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. For waste work, Chapter VIII applies from 18 August 2025.

Several compliance dates are not simple fixed dates. They apply on the listed date or after a delegated or implementing act has entered into force, whichever is later. Treat those items as dependency-managed workstreams, not as ordinary calendar reminders.

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.

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.

The Commission's 2025 notice should be used as interpretation support, not as a substitute for the article. Calendar owners should track product scope, whether an Article 11 derogation is being relied on, instructions and safety information, spare-part availability, and any software restriction 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.

Use this track for producer registration, EPR authorisation, free take-back, collection infrastructure, treatment routing, recycling-efficiency evidence, recovery-of-materials evidence, end-user information, and competent-authority reporting.