EU Batteries Regulation deadlines and compliance calendar

Start the calendar with the Regulation-wide dates before assigning product-category workstreams. The Batteries Regulation entered into force on 17 August 2023, applies from 18 February 2024 unless a specific provision says otherwise, and repeals Directive 2006/66/EC with effect from 18 August 2025.

For market-placement work, Article 17 and Chapter VI apply from 18 August 2024, except Article 17(2), which applies 12 months after the first publication of the notified-body list. Chapter VIII and its producer, registration, take-back, collection, treatment, and reporting framework apply from 18 August 2025. By the same date, Member States had to establish and implement their Article 93 penalty rules.

Several compliance dates are not fixed. They apply on the listed date or after a specified waiting period following the entry into force of a delegated or implementing act, whichever is later. The waiting period is not uniform: Article 7 uses 12 or 18 months depending on the obligation and battery category, Article 8(1) uses 24 months, and Article 13 uses 18 months.

Track the legal act, entry-into-force date, affected battery category, calculation or label format, and the later-of application rule. Where an act is still a draft or support document, label it as such and do not treat it as a final compliance method.

Do not use the original 18 August 2025 date for Chapter VII. Regulation (EU) 2025/1561 entered into force on 31 July 2025 and postponed the obligation date for in-scope economic operators to 18 August 2027.

The amendment also moved the Commission-guidance deadline to 26 July 2026. A policy, supplier questionnaire, traceability exercise, or notified-body discussion completed earlier is readiness work; it should not be described as evidence that Chapter VII was already applicable.

The QR-code and passport clocks should be managed together but not merged. Article 13(6) sets the QR marking date for all batteries; Article 77 sets the electronic battery passport obligation for LMT batteries, industrial batteries above 2 kWh, and electric vehicle batteries.

Passport readiness should include the unique identifier, access-right design, public and restricted data split, update responsibility, and continuity of access if the responsible operator ceases activity in the Union.

Article 11 is a separate product-design clock. It applies from 18 February 2027 and covers products incorporating portable batteries and products incorporating LMT batteries, with different user and professional-removal expectations.

Use Commission Notice C(2026) 5032 final, dated 14 July 2026, as interpretation support for Article 11. The Commission also adopted additional portable-battery derogations on that date; its announcement makes entry into force conditional on scrutiny and Official Journal publication. Before relying on an added category, record the published act and its entry-into-force date. Calendar owners should also record instructions and safety information, spare-part availability, and software restrictions that could impede compatible battery replacement.

Carbon-footprint obligations under Article 7 move through three steps: declaration, performance class, and maximum threshold. Recycled-content obligations under Article 8 move from documentation to minimum shares. Keep both tracks tied to battery category and to whether a required delegated or implementing act has entered into force.

For carbon-footprint work, maintain the battery model, manufacturing plant, life-cycle stage breakdown, EU declaration of conformity identifier, and public study link. For recycled content, maintain the battery model, year, manufacturing plant, covered materials, calculation method, and technical-documentation evidence.

Waste obligations should sit in a separate calendar because they involve producers, producer responsibility organisations, distributors, waste management operators, treatment facilities, recyclers, and Member State competent authorities. Chapter VIII starts on 18 August 2025, while collection and recycling targets use later year-end milestones.

This track supports producer registration in every Member State where the producer first makes batteries available, EPR authorisation, free take-back, collection infrastructure, treatment routing, recycling-efficiency evidence, recovery-of-materials evidence, end-user information, and competent-authority reporting. Commission Implementing Regulation (EU) 2025/2289 now supplies the reporting tables and quality-check format.