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For waste portable batteries, producers or producer responsibility organisations must attain and durably maintain collection targets of 45% by 31 December 2023, 63% by 31 December 2027, and 73% by 31 December 2030.

For waste LMT batteries, the targets are 51% by 31 December 2028 and 61% by 31 December 2031. The collection rate is calculated using the Annex XI methodology, which compares collected waste batteries with the average weight of relevant batteries made available on the market to end-users in the three preceding calendar years.

Collected waste batteries cannot be treated as disposal or energy-recovery material. Article 70 requires treatment in permitted facilities, with waste batteries removed from waste appliances, waste light means of transport, or end-of-life vehicles where applicable.

Article 71 requires permitted facilities to accept waste batteries made available to them and ensure preparation for re-use, preparation for repurposing, or recycling. Recyclers must meet Annex XII recycling efficiency and material recovery targets, calculated under the delegated methodology and documentation format for recycling efficiency and recovery rates.

Article 75 is the practical reporting checklist. Producers of portable and LMT batteries, or their producer responsibility organisations, must report annually by chemistry and battery category on placed-on-market amounts, including the separate amount for portable batteries of general use, collected waste batteries, collection rates, delivery to treatment, export for treatment or preparation, and delivery to preparation for re-use or repurposing.

Waste management operators, treatment operators, recyclers, and exporters also have reporting duties where they collect, treat, recycle, or export waste batteries. The evidence file should therefore connect sales data, collection data, treatment handovers, recycling calculations, and export records by Member State and battery category.

Article 75 ties the first reporting period to the reporting-format implementing act. Commission Implementing Regulation (EU) 2025/2289 entered into force on 11 December 2025, so the first full reporting year is calendar year 2026. Article 75 requires the covered reporting parties to report within six months after that year ends, making 30 June 2027 the EU-level deadline for 2026 data. The competent authority still controls the electronic submission system, format, and any additional information needed to check reliability.

Article 7 covers electric vehicle batteries, rechargeable industrial batteries with a capacity greater than 2 kWh, and batteries for light means of transport (LMT). It distinguishes rechargeable industrial batteries with external storage from other rechargeable industrial batteries when setting application timing.

For those categories, the declaration and class are tied to each battery model per manufacturing plant. Teams should therefore map the battery category, model identifier, manufacturing plant, and whether the industrial battery has external storage before assigning an Article 7 workstream.

The sequence is cumulative. First, the covered battery model needs a carbon footprint declaration. Second, the battery bears a label declaring the carbon footprint performance class for that model and plant. Third, once the relevant delegated act sets maximum life-cycle carbon footprint thresholds, the technical documentation must show that the declared life-cycle carbon footprint value is below the applicable threshold.

That sequence matters because a class is not the same thing as a market-access threshold. Annex II says classes are based on the distribution of declared values for batteries placed on the market, with category A as the best class. Maximum thresholds are a later limit, set after information has been collected through declarations and class distribution and after a dedicated impact assessment.

Article 7 does not itself publish the calculation methodology, class boundaries, label formats, or maximum threshold values. It gives the Commission different tasks: delegated acts for the calculation and verification methodology, delegated acts for performance classes, implementing acts for the declaration and label formats, and delegated acts for maximum life-cycle carbon footprint thresholds.

Track four dependencies separately. A declaration format alone does not settle the calculation methodology, a calculation methodology alone does not set class boundaries, and a class delegated act does not necessarily mean the maximum-threshold requirement is already known.

The statutory dates also differ by category. For declarations, electric vehicle batteries start on 18 February 2025 or 12 months after the methodology or format act enters into force, whichever is later; other covered categories follow later dates and the same delayed-start logic. For class labels, electric vehicle batteries start on 18 August 2026 or 18 months after the class or label-format act enters into force, whichever is later. Maximum-threshold duties use another schedule, beginning for electric vehicle batteries on 18 February 2028 or 18 months after the threshold act enters into force, whichever is later.

Until the relevant class and threshold acts are available for the battery category, the useful evidence is the category and model analysis, calculation inputs, declaration fields, and change-control history. The regulation expects technical documentation to support the declared carbon footprint value and the class, including calculations and the evidence determining the input data.

Keep the evidence aligned to the model and plant. Annex II says the life-cycle carbon footprint calculation is based on the bill of materials, energy, and auxiliary materials used in a specific manufacturing plant for a specific battery model; sampling from different plants for the same model is not allowed, and a change in the bill of materials or energy mix requires recalculation.

Do not publish class boundaries, width of classes, or maximum threshold values unless the relevant delegated act for the battery category supports them. The regulation explains the factors the Commission must use, but it does not turn those factors into final numeric class boundaries in Article 7 itself.

Also avoid saying that carbon footprint classes alone determine market access. Under the Article 7 structure, the class label differentiates batteries by declared carbon footprint performance, while the later maximum life-cycle threshold is the requirement that the declared value must be below once the threshold delegated act applies.