Upcoming changes

11 rules in Regulation (EU) 2023/1542 concerning batteries and waste batteries, for products placed on the market, from 18 Feb 2027. Conditions differ by rule; see below.

• Art. 11 removable-replaceable-lmt

  Applies when: Your role: Manufacturer or Importer; Battery is incorporated in an appliance or vehicle · Article 11 applies from 18 February 2027 (Art. 96(2)(a)).

• Art. 11 software-no-impediment

  Applies when: Your role: Manufacturer or Importer · Article 11 applies from 18 February 2027 (Art. 96(2)(a)).

  Applies when: Your role: Manufacturer or Importer; Battery is incorporated in an appliance or vehicle · Article 11 applies from 18 February 2027 (Art. 96(2)(a)).

• Art. 11 spare-part-availability

  Applies when: Contains a battery; Battery category: Portable battery or LMT battery (e-bike, e-scooter); Your role: Manufacturer or Importer · Article 11 applies from 18 February 2027 (Art. 96(2)(a)).

• Art. 77(10)

  Applies when: Your role: Manufacturer or Importer

  Applies when: Your role: Manufacturer or Importer; Rated energy more than 2000 Wh

• Art. 77(4)

  Applies when: Your role: Manufacturer or Importer

  Applies when: Your role: Manufacturer or Importer; Rated energy more than 2000 Wh

• Battery passport (Annex XIII), accessible by QR code

  Applies when: Your role: Manufacturer or Importer

  Applies when: Your role: Manufacturer or Importer; Rated energy more than 2000 Wh

• QR code (Annex VI Part C)

  Applies when: Your role: Manufacturer or Importer or Distributor

12 rules in Regulation (EU) 2023/1542 concerning batteries and waste batteries, for products placed on the market, from 18 Aug 2027. Conditions differ by rule; see below.

• Art. 49(2)

  Applies when: Your role: Manufacturer or Importer · From 18 August 2027 (Art. 48(1), amended text marked M2).

• Art. 50(3)

  Applies when: Your role: Manufacturer or Importer · From 18 August 2027 (Art. 48(1), amended text marked M2).

• Battery due diligence annual-public-report

  Applies when: Your role: Manufacturer or Importer · From 18 August 2027 (Art. 48(1), amended text marked M2).

• Battery due diligence authority-disclosure

  Applies when: Your role: Manufacturer or Importer · From 18 August 2027 (Art. 48(1), amended text marked M2).

• Battery due diligence downstream-disclosure

  Applies when: Your role: Manufacturer or Importer · From 18 August 2027 (Art. 48(1), amended text marked M2).

• Battery due diligence management-system

  Applies when: Your role: Manufacturer or Importer · From 18 August 2027 (Art. 48(1), amended text marked M2).

• Battery due diligence policy

  Applies when: Your role: Manufacturer or Importer · From 18 August 2027 (Art. 48(1), amended text marked M2).

• Battery due diligence records

  Applies when: Your role: Manufacturer or Importer · From 18 August 2027 (Art. 48(1), amended text marked M2).

• Battery due diligence risk-management

  Applies when: Your role: Manufacturer or Importer · From 18 August 2027 (Art. 48(1), amended text marked M2).

• Battery due diligence third-party-verification

  Applies when: Your role: Manufacturer or Importer · From 18 August 2027 (Art. 48(1), amended text marked M2).

• Carbon footprint label-class (Art. 7)

  Applies when: Rated energy more than 2000 Wh; Rechargeable; Your role: Manufacturer or Importer or Distributor · Art. 7(2)(b) rechargeable industrial batteries over 2 kWh. Batteries with exclusively external storage have a later date (2032-02-18, Art. 7(2)(d)) in the same paragraph; no product fact separates them. The text adds 'or ... months after the date of entry into force of the delegated or implementing act, whichever is the latest'; the published text gives no entry-into-force date, so the stated calendar date is used. The date shown is the earliest possible date: the duty depends on a later Commission act, which sets the final date.

• Minimum electrochemical performance and durability values (Annex IV Part A)

  Applies when: Rated energy more than 2000 Wh; Rechargeable; Your role: Manufacturer or Importer or Distributor · From 18 August 2027 or 18 months after the date of entry into force of the delegated act, whichever is the latest (Art. 10(2)). The date shown is the earliest possible date: the duty depends on a later Commission act, which sets the final date.

Applies to products placed on the market on or after 31 Dec 2027. Applies when: Your role: Manufacturer or Importer or Distributor.

Target date 2027-12-31 as stated; Chapter VIII applies from 18 August 2025 (Art. 96(2)(c)).

Applies to products placed on the market on or after 18 Feb 2028. Applies when: Your role: Manufacturer or Importer or Distributor.

Art. 7(3)(a) electric vehicle batteries. The text adds 'or ... months after the date of entry into force of the delegated or implementing act, whichever is the latest'; the published text gives no entry-into-force date, so the stated calendar date is used. The date shown is the earliest possible date: the duty depends on a later Commission act, which sets the final date.

5 rules in Regulation (EU) 2023/1542 concerning batteries and waste batteries, for products placed on the market, from 18 Aug 2028. Conditions differ by rule; see below.

• Carbon footprint declaration (Art. 7)

  Applies when: Your role: Manufacturer or Importer or Distributor · Art. 7(1)(c) LMT batteries. The text adds 'or ... months after the date of entry into force of the delegated or implementing act, whichever is the latest'; the published text gives no entry-into-force date, so the stated calendar date is used. The date shown is the earliest possible date: the duty depends on a later Commission act, which sets the final date.

• Minimum electrochemical performance and durability values (Annex IV Part A)

  Applies when: Your role: Manufacturer or Importer or Distributor · From 18 August 2028 or 18 months after the date of entry into force of the delegated act, whichever is the latest (Art. 10(3)). The date shown is the earliest possible date: the duty depends on a later Commission act, which sets the final date.

• Minimum electrochemical performance and durability values of portable batteries of general use

  Applies when: Contains a button or coin cell: no; Your role: Manufacturer or Importer or Distributor · From 18 August 2028 or 24 months after the date of entry into force of the delegated act, whichever is the latest (Art. 9(1)). The date shown is the earliest possible date: the duty depends on a later Commission act, which sets the final date.

• Recycled content documentation (Art. 8(1))

  Applies when: Battery chemistry: Lithium-ion or Lithium (non-rechargeable) or Nickel-metal hydride or Nickel-cadmium or Lead-acid; Rated energy more than 2000 Wh; Your role: Manufacturer or Importer or Distributor · Industrial batteries over 2 kWh (not exclusively external storage), electric vehicle batteries and SLI batteries that contain cobalt, lead, lithium or nickel in active materials; the stated date is 2028-08-18 or 24 months after the delegated act, whichever is the latest. The capacity bound for industrial batteries and the active-material content are not product facts here, so the rule is scoped on the whole categories. The date shown is the earliest possible date: the duty depends on a later Commission act, which sets the final date.

  Applies when: Battery chemistry: Lithium-ion or Lithium (non-rechargeable) or Nickel-metal hydride or Nickel-cadmium or Lead-acid; Your role: Manufacturer or Importer or Distributor · Industrial batteries over 2 kWh (not exclusively external storage), electric vehicle batteries and SLI batteries that contain cobalt, lead, lithium or nickel in active materials; the stated date is 2028-08-18 or 24 months after the delegated act, whichever is the latest. The capacity bound for industrial batteries and the active-material content are not product facts here, so the rule is scoped on the whole categories. The date shown is the earliest possible date: the duty depends on a later Commission act, which sets the final date.