EU Batteries RegulationChecklist

EU Batteries Regulation (Regulation (EU) 2023/1542) Compliance checklist

The useful checklist is the one that produces evidence, not slogans.

This version is organized around the artifacts and controls most often requested by customers, authorities, and notified bodies.

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Author

Sorena AI

Published

Feb 21, 2026

Updated

Feb 21, 2026

Sections

Structured answer sets in this page tree.

Primary sources

Cited legal and guidance references.

Publication metadata

Sorena AI

Published Feb 21, 2026

Updated Feb 21, 2026

Overview

Use this checklist per battery model and, where relevant, per manufacturing plant. The Batteries Regulation combines product rules, lifecycle data, waste duties, and due diligence in one regime. The easiest way to implement it is to track one evidence list with category specific routes.

Section 1

Category and scope controls

Everything starts with classification. Make sure the legal category and role are fixed before you build labels, passports, or due diligence claims.

This is also where you capture whether the battery is incorporated into a product and who owns the battery specific compliance artifacts.

Battery model register complete with category, intended use, weight, capacity, and plant.
Role matrix complete for manufacturer, importer, producer, distributor, repurposer, and remanufacturer where relevant.
Date matrix for Article 7, Article 11, Article 13, Article 14, Article 48, Article 59, Article 60, and Article 77 as applicable.
Review triggers recorded for redesign, repurposing, new suppliers, and new markets.

Section 2

Product, label, and QR controls

The label set is phased. The separate collection symbol applies from 18 August 2025. The broader labels under Article 13 paragraphs 1 to 3 apply from 18 August 2026 or 18 months after the implementing act, whichever is later. The QR code applies from 18 February 2027.

Use one controlled label library tied to model data and QR destinations.

Separate collection symbol implemented and sized correctly where required.
Capacity, non rechargeable, and other label rules applied by category.
Chemical symbols Cd and Pb added where thresholds are exceeded.
QR resolution tested and linked to the correct public and restricted destinations.

Section 3

Battery passport and state of health controls

LMT, EV, and industrial batteries above 2 kWh need battery passports from 18 February 2027. Stationary battery energy storage systems, LMT batteries, and EV batteries need Article 14 state of health and expected lifetime data in the battery management system from 18 August 2024.

These are operational systems, not paperwork fields.

Passport schema and access control aligned to Annex XIII.
Unique identifier and QR linkage in place.
Article 14 state of health data accessible on a read only basis to the permitted actors.
Status change workflow and linked new passport process for repurposed and remanufactured batteries.

Section 4

Carbon footprint and recycled content controls

Article 7 and Article 8 require plant specific evidence. Carbon footprint declarations and later recycled content documentation should therefore be handled per battery model per manufacturing plant, not only at product family level.

The timing and coverage are category specific, so the checklist should point to the relevant date for each model.

Article 7 declaration workflow live for the relevant category and date.
Performance class and threshold planning tracked where not yet in force.
Article 8 disclosure and minimum share roadmap tracked by category and material.
Annex VIII technical documentation updated with the supporting evidence.

Section 5

Due diligence and supplier controls

From 18 August 2025, the due diligence chapter becomes live. Operators need a due diligence policy, management system, traceability, risk assessment and mitigation, third party verification by a notified body, annual public reporting, and long retention of evidence.

Supplier evidence is the bottleneck, so the checklist should cover onboarding, contracts, verification, and remediation.

Battery due diligence policy approved and published.
Supplier traceability data and risk assessments collected.
Notified body verification and periodic audit route in place.
Annual public report and downstream information sharing process in place.
Ten year retention policy applied to due diligence records.

Section 6

Waste battery, collection, and reporting controls

Producer responsibility and waste duties are not secondary tasks. Portable and LMT collection systems, collection targets, treatment, and reporting all need named owners and Member State specific execution.

Portable batteries must hit 45 percent by 31 December 2023, 63 percent by 31 December 2027, and 73 percent by 31 December 2030. LMT batteries must hit 51 percent by 31 December 2028 and 61 percent by 31 December 2031.

Producer registrations and authorizations completed where required.
Portable and LMT collection networks documented and funded.
Recycler and treatment contracts aligned to Article 70 and Annex XII requirements.
Reporting process aligned to the Commission implementing format and local authority expectations.

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