EU Batteries Regulation requirements

Regulation (EU) 2023/1542 applies to all battery categories: portable, starting-lighting-ignition (SLI), light means of transport (LMT), electric vehicle, and industrial batteries. It also covers batteries incorporated into or added to products, and battery cells or modules made available for end use can be treated as batteries for the closest category.

The first implementation step is therefore a scope table, not a policy memo. For each battery model, record the category, chemistry, capacity, whether it is incorporated in another product, whether it is placed on the market or put into service, and which economic operator or producer role applies. If a battery could fall into more than one Chapter II category, the Regulation points teams to the category with the strictest requirements.

Chapter II is the core product requirement layer. It covers substance restrictions, carbon footprint declarations for electric vehicle batteries, rechargeable industrial batteries above 2 kWh, and LMT batteries, recycled content documentation and minimum levels for specified categories, performance and durability records, removability and replaceability for portable and LMT batteries, and safety evidence for stationary battery energy storage systems.

Teams should separate declared information from threshold compliance. Carbon footprint declarations need model, plant, lifecycle-stage footprint values, EU declaration of conformity identification, and a public supporting-study link. Recycled content starts as documentation for relevant cobalt, lead, lithium, and nickel content before minimum recycled-content percentages become technical-documentation obligations for covered battery categories.

Batteries must pass the applicable conformity assessment route before market placement or putting into service. Article 17 points to Module A or Module D1 for series production requirements in Articles 6, 9, 10, 12, 13, and 14, and Module D1 or Module G for Article 7 and Article 8 requirements. Batteries not manufactured in series can use Module A or Module G depending on the requirement set.

The EU declaration of conformity must state that compliance with Articles 6 to 10 and 12 to 14 has been demonstrated, follow the Annex IX model structure, be kept up to date, and be available electronically. The CE marking must be visible, legible, indelible, and affixed before the battery is placed on the market or put into service; if the battery form prevents that, the marking can be placed on packaging and accompanying documents.

Article 13 creates the information layer that connects labels, markings, QR codes, declarations, waste information, and passport access. General labels and capacity or non-rechargeable-use information apply by category. All batteries must carry the separate collection symbol, and all batteries with more than the specified cadmium or lead content must carry the relevant chemical symbol.

From 18 February 2027, all batteries must be marked with a QR code. For LMT batteries, industrial batteries above 2 kWh, and electric vehicle batteries, the QR code gives access to the Article 77 battery passport. Other batteries use the QR code for the applicable label information, declaration of conformity, due diligence report where relevant, and waste-prevention and waste-management information.

The due diligence chapter is a management-system and evidence requirement, not only a supplier questionnaire. In-scope economic operators must maintain a battery due diligence policy, identify and assess social and environmental risks in the supply chain, implement a risk response strategy, use third-party verification through a notified body, and disclose due diligence information.

The practical output should connect battery models and raw materials to supplier-chain risk records. The record should cover risk categories, raw materials and secondary raw materials, supplier and subcontractor links, top-management responsibility, risk mitigation measures, stakeholder consultation where mitigation continues during trade, notified-body verification, and the public annual due diligence report.

End-of-life obligations are a separate evidence stream. Producers or producer responsibility organisations must provide waste-prevention and waste-management information to end users and distributors for the battery categories they supply in each Member State. The information must cover safe handling, separate collection, take-back and collection points, reuse or repurposing options, treatment availability, label meanings, and impacts of hazardous substances and inappropriate disposal.

Recyclers need chemistry-specific documentation for recycling efficiency and material recovery. Commission Delegated Regulation (EU) 2025/606 sets out calculation and verification methodology and documentation formats for lead-acid, lithium-based, nickel-cadmium, and other waste batteries, including recovery calculations for cobalt, copper, lead, lithium, and nickel.

A useful requirements review ends with maintained outputs that can survive product changes, supplier changes, authority questions, and website or packaging updates. The evidence set should be organized by battery model and actor role, with direct links from each public claim, label, QR code, declaration, passport field, or waste instruction to its source system and approval owner.

Do not collapse the Batteries Regulation into a single compliance status. A model can be ready for one obligation area and incomplete for another, especially where delegated acts, notified-body verification, or Member State waste arrangements affect implementation.