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Across 11 modules • Updated Jul 24, 2026
Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
EU Batteries Regulation NANDO and notified bodies

How should teams use NANDO or the Single Market Compliance Space for batteries?

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. Confirm an active body whose notification covers the Batteries Regulation task you plan to rely on.

For each candidate, record the body number, legal name, country, notification status, covered legislation, covered procedure, and covered products. If the page or body detail does not show the procedure or product scope needed for your battery model, do not treat the body as confirmed for that task until the scope is verified with the notifying authority or another official record.

Repeat the public-scope check when the assessment route, battery category, body status, certificate scope, or production arrangement changes. A dated lookup proves what the public record showed on that date; it does not establish that the notification will remain active or cover later work.

  • 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.
  • Change check: recheck status and scope before relying on the body for a new module, product family, assessment, or material change.
  • Conflict check: a quoted proposal from a testing provider is not enough unless it aligns with the public notification scope.
Citations
EU Batteries Regulation NANDO and notified bodies

What should appear in the evidence file after a notified-body check?

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.

For Chapter VII due diligence applying from 18 August 2027, preserve the notified body's verification report and approval decision under Article 51, audit reports under Article 48, and the public report summary that includes the name of the notified body. Material prepared before then should be labelled as readiness evidence. Importers should also be able to show that the EU declaration of conformity and technical documentation exist and that the relevant Article 17 conformity assessment was carried out by the manufacturer.

  • 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.
Citations
EU Batteries Regulation NANDO and notified bodies

What are common mistakes when checking Batteries Regulation notified bodies?

A known laboratory or certification brand is not 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.

Another mistake is collapsing Annex VIII conformity assessment and battery due-diligence verification into one generic supplier check. They can both involve notified bodies, but they support different obligations, records, and outputs. The evidence should show which obligation was being satisfied.

  • 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.
Citations
EU Batteries Regulation QR code and label timing

When do EU Batteries Regulation QR codes and labels apply?

Article 13 sets several label clocks. The Cd or Pb marking rule has applied with the Regulation since 18 February 2024 when a battery exceeds 0.002% cadmium or 0.004% lead. 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.

The QR code clock is separate. From 18 February 2027, all batteries must be marked with a QR code described in Annex VI Part C. For LMT batteries, industrial batteries above 2 kWh, and electric vehicle batteries, that QR code must provide access to the battery passport under Article 77.

  • 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.
  • Check the separate collection symbol dimensions and packaging fallback in Article 13(4), and place any required Cd or Pb symbol beneath it at no less than one quarter of the collection symbol's area.
  • 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.
Citations
Regulation (EU) 2023/1542 on batteries

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.

EU Batteries Regulation QR code and label timing

What must the Article 13 label contain?

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.

Article 13 also adds targeted markings: capacity for rechargeable portable, LMT and SLI batteries; minimum average duration and a non-rechargeable label for non-rechargeable portable batteries; a separate collection symbol for all batteries; and Cd or Pb chemical symbols where cadmium or lead thresholds are exceeded.

  • 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.
Citations
Regulation (EU) 2023/1542 on batteries

Annex VI Part A lists the general information required on battery labels; Article 13 adds category-specific capacity, duration, collection, and heavy-metal markings.

EU Batteries Regulation QR code and label timing

What does the QR code need to open?

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.

For other batteries, Article 13(6) points the QR code to the applicable Article 13 label and marking information, the EU declaration of conformity, the Article 52(3) due diligence report where that report applies, and waste-prevention and management information. For SLI batteries, the QR code must also provide recovered cobalt, lead, lithium or nickel information calculated under Article 8.

A battery that has been prepared for re-use, prepared for repurposing, repurposed, or remanufactured needs new Article 13 labels or markings. Its change of status must also be available through the QR code.

  • 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.
Citations
EU Batteries Regulation QR code and label timing

Which QR and label details depend on Commission acts?

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.

Separate delegated-act powers cover future changes to smart labels and passport information. Article 13(8) allows delegated acts for alternative smart labels instead of, or in addition to, the QR code. Article 77 allows delegated acts to amend Annex XIII passport information and the QR-code or unique-identifier standards. Article 77(9) separately requires implementing acts specifying legitimate-interest access and permitted download, sharing, publication, and reuse rights.

  • 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.
Citations
EU Batteries Regulation: CE Marking

Which Article 17 conformity assessment module applies to batteries?

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.

For Article 7 carbon footprint requirements and Article 8 recycled content requirements, Article 17 points series production to Module D1 and non-series batteries to Module G. Batteries that have been prepared for re-use, prepared for repurposing, repurposed or remanufactured need an additional Module A assessment covering Articles 6, 9, 10, 12, 13 and 14.

Article 17 generally applies from 18 August 2024. The Article 7 and 8 conformity assessment in Article 17(2) has a separate trigger: Article 96 says it applies 12 months after the first publication of the Article 30(2) notified-body list. A manufacturer should record the list-publication date used for its applicability decision instead of assuming that every Article 17 route began on the same day.

  • 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.
Citations
New legislative framework

Commission product-law overview explaining the New Legislative Framework context for conformity assessment, accreditation, market surveillance and CE marking.

EU Batteries Regulation: CE Marking

What must the manufacturer prepare before affixing the CE marking?

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.

Article 18 requires the EU declaration of conformity to state that compliance with Articles 6 to 10 and Articles 12, 13 and 14 has been demonstrated. The declaration must follow the Annex IX model structure, stay up to date, be translated into the language required by the relevant Member State, and be available electronically and, when requested, on paper.

  • 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 technical file available for national authorities for the Annex VIII retention period: under Module A, keep both for 10 years after the last battery belonging to the model is placed on the market; under Module D1, keep the technical documentation for 10 years after the battery is placed on the market and the declaration for 10 years after the last battery belonging to the model is placed on the market; under Module G, keep both for 10 years after the assessed battery is placed on the market.
Citations
EU Batteries Regulation: CE Marking

When does a notified body become part of the Batteries Regulation CE process?

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.

Where Annex VIII requires notified body involvement, Article 20 requires the CE marking to be followed by the notified body's identification number. The public notified-body directory should be checked for the body, notification status, Batteries Regulation legislation scope, module, procedure and battery categories.

  • 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.
Citations
EU Batteries Regulation: CE Marking

What should importers and distributors check before batteries reach the EU market?

Importers cannot rely only on a supplier statement. Before placing a battery on the EU market, Article 41 requires importers to verify that the EU declaration of conformity and Annex VIII technical documentation have been drawn up, that the Article 17 conformity assessment has been carried out, that the battery bears CE marking, and that required marking, labelling, documents, instructions and safety information are present.

Distributors have a narrower but still concrete gate under Article 42. Before making a battery available on the market, they must verify producer registration, CE marking, required marking and labelling, required documents, instructions and safety information, and the manufacturer and importer identity details. If either actor has reason to believe the battery is non-conforming, it should not proceed until brought into conformity.

  • Importer evidence: EU declaration of conformity, Annex VIII technical documentation availability, Article 17 assessment confirmation, CE marking, labels, documents, instructions and manufacturer identity details.
  • Importer retention: keep a copy of the EU declaration of conformity for 10 years and ensure technical documentation can be made available to authorities on request.
  • Distributor evidence: producer registration check, CE marking check, label and document check, safety information language check, and manufacturer/importer identity check.
  • Escalation evidence: non-conformity hold, corrective action, withdrawal or recall records, and market-surveillance authority communications where a risk is present.
Citations
New legislative framework

Commission product-law overview supporting the distinction between conformity assessment, CE marking and market surveillance checks.

EU Batteries Regulation: CE Marking

What evidence should a CE and conformity assessment file contain?

A useful Batteries Regulation conformity file should let a reviewer reconstruct the path from battery scope to CE marking. It should show the battery category, whether the product is series or non-series, which Article 17 module applies, which Articles 6 to 10 and 12 to 14 requirements are relevant, and whether Article 7 or Article 8 triggered notified body involvement.

The evidence file should also separate manufacturer evidence from importer and distributor checks. That prevents a downstream actor from treating CE marking as a substitute for verifying the declaration, technical documentation availability, labels, instructions, producer registration and identity details.

  • Battery model, product category, batch or serial identifiers, intended use and market-placement status.
  • Article 17 module selection record and Annex VIII module evidence.
  • Technical documentation index, including risk assessment, label specimen, standards or common specifications, calculations, test reports and supporting studies for carbon footprint or recycled content where relevant.
  • EU declaration of conformity using the Annex IX structure and translations required for target Member States.
  • CE marking placement proof and notified body identification number proof where Module D1 or Module G requires it.
  • Notified body certificates, approval decisions, audit reports, visit reports and test reports where applicable.
  • Importer and distributor verification records, non-conformity holds, corrective actions, withdrawals, recalls and authority responses.
Citations
EU Batteries Regulation: Waste Collection

What should producers do first for waste battery collection and reporting?

Start with the Member State where each battery category is made available on the market for the first time. Article 55 requires a producer register in each Member State, and producers may place batteries on that Member State market only if they, or their authorised representative where applicable, are registered there.

The registration file should identify the producer, battery categories and chemistries, and the measures used to meet extended producer responsibility and collection obligations. For portable and LMT batteries, the record should also explain the system used to keep reported data reliable. Chapter VIII, which contains these waste-management duties, applies from 18 August 2025; national registers, competent authorities, and filing mechanics still have to be checked in each Member State.

  • Map each battery category: portable, LMT, SLI, industrial, and electric vehicle batteries.
  • Register in every Member State where batteries are first made available on the market.
  • Record whether obligations are fulfilled individually, through an authorised representative, or through a producer responsibility organisation.
  • Keep written evidence of collection measures, data reliability controls, and any producer responsibility organisation mandate.
Citations
EU Batteries Regulation: Waste Collection

Who pays for collection, take-back, treatment, and reporting?

The Batteries Regulation uses extended producer responsibility. Article 56 makes producers responsible for batteries they make available for the first time in a Member State, including batteries resulting from preparation for re-use, preparation for repurposing, repurposing, or remanufacturing.

Producer financial contributions cover separate collection, transport and treatment, compositional surveys where required, information on prevention and management of waste batteries, and data gathering and reporting to competent authorities. A producer responsibility organisation can carry out obligations on behalf of producers.

  • Budget collection, transport, and treatment costs by Member State and battery category.
  • Include reporting and data gathering in the EPR cost model, not only logistics invoices.
  • For repurposed or remanufactured batteries placed on the market, check whether the operator becomes the producer for EPR purposes.
  • Avoid unsupported national details unless the relevant Member State source is separately verified.
Citations
EU Batteries Regulation: Waste Collection

How must free collection and take-back work for portable and LMT batteries?

For portable batteries and LMT batteries, producers or their producer responsibility organisations must establish take-back and collection systems in the Member State where they make those batteries available for the first time. Those systems must cover the whole territory, taking account of population, expected waste battery volumes, accessibility, and proximity to end-users.

End-users must be able to discard waste portable batteries and waste LMT batteries at collection points without being charged, without having to buy a new battery, and without having to prove they bought the battery from the producer that set up the collection point.

  • Portable battery collection points can involve distributors, public authorities, voluntary points, end-of-life vehicle treatment facilities, and WEEE treatment facilities.
  • LMT battery systems use the same types of cooperation points, with suitable infrastructure for the volume and hazardous nature of LMT waste batteries.
  • Distributors must take back waste batteries from end-users free of charge, limited to categories they have or had in their offer and, for portable batteries, normal non-professional quantities.
  • Distance sellers must provide collection points across the Member State and tell end-users the take-back arrangements when a battery is ordered.
Citations
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