate compliance and can require corrective action, withdrawal or recall (Art. 79).
- Union safeguard procedure: for restrictive measures, the Commission evaluates and can adopt an implementing act determining whether the national measure is justified (Art. 80).
- Formal non-compliance: authorities can require operators to remedy certain administrative non-compliances (for example, missing CE marking or EU declaration of conformity) (Art. 83).
- Due diligence non-compliance: authorities can require due diligence compliance, and can restrict or prohibit batteries if non-compliance persists and is serious (Art. 84).
- Penalties: Member States establish effective, proportionate, dissuasive penalties; may include fines, product withdrawal, publication of infringement (Art. 93).
- Online platforms: certain providers must obtain producer registration details and self-certification from producers offering batteries to consumers (Art. 62(6)).
- Commission reviews: reports on Regulation application and impact every 5 years (Art. 94).

### Hazardous Substances Restrictions

- Restrictions are set out under Article 6 and Annex I (Restriction on substances).
- Mercury: batteries must not contain more than 0.0005% mercury by weight (Annex I).
- Cadmium: portable batteries must not contain more than 0.002% cadmium by weight (Annex I).
- Lead: from 18 Aug 2024, portable batteries must not contain more than 0.01% lead by weight; this restriction does not apply to portable zinc-air button cells until 18 Aug 2028 (Annex I).
- Marking: batteries containing more than 0.002% cadmium or more than 0.004% lead must be marked with Cd or Pb beneath the separate collection symbol (Art. 13(5)).
- The Commission can amend restrictions by delegated acts following a restriction dossier and assessment process (Art. 6(2)-(5)).

### Safety Requirements

- Stationary battery energy storage systems placed on the market or put into service must be safe during normal operation and use (Art. 12(1)).
- By 18 Aug 2024, technical documentation must demonstrate safety compliance and include evidence of successful testing for applicable safety parameters in Annex V, plus hazard assessment and mitigation instructions (Art. 12(2), Annex V).
- If a battery is prepared for re-use, prepared for repurposing, remanufactured or repurposed, the technical documentation must be reviewed (Art. 12(2)).
- Tests, measurements and calculations for certain requirements must use reliable, accurate and reproducible methods; harmonised standards and common specifications support presumption of conformity (Arts. 15-16).

### Reporting and Transparency Obligations

- Reporting to competent authorities: producers (and certain other actors) must report specified data on batteries and waste batteries, including amounts made available, collected and treated, within six months of the end of the reporting year (Art. 75(1)-(7)).
- Reporting to the Commission: Member States must make aggregated data publicly available and in the Commission format, and notify the Commission (Art. 76(1)-(5)).
- Due diligence disclosure: economic operators in scope must draw up and make publicly available a due diligence report (Art. 52).
- Battery passport accuracy: the operator placing the battery on the market must ensure passport information is accurate, complete and up to date (Art. 77(4)).
- Formats: the Commission adopts implementing acts for the reporting format to the Commission (Art. 76(5)).

## Possible Outcomes

### [PORTABLE] Portable Battery Compliance

Sealed, 5 kg or less, not industrial/EV/LMT/SLI

- Category definition: portable batteries are defined in Art. 3(9).
- Substance restrictions and labelling: restrictions are set out under Art. 6 and Annex I; labelling and marking requirements are in Art. 13.
- Performance and durability: portable batteries of general use are subject to minimum performance and durability values under Art. 9 (with parameters in Annex III and delegated act timing).
- Removability and replaceability: if you place products incorporating portable batteries on the market, Article 11 imposes removability/replaceability and related instructions and online information obligations (Art. 11; applies from 18 Feb 2027 via Art. 96(2)(a)).
- Conformity and CE marking: manufacturers carry out conformity assessment and issue the EU declaration of conformity, and affix CE marking where required (Arts. 17-20, Art. 38).
- EPR and collection targets: producers must register and fulfil extended producer responsibility obligations, including portable battery collection targets in Art. 59(3) (Arts. 55-62).
- Carbon footprint requirements in Art. 7 apply to EV, LMT and rechargeable industrial batteries over 2 kWh, not portable batteries.

### [LMT] LMT Battery Compliance

Sealed, 25 kg or less, traction for wheeled vehicles (not EV)

- Category definition: LMT batteries are defined in Art. 3(11).
- Carbon footprint: LMT batteries are in scope of Art. 7, with LMT-specific phased applicability dates (Art. 7(1)-(3)).
- Performance and durability: LMT batteries must be accompanied by performance and durability parameter values from 18 Aug 2024, and minimum values apply from 18 Aug 2028 (or later depending on delegated act timing) (Art. 10(1) and Art. 10(3)).
- Labelling and passport: separate collection symbol applies from 18 Aug 2025; QR code marking applies from 18 Feb 2027; and LMT batteries must have a battery passport from 18 Feb 2027 (Art. 13(4) and (6), Art. 77(1)).
- Removability: products incorporating LMT batteries must ensure removability and replaceability by an independent professional, plus spare parts and software requirements (Art. 11(5)-(8); applies from 18 Feb 2027 via Art. 96(2)(a)).
- EPR and collection targets: LMT collection targets are in Art. 60(3); distributors have take-back obligations under Art. 62 (Chapter VIII applies from 18 Aug 2025 via Art. 96(2)(c)).
- Due diligence: if you place batteries on the market or put them into service and you are in scope (including the turnover threshold), due diligence obligations apply from 18 Aug 2025 (Arts. 47-52).
- Conformity and CE marking: conformity assessment, EU declaration of conformity and CE marking requirements apply as relevant (Arts. 17-20, Annex VIII-IX, Art. 38).

### [SLI] SLI Battery Compliance

Starting, Lighting, Ignition

- Category definition: SLI batteries are defined in Art. 3(12).
- Recycled content: SLI batteries containing cobalt, lead, lithium or nickel in active materials are subject to recycled content documentation from 18 Aug 2028 and minimum recycled content shares from 18 Aug 2031 (Art. 8(1)-(2)).
- Labelling and QR code: separate collection symbol applies from 18 Aug 2025; QR code marking applies from 18 Feb 2027; and for SLI batteries the QR code provides access to recovered material information calculated in accordance with Art. 8 (Art. 13(4)-(6)).
- Conformity and CE marking: conformity assessment, EU declaration of conformity and CE marking requirements apply as relevant (Arts. 17-20, Annex VIII-IX, Art. 38).
- EPR and take-back: producers must take back and ensure separate collection of waste SLI batteries free of charge under Chapter VIII (Art. 61; Chapter VIII applies from 18 Aug 2025 via Art. 96(2)(c)).

### [EV] EV Battery Compliance

Traction batteries for certain L, M, N, O vehicles

- Category definition: EV batteries are defined in Art. 3(14).
- Carbon footprint: EV batteries are in scope of Art. 7, with EV-specific phased applicability dates (Art. 7(1)-(3)).
- Recycled content: EV batteries are in scope of Art. 8 recycled content documentation and targets (Art. 8(1)-(3)).
- Performance and durability: EV batteries must be accompanied by performance and durability parameter values from 18 Aug 2024 (Art. 10(1)).
- State of health and expected lifetime data: up-to-date parameters must be contained in the battery management system for EV batteries from 18 Aug 2024, with read-only access to purchasers and certain third parties (Art. 14).
- Labelling and passport: separate collection symbol applies from 18 Aug 2025; QR code marking applies from 18 Feb 2027; and EV batteries must have a battery passport from 18 Feb 2027 (Art. 13(4) and (6), Art. 77(1)).
- Due diligence: if you place batteries on the market or put them into service and you are in scope (including the turnover threshold), due diligence obligations apply from 18 Aug 2025 (Arts. 47-52).
- EPR and take-back: producers must take back and ensure separate collection of waste EV batteries free of charge under Chapter VIII (Art. 61; Chapter VIII applies from 18 Aug 2025 via Art. 96(2)(c)).
- Conformity and CE marking: conformity assessment, EU declaration of conformity and CE marking requirements apply as relevant (Arts. 17-20, Annex VIII-IX, Art. 38).

### [INDUSTRIAL] Industrial Battery Compliance

For industrial activities, energy storage, or >5 kg

- Category definition: industrial batteries are defined in Art. 3(13).
- If rechargeable and over 2 kWh: carbon footprint requirements apply under Art. 7 (with later dates for exclusively external storage), performance and durability information applies under Art. 10, and battery passport applies from 18 Feb 2027 (Art. 77(1)).
- Recycled content: industrial batteries over 2 kWh (except exclusively external storage) are in scope of Art. 8 recycled content documentation and targets (Art. 8(1)-(3)).
- Stationary battery energy storage systems: safety requirements apply under Art. 12 and state of health and expected lifetime data requirements apply under Art. 14 (where applicable).
- Labelling and QR code: separate collection symbol applies from 18 Aug 2025; general labels apply from 18 Aug 2026 (or later depending on implementing act timing); QR code marking applies from 18 Feb 2027 (Art. 13).
- Due diligence: if you place batteries on the market or put them into service and you are in scope (including the turnover threshold), due diligence obligations apply from 18 Aug 2025 (Arts. 47-52).
- EPR and take-back: producers must take back and ensure separate collection of waste industrial batteries free of charge under Chapter VIII (Art. 61; Chapter VIII applies from 18 Aug 2025 via Art. 96(2)(c)).
- Conformity and CE marking: conformity assessment, EU declaration of conformity and CE marking requirements apply as relevant (Arts. 17-20, Annex VIII-IX, Art. 38).

### [OUT OF SCOPE] Not Subject to Batteries Regulation

No batteries placed on EU market

- If you do not place batteries on the EU market or put them into service, this Regulation does not apply.
- Note: batteries incorporated into products (appliances, vehicles) are still covered when the product is placed on the market.
- The Regulation also excludes certain batteries incorporated into equipment connected with essential security interests and equipment designed to be sent into space (Art. 1(5)).
- Consider whether you may be indirectly affected via supply chain requirements from EU customers.

## EU Batteries Regulation Timeline

| Date | Event | Reference |
| --- | --- | --- |
| 2023-07-12 | Regulation adopted | Reg. (EU) 2023/1542 |
| 2023-07-28 | Published in Official Journal (OJ L 191) | Reg. (EU) 2023/1542 |
| 2023-08-17 | Entry into force (20 days after publication) | Art. 96(1) |
| 2024-02-18 | General application date (with phased provisions) | Art. 96(2) |
| 2024-08-18 | Article 17 and Chapter VI apply (conformity and economic operator obligations) | Art. 96(2)(b) |
| 2025-02-18 | Commission deadline to publish due diligence guidelines | Art. 48(5) |
| 2025-08-18 | Directive 2006/66/EC repealed; Chapter VIII (waste batteries) applies; due diligence obligations start | Art. 95, Art. 96(2)(c), Art. 48(1) |
| 2025-08-18 | Separate collection symbol marking applies | Art. 13(4) |
| 2026-08-18 | General labelling and capacity labels apply (earliest) | Art. 13(1)-(3) |
| 2027-02-18 | QR code marking and battery passport start; removability applies | Art. 13(6), Art. 77(1), Art. 11 (via Art. 96(2)(a)) |
| 2028-08-18 | Recycled content documentation starts (industrial, EV, SLI; LMT later) | Art. 8(1) |
| 2031-08-18 | Mandatory minimum recycled content targets start (industrial, EV, SLI; LMT later) | Art. 8(2) |

## Compliance Timeline

| Date | Event | Category | Reference |
| --- | --- | --- | --- |
| 2006-09-06 | Batteries Directive (2006/66/EC) adopted | Legislative Milestones |  |
| 2006-09-26 | Batteries Directive (2006/66/EC) published in the Official Journal (OJ L 266) | Legislative Milestones |  |
| 2023-07-12 | EU Batteries Regulation (EU) 2023/1542 adopted | Legislative Milestones |  |
| 2023-07-28 | EU Batteries Regulation published in the Official Journal | Legislative Milestones |  |
| 2023-08-17 | EU Batteries Regulation enters into force | Legislative Milestones |  |
| 2024-02-18 | EU Batteries Regulation applies (general application date) | Legislative Milestones |  |
| 2024-04-17 | Corrigendum published (EU Batteries Regulation) | Legislative Milestones |  |
| 2024-08-18 | Article 17 and Chapter VI apply | Legislative Milestones |  |
| 2025-02-18 | Carbon footprint declaration starts (earliest) for EV batteries | Carbon Footprint |  |
| 2025-07-04 | Commission news: Delegated Regulation (EU) 2025/606 on recycling efficiency and material recovery | Recycling & Recovery |  |
| 2025-07-24 | Recycling methodology enters into force | Recycling & Recovery |  |
| 2025-08-18 | Chapter VIII applies | Legislative Milestones |  |
| 2025-10-08 | Corrigendum published (EU Batteries Regulation) | Legislative Milestones |  |
| 2025-11-19 | Commission technical support report published | Legislative Milestones |  |
| 2025-12-31 | Recycling efficiency targets due (Annex XII) | Recycling & Recovery |  |
| 2026-02-18 | Carbon footprint declaration starts (earliest) for rechargeable industrial batteries | Carbon Footprint |  |
| 2026-08-18 | Carbon footprint performance class labelling starts (earliest) for EV batteries | Carbon Footprint |  |
| 2027-02-18 | Article 11 applies | Legislative Milestones |  |
| 2027-02-18 | Battery passport requirement starts | Battery Passport |  |
| 2027-12-31 | Material recovery targets start (Annex XII) | Recycling & Recovery |  |
| 2028-02-18 | Maximum life cycle carbon footprint threshold starts (earliest) for EV batteries | Carbon Footprint |  |
| 2028-08-18 | Carbon footprint declaration starts (earliest) for LMT batteries | Carbon Footprint |  |
| 2028-08-18 | Recycled content disclosure documentation starts (industrial, EV, SLI) | Recycled Content |  |
| 2029-02-18 | Maximum life cycle carbon footprint threshold starts (earliest) for rechargeable industrial batteries | Carbon Footprint |  |
| 2030-02-18 | Carbon footprint performance class labelling starts (earliest) for LMT batteries | Carbon Footprint |  |
| 2030-08-18 | Carbon footprint declaration starts (earliest) for rechargeable industrial batteries with external storage | Carbon Footprint |  |
| 2030-12-31 | Increased recycling efficiency targets due (Annex XII) | Recycling & Recovery |  |
| 2031-08-18 | Maximum life cycle carbon footprint threshold starts (earliest) for LMT batteries | Carbon Footprint |  |
| 2031-08-18 | Mandatory minimum recycled content targets start (industrial, EV, SLI) | Recycled Content |  |
| 2031-12-31 | Increased material recovery targets due (Annex XII) | Recycling & Recovery |  |
| 2032-02-18 | Carbon footprint performance class labelling starts (earliest) for rechargeable industrial batteries with external storage | Carbon Footprint |  |
| 2033-08-18 | Maximum life cycle carbon footprint threshold starts (earliest) for rechargeable industrial batteries with external storage | Carbon Footprint |  |
| 2033-08-18 | Recycled content disclosure documentation starts (LMT batteries) | Recycled Content |  |
| 2036-08-18 | Increased mandatory recycled content targets start | Recycled Content |  |

**Event details:**

- **2006-09-06 - Batteries Directive (2006/66/EC) adopted**: Date of Directive 2006/66/EC of the European Parliament and of the Council: 6 September 2006.
- **2006-09-26 - Batteries Directive (2006/66/EC) published in the Official Journal (OJ L 266)**: Official Journal reference for Directive 2006/66/EC: OJ L 266, 26.9.2006, p. 1.
- **2023-07-12 - EU Batteries Regulation (EU) 2023/1542 adopted**: Date of the Regulation: of 12 July 2023.
- **2023-07-28 - EU Batteries Regulation published in the Official Journal**: Official Journal of the European Union date: 28.7.2023.
- **2023-08-17 - EU Batteries Regulation enters into force**: Entry into force: 20 days after publication in the Official Journal (published 28 July 2023).
- **2024-02-18 - EU Batteries Regulation applies (general application date)**: General application date: 18 February 2024 (with specific phased provisions).
- **2024-04-17 - Corrigendum published (EU Batteries Regulation)**: Corrigendum dated 17 April 2024 (Official Journal corrigendum entry for Regulation (EU) 2023/1542).
- **2024-08-18 - Article 17 and Chapter VI apply**: From 18 August 2024, Article 17 and Chapter VI apply (per phased application rules).
- **2025-02-18 - Carbon footprint declaration starts (earliest) for EV batteries**: Earliest: 18 February 2025 for EV batteries (or later depending on delegated and implementing acts).
- **2025-07-04 - Commission news: Delegated Regulation (EU) 2025/606 on recycling efficiency and material recovery**: 4 July 2025: Commission news announcing Delegated Regulation (EU) 2025/606 on calculating and verifying recycling efficiency and recovery of materials from waste batteries.
- **2025-07-24 - Recycling methodology enters into force**: The newly established methodology will enter into force on 24 July 2025.
- **2025-08-18 - Chapter VIII applies**: From 18 August 2025, Chapter VIII applies (per phased application rules).
- **2025-10-08 - Corrigendum published (EU Batteries Regulation)**: Corrigendum dated 8 October 2025 (Official Journal corrigendum entry for Regulation (EU) 2023/1542).
- **2025-11-19 - Commission technical support report published**: General publications: 19 November 2025 (Task 1 Report - technical support for delegated acts and Commission reports).
- **2025-12-31 - Recycling efficiency targets due (Annex XII)**: No later than 31 December 2025, recycling efficiency targets apply: 75% lead-acid, 65% lithium-based, 80% nickel-cadmium, 50% other waste batteries.
- **2026-02-18 - Carbon footprint declaration starts (earliest) for rechargeable industrial batteries**: Earliest: 18 February 2026 for rechargeable industrial batteries (except those with exclusively external storage), or later depending on delegated and implementing acts.
- **2026-08-18 - Carbon footprint performance class labelling starts (earliest) for EV batteries**: Earliest: 18 August 2026 for EV batteries, or later depending on delegated and implementing acts.
- **2027-02-18 - Article 11 applies**: From 18 February 2027, Article 11 applies (per phased application rules).
- **2027-02-18 - Battery passport requirement starts**: From 18 February 2027, each LMT battery, each industrial battery over 2 kWh, and each EV battery must have a battery passport.
- **2027-12-31 - Material recovery targets start (Annex XII)**: No later than 31 December 2027, recovery targets apply: 90% cobalt/copper/lead/nickel and 50% lithium.
- **2028-02-18 - Maximum life cycle carbon footprint threshold starts (earliest) for EV batteries**: Earliest: 18 February 2028 for EV batteries, or later depending on delegated acts setting thresholds.
- **2028-08-18 - Carbon footprint declaration starts (earliest) for LMT batteries**: Earliest: 18 August 2028 for LMT batteries, or later depending on delegated and implementing acts.
- **2028-08-18 - Recycled content disclosure documentation starts (industrial, EV, SLI)**: From 18 August 2028, industrial batteries over 2 kWh (except exclusively external storage), EV batteries and SLI batteries must be accompanied by recycled content share documentation (for cobalt, lead, lithium, nickel in active materials).
- **2029-02-18 - Maximum life cycle carbon footprint threshold starts (earliest) for rechargeable industrial batteries**: Earliest: 18 February 2029 for rechargeable industrial batteries (except exclusively external storage), or later depending on delegated acts setting thresholds.
- **2030-02-18 - Carbon footprint performance class labelling starts (earliest) for LMT batteries**: Earliest: 18 February 2030 for LMT batteries, or later depending on delegated and implementing acts.
- **2030-08-18 - Carbon footprint declaration starts (earliest) for rechargeable industrial batteries with external storage**: Earliest: 18 August 2030 for rechargeable industrial batteries with external storage, or later depending on delegated and implementing acts.
- **2030-12-31 - Increased recycling efficiency targets due (Annex XII)**: No later than 31 December 2030, recycling efficiency targets increase to 80% lead-acid and 70% lithium-based.
- **2031-08-18 - Maximum life cycle carbon footprint threshold starts (earliest) for LMT batteries**: Earliest: 18 August 2031 for LMT batteries, or later depending on delegated acts setting thresholds.
- **2031-08-18 - Mandatory minimum recycled content targets start (industrial, EV, SLI)**: From 18 August 2031, batteries in scope must meet minimum recycled content shares in active materials (including cobalt, lead, lithium, nickel) as part of technical documentation.
- **2031-12-31 - Increased material recovery targets due (Annex XII)**: No later than 31 December 2031, recovery targets increase to 95% cobalt/copper/lead/nickel and 80% lithium.
- **2032-02-18 - Carbon footprint performance class labelling starts (earliest) for rechargeable industrial batteries with external storage**: Earliest: 18 February 2032 for rechargeable industrial batteries with external storage, or later depending on delegated and implementing acts.
- **2033-08-18 - Maximum life cycle carbon footprint threshold starts (earliest) for rechargeable industrial batteries with external storage**: Earliest: 18 August 2033 for rechargeable industrial batteries with external storage, or later depending on delegated acts setting thresholds.
- **2033-08-18 - Recycled content disclosure documentation starts (LMT batteries)**: From 18 August 2033, LMT batteries in scope must be accompanied by recycled content share documentation (for cobalt, lead, lithium, nickel in active materials).
- **2036-08-18 - Increased mandatory recycled content targets start**: From 18 August 2036, increased minimum recycled content shares apply (including higher cobalt, lithium, and nickel targets).


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