--- title: "EU Batteries Regulation FAQ" canonical_url: "https://www.sorena.io/artifacts/eu/batteries-regulation/faq" source_url: "https://www.sorena.io/artifacts/eu/batteries-regulation/faq/items/page/2" author: "Sorena AI" description: "Answers to practical EU Batteries Regulation questions on battery categories, CE conformity, QR labels, battery passports, due diligence, removability, and waste collection duties." published_at: "2026-05-09" updated_at: "2026-05-09" keywords: - "EU Batteries Regulation" - "Regulation (EU) 2023/1542 FAQ" - "battery categories" - "CE marking batteries" - "battery QR code" - "battery passport" - "battery due diligence" - "removable batteries" - "producer responsibility" - "waste batteries" - "Batteries Regulation" - "CE conformity" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # EU Batteries Regulation FAQ Answers to practical EU Batteries Regulation questions on battery categories, CE conformity, QR labels, battery passports, due diligence, removability, and waste collection duties. *FAQ* *Batteries Regulation* *EU* ## EU Batteries Regulation FAQ scope, labels, passports, due diligence, and waste Direct answers for teams placing batteries, battery packs, or battery-powered products on the EU market. The focus is on category routing, conformity evidence, QR and passport data, supply-chain due diligence, removability, and producer responsibility. Regulation (EU) 2023/1542 applies across the battery life cycle: placing batteries on the EU market, proving conformity, providing labels and digital information, managing raw-material due diligence, designing removable or replaceable batteries where required, and financing collection and treatment of waste batteries. ## Browse sub-FAQ modules ### [EU Batteries Regulation Article 11 removability FAQ](/artifacts/eu/batteries-regulation/faq/removability-and-replaceability.md) FAQ on Article 11 removability and replaceability duties for portable and LMT batteries, including end-user removal, professional replacement, spares, software, and evidence. - 6 items ### [EU Batteries Regulation Article 8 recycled content calculation FAQ](/artifacts/eu/batteries-regulation/faq/recycled-content-calculation.md) FAQ on Article 8 recycled content calculations for EU Batteries Regulation battery models, materials, thresholds, documentation, and delegated methodology status. - 5 items ### [EU Batteries Regulation battery passport fields FAQ](/artifacts/eu/batteries-regulation/faq/battery-passport-fields.md) FAQ on Article 77 and Annex XIII battery passport field groups, public and restricted access, QR codes, unique identifiers, and model versus individual battery data. - 4 items ### [EU Batteries Regulation category routing FAQ: portable, LMT, SLI, EV and industrial batteries](/artifacts/eu/batteries-regulation/faq/category-routing.md) FAQ guidance for routing batteries under Regulation (EU) 2023/1542 across portable, LMT, SLI, EV and industrial categories, including incorporated batteries and obligation checks. - 5 items ### [EU Batteries Regulation due diligence threshold FAQ](/artifacts/eu/batteries-regulation/faq/due-diligence-thresholds.md) FAQ on the EU Batteries Regulation Chapter VII due diligence threshold, Article 47 exclusions, Annex X raw materials, and verification and disclosure records. - 4 items ### [EU Batteries Regulation economic operator roles FAQ](/artifacts/eu/batteries-regulation/faq/economic-operator-roles.md) FAQ on manufacturer, importer, distributor, fulfilment service provider, producer, and second-life operator roles under Regulation (EU) 2023/1542. - 5 items ### [EU Batteries Regulation NANDO and notified bodies FAQ](/artifacts/eu/batteries-regulation/faq/nando.md) When notified bodies matter under the EU Batteries Regulation, how to use the Single Market Compliance Space/NANDO lookup, and what scope evidence to retain. - 4 items ### [EU Batteries Regulation QR code and label timing FAQ](/artifacts/eu/batteries-regulation/faq/qr-and-label-timing.md) FAQ on Article 13 battery labels, the 18 February 2027 QR code rule, battery passport access, and Commission act dependencies under Regulation (EU) 2023/1542. - 4 items ### [EU Batteries Regulation: CE Marking FAQ](/artifacts/eu/batteries-regulation/faq/ce-and-conformity-assessment.md) FAQ on Article 17 conformity assessment, Annex VIII modules, EU declarations of conformity, CE marking, notified bodies, and importer and distributor checks under Regulation (EU) 2023/1542. - 5 items ### [EU Batteries Regulation: Waste Collection FAQ](/artifacts/eu/batteries-regulation/faq/waste-collection-and-recycling-reporting.md) FAQ on EU Batteries Regulation waste battery collection, producer registration, free take-back, collection targets, recycling, and reporting evidence. - 6 items ### [FAQ: EU Batteries Regulation carbon footprint performance classes](/artifacts/eu/batteries-regulation/faq/carbon-footprint-classes.md) FAQ on Article 7 carbon footprint declarations, performance classes, maximum-threshold sequencing, covered battery categories, and delegated-act dependencies. - 5 items Browse all indexed questions: [/artifacts/eu/batteries-regulation/faq/items](/artifacts/eu/batteries-regulation/faq/items.md) ## All FAQ items *Page 2 of 3. Showing 20 of 53 items.* ### [When does Article 47 keep an operator outside Chapter VII battery due diligence?](/artifacts/eu/batteries-regulation/faq/due-diligence-thresholds.md#when-does-article-47-keep-an-operator-outside-chapter-vii-battery-due-diligence) *Module: [EU Batteries Regulation due diligence threshold](/artifacts/eu/batteries-regulation/faq/due-diligence-thresholds.md)* Article 47 says Chapter VII does not apply to economic operators that had net turnover below EUR 40 million in the financial year preceding the last financial year, provided they are not part of a parent-subsidiary group whose consolidated turnover exceeds EUR 40 million. - Run the turnover check at economic-operator level, then check whether group consolidation pushes the operator above EUR 40 million. - Treat the reuse, repurposing, and remanufacturing exclusion as battery-specific: it depends on whether the batteries were already placed on the market or put into service before the operation. - Do not use an Article 47 out-of-scope result to dismiss other Batteries Regulation duties, such as product, labelling, producer responsibility, or waste-battery requirements. Sources for this answer: - [Regulation (EU) 2023/1542, Article 47](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Article 47 is the source for the Chapter VII net-turnover threshold, group consolidation test, and reuse, repurposing, remanufacturing exclusion. - [EUR-Lex summary of Regulation (EU) 2023/1542](https://eur-lex.europa.eu/EN/legal-content/summary/sustainability-rules-for-batteries-and-waste-batteries.html?ref=sorena.io) - EUR-Lex explains the wider Regulation scope, which is broader than the Chapter VII due diligence threshold. ### [Which batteries and raw materials matter if Chapter VII applies?](/artifacts/eu/batteries-regulation/faq/due-diligence-thresholds.md#which-batteries-and-raw-materials-matter-if-chapter-vii-applies) *Module: [EU Batteries Regulation due diligence threshold](/artifacts/eu/batteries-regulation/faq/due-diligence-thresholds.md)* Once Chapter VII applies, Article 48 focuses on economic operators that place batteries on the market or put them into service. Those operators must set up and implement battery due diligence policies covering the Article 49 management-system duties, Article 50 risk-management duties, and Article 52 disclosure duties. - Map battery models and categories that are placed on the market or put into service by the operator. - Identify whether cobalt, natural graphite, lithium, nickel, or covered chemical compounds are present in the battery supply chain. - Connect the materials review to sourcing, processing, and trading risks rather than treating the threshold as a one-time finance-only check. Sources for this answer: - [Regulation (EU) 2023/1542, Articles 48-50 and Annex X](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Articles 48-50 define the operator duties after Chapter VII applies; Annex X lists the covered raw materials and risk categories. - [European Commission Batteries Regulation entry-into-force article](https://environment.ec.europa.eu/news/new-law-more-sustainable-circular-and-safe-batteries-enters-force-2023-08-17_en?ref=sorena.io) - The Commission describes due diligence as addressing risks linked to sourcing, processing, and trading of lithium, cobalt, nickel, and natural graphite. ### [What evidence should support the threshold decision?](/artifacts/eu/batteries-regulation/faq/due-diligence-thresholds.md#what-evidence-should-support-the-threshold-decision) *Module: [EU Batteries Regulation due diligence threshold](/artifacts/eu/batteries-regulation/faq/due-diligence-thresholds.md)* Keep enough evidence to show why Chapter VII was treated as in scope or out of scope. For the Article 47 turnover route, that means the operator's net turnover for the relevant financial year and whether it is part of a consolidated parent-subsidiary group above EUR 40 million. - Turnover evidence: signed finance source, financial year used, group consolidation conclusion, and approver. - Battery exclusion evidence: original market-placement or put-into-service record and the later reuse, repurposing, or remanufacturing operation record. - Materials evidence: bill of materials or supplier declaration for cobalt, natural graphite, lithium, nickel, and covered compounds. - Supply-chain evidence: supplier identity, country of origin, transaction trail, raw-material quantities, and relevant third-party verification reports where Article 49 requires them. - Retention evidence: Chapter VII documentation, verification reports, approval decisions, and audit reports kept for the period required by Article 48. Sources for this answer: - [Regulation (EU) 2023/1542, Articles 47-49](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Articles 47-49 support the threshold record, raw-material traceability data, supplier information, origin information, quantities, and management-system records. ### [What is the verification and disclosure route after the threshold is met?](/artifacts/eu/batteries-regulation/faq/due-diligence-thresholds.md#what-is-the-verification-and-disclosure-route-after-the-threshold-is-met) *Module: [EU Batteries Regulation due diligence threshold](/artifacts/eu/batteries-regulation/faq/due-diligence-thresholds.md)* If Chapter VII applies, the operator's battery due diligence policy must be verified by a notified body and periodically audited. Article 51 says third-party verification covers the activities, processes, and systems used to meet Articles 49, 50, and 52, and results in a verification report; an approval decision is issued when the policy fulfils the relevant duties. - Verification route: notified-body verification, report, approval decision where applicable, and periodic audit. - Authority route: make verification, approval, audit, and recognised-scheme evidence available to market surveillance or national authorities when requested. - Customer route: provide immediate downstream purchasers with relevant due diligence information, subject to business confidentiality and competitive concerns. - Public route: annually review and publish the battery due diligence policy report, including significant adverse impacts and how they were addressed. - Recycled-source route: publicly disclose conclusions in reasonable detail when Annex X raw materials in the battery are demonstrated to come from recycled sources. Sources for this answer: - [Regulation (EU) 2023/1542, Articles 48, 51 and 52](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Articles 48, 51, and 52 support the notified-body verification, audit, record-retention, authority disclosure, downstream disclosure, annual public report, and recycled-source disclosure routes. - [EUR-Lex summary of Regulation (EU) 2023/1542](https://eur-lex.europa.eu/EN/legal-content/summary/sustainability-rules-for-batteries-and-waste-batteries.html?ref=sorena.io) - EUR-Lex summarises the due diligence purpose as identifying, preventing, and addressing social and environmental raw-material risks. ### [Who counts as an economic operator under the EU Batteries Regulation?](/artifacts/eu/batteries-regulation/faq/economic-operator-roles.md#who-counts-as-an-economic-operator-under-the-eu-batteries-regulation) *Module: [EU Batteries Regulation economic operator roles](/artifacts/eu/batteries-regulation/faq/economic-operator-roles.md)* An economic operator is not only the original battery maker. The Regulation includes manufacturers, authorised representatives, importers, distributors, fulfilment service providers, and other persons with obligations linked to manufacturing, preparation for re-use, preparation for repurposing, repurposing, remanufacturing, making batteries available, placing batteries on the market, online supply, or putting batteries into service. - Manufacturer: designs or manufactures a battery, has one designed or manufactured, and markets it under its own name or trademark or puts it into service for its own purposes. - Authorised representative: an EU-established person with a written mandate from the manufacturer for specified Batteries Regulation tasks. - Importer: an EU-established person that places a battery from a third country on the Union market. - Distributor: a supply-chain actor, other than the manufacturer or importer, that makes a battery available on the market. - Producer: a manufacturer, importer, distributor, distance seller, or other person that first supplies batteries in a Member State or sells directly to end-users there under the producer definition. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries and waste batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Article 3 defines economic operator, manufacturer, authorised representative, importer, distributor, producer, and the market-placement terms used to assign roles. - [EUR-Lex summary: sustainability rules for batteries and waste batteries](https://eur-lex.europa.eu/EN/legal-content/summary/sustainability-rules-for-batteries-and-waste-batteries.html?ref=sorena.io) - The summary confirms the Regulation's lifecycle coverage and producer collection responsibilities in plain language. ### [What does each product-compliance role need to check before batteries are supplied?](/artifacts/eu/batteries-regulation/faq/economic-operator-roles.md#what-does-each-product-compliance-role-need-to-check-before-batteries-are-supplied) *Module: [EU Batteries Regulation economic operator roles](/artifacts/eu/batteries-regulation/faq/economic-operator-roles.md)* The manufacturer owns the core product-compliance file. Before placing a battery on the market or putting it into service, the manufacturer must address the applicable design, sustainability, safety, labelling, information, technical documentation, conformity assessment, EU declaration of conformity, CE marking, identification, contact-detail, battery-management-system data, corrective-action, authority-cooperation, and record-retention duties. - Authorised representative: keep the mandated conformity and due diligence records available to authorities, respond to reasoned authority requests, cooperate on risk elimination, and immediately inform authorities where the battery presents a risk. - Importer: do not place a battery on the market if there is reason to believe it is not in conformity; keep the EU declaration of conformity available for authorities; ensure technical documentation can be made available on request. - Distributor: do not make the battery available until a known conformity problem is corrected; keep storage and transport from undermining compliance; help authorities trace and address risks. - Fulfilment service provider: keep warehousing, packaging, addressing, and dispatching conditions from jeopardising compliance and perform the risk-cooperation and risk-notification tasks assigned by the Regulation. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries and waste batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Articles 38 to 43 set the manufacturer, authorised representative, importer, distributor, and fulfilment service provider obligations summarised in this section. ### [When do importers, distributors, or second-life operators become manufacturers?](/artifacts/eu/batteries-regulation/faq/economic-operator-roles.md#when-do-importers-distributors-or-second-life-operators-become-manufacturers) *Module: [EU Batteries Regulation economic operator roles](/artifacts/eu/batteries-regulation/faq/economic-operator-roles.md)* Role-change triggers are the part most teams miss. An importer or distributor is treated as a manufacturer if it places a battery on the market or puts it into service under its own name or trademark, modifies a battery in a way that could affect compliance, or modifies the purpose of a battery already placed on the market or put into service. - Rebranding trigger: selling under the importer or distributor's own name or trademark shifts manufacturer obligations to that actor. - Modification trigger: changing a battery in a way that could affect compliance shifts manufacturer obligations to the modifying importer or distributor. - Purpose-change trigger: changing what the battery is for can shift manufacturer obligations even if the physical battery is already on the market. - Second-life trigger: preparation for re-use, preparation for repurposing, repurposing, or remanufacturing followed by market placement or putting into service makes the second-life operator a manufacturer for the Regulation. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries and waste batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Articles 44 and 45 identify when importer, distributor, and second-life activities trigger manufacturer treatment and additional obligations. - [European Commission: more sustainable, circular and safe batteries](https://environment.ec.europa.eu/news/new-law-more-sustainable-circular-and-safe-batteries-enters-force-2023-08-17_en?ref=sorena.io) - Commission overview explaining the Regulation's circular-economy focus, including removability, replacement, collection, recycling, and battery lifecycle improvements. ### [How is the producer role different from manufacturer or importer?](/artifacts/eu/batteries-regulation/faq/economic-operator-roles.md#how-is-the-producer-role-different-from-manufacturer-or-importer) *Module: [EU Batteries Regulation economic operator roles](/artifacts/eu/batteries-regulation/faq/economic-operator-roles.md)* Producer is an extended producer responsibility role, not just another word for manufacturer. The producer definition turns on first supply in a Member State, own-name or own-trademark supply, resale where the original maker's name or trademark does not appear, cross-border supply into a Member State, and direct distance sales to end-users in a Member State. - Check the Member State of first supply, not only the EU-level importer of record. - Separate the product file owner from the producer-registration owner when the commercial route differs by country. - Treat direct distance sales to end-users in a Member State as a producer-role trigger under the Regulation. - For second-life batteries, the actor first making the prepared, repurposed, or remanufactured battery available in a Member State is treated as the producer of that battery for extended producer responsibility. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries and waste batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Articles 3, 55, and 56 define producer, require producer registration by Member State, and assign extended producer responsibility including for second-life batteries. ### [What records should support an economic-operator role decision?](/artifacts/eu/batteries-regulation/faq/economic-operator-roles.md#what-records-should-support-an-economic-operator-role-decision) *Module: [EU Batteries Regulation economic operator roles](/artifacts/eu/batteries-regulation/faq/economic-operator-roles.md)* Keep the role decision close to the battery model, supply route, and Member State. A useful record says which company is acting as manufacturer, authorised representative, importer, distributor, fulfilment service provider, producer, producer responsibility organisation, authorised representative for extended producer responsibility, or second-life operator for the specific battery and transaction. - Battery model, category, batch or serial identifier, and whether the battery is standalone or incorporated into another product. - Market route: first EU placement, Member State of first supply, distance-sale route, importer of record, distributor chain, and fulfilment provider. - Role-change review: own-brand sale, product modification, purpose modification, preparation for re-use, preparation for repurposing, repurposing, or remanufacturing. - Conformity evidence: technical documentation location, EU declaration of conformity, CE marking check, labelling check, instructions and safety information, and responsible contact details. - Traceability record: identity of the operator that supplied the battery, identity of the operator that received it, quantity, and exact models retained for the Regulation's traceability period. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries and waste batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Article 46 requires economic operators to identify upstream and downstream operators, quantities, and exact models to market surveillance authorities. ### [When does a notified body matter under the EU Batteries Regulation?](/artifacts/eu/batteries-regulation/faq/nando.md#when-does-a-notified-body-matter-under-the-eu-batteries-regulation) *Module: [EU Batteries Regulation NANDO and notified bodies](/artifacts/eu/batteries-regulation/faq/nando.md)* A notified body matters when the Batteries Regulation route selected for the battery requires third-party involvement. Article 17 points manufacturers to Annex VIII. For Articles 6, 9, 10, 12, 13 and 14, series batteries can use Module A or Module D1, and non-series batteries can use Module A or Module G. Module A is internal production control, so it does not make NANDO selection the central task. - First identify the applicable Batteries Regulation requirements: Articles 6, 7, 8, 9, 10, 12, 13 and 14 do not all point to the same Annex VIII route. - Then classify the production pattern: series production points to the series routes; one-off or non-series batteries point to the non-series routes. - Use NANDO/Single Market Compliance Space only after you know the needed procedure, because a body's general competence does not prove notification for every module or battery category. - Keep due-diligence verification separate from Annex VIII conformity assessment: Articles 48 and 51 also involve a notified body for battery due diligence policies. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Article 17 and Annex VIII set out when Module A, Module D1, and Module G apply to Batteries Regulation conformity assessment. - [EU Single Market Compliance Space notified bodies search](https://webgate.ec.europa.eu/single-market-compliance-space/notified-bodies/free-search?ref=sorena.io) - The public lookup supports searches by legislation, article or annex, procedure, products, body number, and notification status. ### [How should teams use NANDO or the Single Market Compliance Space for batteries?](/artifacts/eu/batteries-regulation/faq/nando.md#how-should-teams-use-nando-or-the-single-market-compliance-space-for-batteries) *Module: [EU Batteries Regulation NANDO and notified bodies](/artifacts/eu/batteries-regulation/faq/nando.md)* Use the lookup as a scope confirmation tool. Search for notified bodies under Regulation (EU) 2023/1542, then narrow the result by notification status, article or annex, procedure, and products. The result you need is not simply an active body name; it is an active body whose notification covers the Batteries Regulation task you plan to rely on. - Legislation check: confirm the body is notified for Regulation (EU) 2023/1542 or the Batteries Regulation entry, not only for a different product law. - Procedure check: match the body to Module D1, Module G, Article 48/51 due diligence verification, or the specific procedure shown in the lookup. - Product check: match the notification to the battery category, model family, or product description you need assessed. - Status check: preserve evidence that the notification was active at the time the selection or supplier approval was made. - Conflict check: a quoted proposal from a testing provider is not enough unless it aligns with the public notification scope. Sources for this answer: - [EU Single Market Compliance Space notified bodies search](https://webgate.ec.europa.eu/single-market-compliance-space/notified-bodies/free-search?ref=sorena.io) - The search interface exposes the filters needed to check notification status, legislation, article or annex, procedure, and products. - [European Commission New Legislative Framework](https://single-market-economy.ec.europa.eu/single-market/goods/new-legislative-framework_en?ref=sorena.io) - The Commission explains the New Legislative Framework context for accreditation, conformity assessment, CE marking, and product-legislation alignment. ### [What should appear in the evidence file after a notified-body check?](/artifacts/eu/batteries-regulation/faq/nando.md#what-should-appear-in-the-evidence-file-after-a-notified-body-check) *Module: [EU Batteries Regulation NANDO and notified bodies](/artifacts/eu/batteries-regulation/faq/nando.md)* The evidence file should let a reviewer see why a notified body was or was not needed, and why a selected body was in scope. For Module D1, preserve the quality-system application, the declaration that the same application was not lodged with another notified body, the quality-system documentation, the audit decision, later change assessments, surveillance audit reports, visit reports, and any test reports. For Module G, preserve the technical documentation supplied to the notified body, the examination or test basis, the certificate of conformity, and the notified-body identification number used with the CE marking where required. - Module decision: why Module A, D1, or G was selected for the battery and requirement set. - NANDO/SMCS evidence: dated copy or export of the body number, body name, status, legislation, procedure, article or annex, and product scope checked. - Contract alignment: statement of work or purchase order matching the public notification scope, not just a broad testing description. - Conformity outputs: EU declaration of conformity, technical documentation, certificate or approval decision, CE marking and notified-body identification number evidence where required. - Change control: record of production, design, standards, common-specification, supplier, or due-diligence changes that may require notifying the body or rechecking scope. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Annex VIII specifies notified-body records for Modules D1 and G, including quality-system decisions, audits, certificates, and identification numbers. - [EU Single Market Compliance Space notified bodies search](https://webgate.ec.europa.eu/single-market-compliance-space/notified-bodies/free-search?ref=sorena.io) - The lookup evidence should capture the public notification fields used to validate the selected body's scope. ### [What are common mistakes when checking Batteries Regulation notified bodies?](/artifacts/eu/batteries-regulation/faq/nando.md#what-are-common-mistakes-when-checking-batteries-regulation-notified-bodies) *Module: [EU Batteries Regulation NANDO and notified bodies](/artifacts/eu/batteries-regulation/faq/nando.md)* The most common mistake is treating a known laboratory or certification brand as automatically valid for Batteries Regulation work. Regulation (EU) 2023/1542 requires notification for the specific conformity assessment activity. The Commission keeps a public list of bodies notified under the Regulation, including identification numbers and the conformity assessment activities for which they are notified. - Do not rely on an old NANDO screenshot unless the status, legislation, procedure, and product scope are still checked in the current lookup. - Do not assume Module A needs a notified-body contract; Module A is internal production control under Annex VIII. - Do not use a notified body's number on CE marking unless Annex VIII requires it for the selected route. - Do not accept a quote for carbon footprint or recycled-content work without checking whether the route is Module D1 or Module G and whether the body is notified for that scope. - Do not omit due-diligence verification evidence when Articles 48 to 52 apply; Article 51 verification is a separate record set. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Articles 21 to 35 and Annex VIII explain notification, public lists, notified-body operation, and when identification numbers and certificates matter. - [EU Single Market Compliance Space notified bodies search](https://webgate.ec.europa.eu/single-market-compliance-space/notified-bodies/free-search?ref=sorena.io) - The search result structure supports checking active notification status and candidate body identity before relying on a provider. ### [When do EU Batteries Regulation QR codes and labels apply?](/artifacts/eu/batteries-regulation/faq/qr-and-label-timing.md#when-do-eu-batteries-regulation-qr-codes-and-labels-apply) *Module: [EU Batteries Regulation QR code and label timing](/artifacts/eu/batteries-regulation/faq/qr-and-label-timing.md)* Article 13 sets the label clock first. The separate collection symbol applies from 18 August 2025. General battery labels, capacity labels for rechargeable portable, LMT and SLI batteries, and non-rechargeable portable battery duration and non-rechargeable labels apply from 18 August 2026 or 18 months after the Article 13(10) implementing act enters into force, whichever is later. - Do not use 18 February 2027 as the start date for every label element; some Article 13 markings start earlier or depend on the Article 13(10) implementing act. - Plan artwork, packaging, and accompanying-document fallbacks separately because Article 13(7) allows packaging and accompanying documents where battery marking is not possible or not warranted by nature and size. - Treat battery passport readiness as a QR-linked data requirement for LMT, qualifying industrial, and electric vehicle batteries placed on the market or put into service from 18 February 2027. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Article 13 provides the separate timing rules for battery labels, the collection symbol, heavy-metal markings, QR codes, and the Article 13(10) implementing act. - [EUR-Lex summary of Regulation (EU) 2023/1542](https://eur-lex.europa.eu/EN/legal-content/summary/sustainability-rules-for-batteries-and-waste-batteries.html?ref=sorena.io) - EUR-Lex summarizes the regulation's lifecycle coverage, including information, labelling, and digital battery passport obligations. ### [What must the Article 13 label contain?](/artifacts/eu/batteries-regulation/faq/qr-and-label-timing.md#what-must-the-article-13-label-contain) *Module: [EU Batteries Regulation QR code and label timing](/artifacts/eu/batteries-regulation/faq/qr-and-label-timing.md)* The general label content comes from Annex VI Part A. It includes manufacturer identification, battery category and identifying information, place and date of manufacture, weight, capacity, chemistry, hazardous substances other than mercury, cadmium or lead, usable extinguishing agent, and critical raw materials above 0.1% weight by weight. - Keep Annex VI Part A data fields in the product master data, not only in packaging artwork files. - Separate universal label fields from category-specific labels so rechargeable portable, LMT, SLI, and non-rechargeable portable batteries do not receive the wrong marking set. - Keep a label specimen in the technical documentation because the regulation's conformity assessment annexes refer to a specimen of the Article 13 label. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Annex VI Part A lists the general information required on battery labels; Article 13 adds category-specific capacity, duration, collection, and heavy-metal markings. - [European Commission Batteries Regulation entry-into-force announcement](https://environment.ec.europa.eu/news/new-law-more-sustainable-circular-and-safe-batteries-enters-force-2023-08-17_en?ref=sorena.io) - The Commission announcement confirms that the regulation includes labelling and QR-code information measures as part of the EU battery lifecycle framework. ### [What does the QR code need to open?](/artifacts/eu/batteries-regulation/faq/qr-and-label-timing.md#what-does-the-qr-code-need-to-open) *Module: [EU Batteries Regulation QR code and label timing](/artifacts/eu/batteries-regulation/faq/qr-and-label-timing.md)* For LMT batteries, industrial batteries with a capacity greater than 2 kWh, and electric vehicle batteries, the QR code must open the Article 77 battery passport through a unique identifier attributed by the economic operator placing the battery on the market. Article 77 requires the passport from 18 February 2027 for those battery categories. - Public passport information under Annex XIII includes Annex VI label information, material composition, carbon footprint information, responsible sourcing information, recycled content information, renewable content share, performance data, Article 13 marking requirements, the EU declaration of conformity, and waste-prevention and management information. - Non-public passport layers are restricted: some information is for persons with a legitimate interest and the Commission, some for notified bodies, market surveillance authorities and the Commission, and some individual-battery data for persons with a legitimate interest. - Article 78 requires free access based on access rights, machine-readable and interoperable data, authentication, reliability, integrity, security, privacy, and continued passport availability if the responsible operator ceases activity in the Union. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Articles 13, 77, and 78 define what the QR code must access, which batteries need a passport, and how passport access rights and technical operation work. - [European Commission Batteries Regulation entry-into-force announcement](https://environment.ec.europa.eu/news/new-law-more-sustainable-circular-and-safe-batteries-enters-force-2023-08-17_en?ref=sorena.io) - The Commission describes the regulation's QR code and battery passport measures as transparency tools across the battery lifecycle. ### [Which QR and label details depend on Commission acts?](/artifacts/eu/batteries-regulation/faq/qr-and-label-timing.md#which-qr-and-label-details-depend-on-commission-acts) *Module: [EU Batteries Regulation QR code and label timing](/artifacts/eu/batteries-regulation/faq/qr-and-label-timing.md)* Article 13(10) requires the Commission to adopt implementing acts for harmonised specifications for the Article 13(1), (2), and (3) labelling requirements. That dependency matters because those label obligations apply from 18 August 2026 or 18 months after that implementing act enters into force, whichever is later. - Track Article 13(10) implementing acts for label specification details and the final label-compliance start date for Article 13(1) to (3). - Track Article 13(8) delegated acts separately because they may affect smart-label carrier options, not the current Article 13 QR obligation by itself. - Track Article 77 delegated and implementing acts separately because they affect passport data fields, QR and unique-identifier standards, and non-public access rights. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Article 13(8), Article 13(10), Article 77(2), Article 77(3), and Article 77(9) separate delegated-act powers from implementing-act dependencies. ### [Which Article 17 conformity assessment module applies to batteries?](/artifacts/eu/batteries-regulation/faq/ce-and-conformity-assessment.md#which-article-17-conformity-assessment-module-applies-to-batteries) *Module: [EU Batteries Regulation: CE Marking](/artifacts/eu/batteries-regulation/faq/ce-and-conformity-assessment.md)* Article 17 splits the conformity assessment route by requirement type and production pattern. For the requirements in Articles 6, 9, 10, 12, 13 and 14, batteries manufactured in series can use Annex VIII Module A, internal production control, or Module D1, quality assurance of the production process. Batteries not manufactured in series can use Module A or Module G, conformity based on unit verification. - Series production for Articles 6, 9, 10, 12, 13 and 14: Module A or Module D1. - Non-series batteries for Articles 6, 9, 10, 12, 13 and 14: Module A or Module G. - Articles 7 and 8 for series production: Module D1. - Articles 7 and 8 for non-series batteries: Module G. - Re-used, repurposed, remanufactured or similar batteries: additional Module A assessment for the listed product, safety, labelling and information requirements. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries and waste batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Article 17 and Annex VIII identify the applicable Batteries Regulation conformity assessment modules by requirement and production route. - [New legislative framework](https://single-market-economy.ec.europa.eu/single-market/goods/new-legislative-framework_en?ref=sorena.io) - Commission product-law overview explaining the New Legislative Framework context for conformity assessment, accreditation, market surveillance and CE marking. ### [What must the manufacturer prepare before affixing the CE marking?](/artifacts/eu/batteries-regulation/faq/ce-and-conformity-assessment.md#what-must-the-manufacturer-prepare-before-affixing-the-ce-marking) *Module: [EU Batteries Regulation: CE Marking](/artifacts/eu/batteries-regulation/faq/ce-and-conformity-assessment.md)* The manufacturer should treat the CE mark as evidence-backed output. Annex VIII requires technical documentation that lets authorities assess conformity, including the applicable requirements, design and manufacturing information, label specimen, standards or common specifications used, alternative technical solutions where needed, calculations, examinations, technical or documentary evidence, and test reports. - Keep the Article 17 module selection and rationale with the product conformity file. - Keep the Annex VIII technical documentation and risk assessment evidence. - Prepare one EU declaration of conformity for the battery model or battery, as required by the chosen module. - Use the Annex IX fields: battery identification, manufacturer details, responsibility statement, object description, Union legislation, standards or specifications, notified body intervention where applicable, and signature details. - Keep the declaration and related technical file available for national authorities for the required 10-year period stated in Annex VIII. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries and waste batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Articles 18 to 20 and Annexes VIII and IX set the declaration, technical documentation, CE marking and retention requirements. - [EUR-Lex summary: sustainability rules for batteries and waste batteries](https://eur-lex.europa.eu/EN/legal-content/summary/sustainability-rules-for-batteries-and-waste-batteries.html?ref=sorena.io) - EUR-Lex plain-language summary of the Batteries Regulation lifecycle, labelling, conformity and market-placement framework. ### [When does a notified body become part of the Batteries Regulation CE process?](/artifacts/eu/batteries-regulation/faq/ce-and-conformity-assessment.md#when-does-a-notified-body-become-part-of-the-batteries-regulation-ce-process) *Module: [EU Batteries Regulation: CE Marking](/artifacts/eu/batteries-regulation/faq/ce-and-conformity-assessment.md)* A notified body is not needed for every battery conformity assessment. Module A is internal production control by the manufacturer. Module D1 and Module G involve a notified body: Module D1 assesses and surveils the production quality system, while Module G verifies an individual battery through examinations, calculations, measurements and tests and issues a certificate of conformity. - Use Module D1 when Article 17 points a series-production battery to production-process quality assurance. - Use Module G when Article 17 points a non-series battery to unit verification. - Record the notified body's name, address, number, intervention and certificates in the EU declaration of conformity where applicable. - Keep approval decisions, audit reports, visit reports, test reports or certificates with the conformity file. - Do not add a notified body identification number beside the CE mark unless Annex VIII requires it for the chosen route. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries and waste batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Annex VIII describes the notified body role in Module D1 and Module G, including audits, surveillance, certificates and identification numbers. - [Single Market Compliance Space notified bodies search](https://webgate.ec.europa.eu/single-market-compliance-space/notified-bodies/free-search?ref=sorena.io) - Official EU search page for checking notified bodies by notification status, legislation, article or annex, procedure and products. ## FAQ Pagination - Canonical index (page 1): [/artifacts/eu/batteries-regulation/faq/items](/artifacts/eu/batteries-regulation/faq/items.md) - Page 1 rule: `/page/1` is intentionally not generated; use the canonical index markdown URL. - Current page: 2 of 3 Pages: [1](/artifacts/eu/batteries-regulation/faq/items.md) | [2](/artifacts/eu/batteries-regulation/faq/items/page/2.md) | [3](/artifacts/eu/batteries-regulation/faq/items/page/3.md) [Previous page](/artifacts/eu/batteries-regulation/faq/items.md) | [Next page](/artifacts/eu/batteries-regulation/faq/items/page/3.md) *Recommended next step* *Placement: after evidence section* ## Build a Batteries Regulation evidence file Use the FAQ answers to route each battery model by category, owner, source, label or passport field, due diligence record, removability evidence, and waste responsibility record. - [Open Research Copilot](/solutions/research-copilot.md): Check Batteries Regulation questions against cited EU source material. - [Discuss Batteries Regulation implementation](/contact.md): Review category routing, conformity evidence, passport fields, and waste responsibility with Sorena. --- [Privacy Policy](https://www.sorena.io/privacy) | [Terms of Use](https://www.sorena.io/terms-of-use) | [DMCA](https://www.sorena.io/dmca) | [About Us](https://www.sorena.io/about-us) (c) 2026 Sorena AB (559573-7338). 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