Selling in the European Union?

Art. 11 software-no-impediment

Banned

• Contains a battery
• Battery category: Portable battery or LMT battery (e-bike, e-scooter)
• Your role: Manufacturer or Importer

Depends on: contains battery, battery category, economic operator role

Takes effect 18 Feb 2027

Applies to products placed on the market on or after 18 Feb 2027

Article 11 applies from 18 February 2027 (Art. 96(2)(a)).

Art. 11 software-no-impediment

Banned

• Your role: Manufacturer or Importer
• Battery is incorporated in an appliance or vehicle

Depends on: economic operator role, battery incorporated in appliance

Takes effect 18 Feb 2027

Applies to products placed on the market on or after 18 Feb 2027

Article 11 applies from 18 February 2027 (Art. 96(2)(a)).

Art. 11 software-no-impediment

Banned

• Your role: Manufacturer or Importer

Depends on: economic operator role

Takes effect 18 Feb 2027

Applies to products placed on the market on or after 18 Feb 2027

Article 11 applies from 18 February 2027 (Art. 96(2)(a)).

Battery due diligence annual-public-report

Disclosure to consumer

Annual public report on the battery due diligence policy, including a summary of third-party verifications

• Your role: Manufacturer or Importer

Depends on: economic operator role

Takes effect 18 Aug 2027

Applies to products placed on the market on or after 18 Aug 2027

From 18 August 2027 (Art. 48(1), amended text marked M2).

Battery due diligence authority-disclosure

Disclosure to authority

Verification report, approval decision, audit reports and evidence of compliance with a recognised due diligence scheme, on request

• Your role: Manufacturer or Importer

Depends on: economic operator role

Takes effect 18 Aug 2027

Applies to products placed on the market on or after 18 Aug 2027

From 18 August 2027 (Art. 48(1), amended text marked M2).

Battery passport (Annex XIII), accessible by QR code

Disclosure to consumer

Battery passport: electronic record with the Annex XIII information, accessible through the QR code, unique identifier uploaded to the registry (Art. 77)

• Your role: Manufacturer or Importer

Depends on: economic operator role

Takes effect 18 Feb 2027

Applies to products placed on the market on or after 18 Feb 2027

Battery due diligence downstream-disclosure

Disclosure to buyer

All relevant information gained under the battery due diligence policy, to immediate downstream purchasers

• Your role: Manufacturer or Importer

Depends on: economic operator role

Takes effect 18 Aug 2027

Applies to products placed on the market on or after 18 Aug 2027

From 18 August 2027 (Art. 48(1), amended text marked M2).

Art. 49(2)

Declaration required

Documentation supporting the chain of custody or traceability system: raw material description, supplier name and address, quantities, and the further information listed in Art. 49(2)

• Your role: Manufacturer or Importer

Depends on: economic operator role

Takes effect 18 Aug 2027

Applies to products placed on the market on or after 18 Aug 2027

From 18 August 2027 (Art. 48(1), amended text marked M2).

Battery due diligence records

Declaration required

Documentation of due diligence, including verification report, approval decision and audit reports, kept for 10 years after the last battery under the policy is placed on the market

• Your role: Manufacturer or Importer

Depends on: economic operator role

Takes effect 18 Aug 2027

Applies to products placed on the market on or after 18 Aug 2027

From 18 August 2027 (Art. 48(1), amended text marked M2).

Art. 50(3)

Test required

Third-party verification of the economic operator battery due diligence practices

• Your role: Manufacturer or Importer

Depends on: economic operator role

Takes effect 18 Aug 2027

Applies to products placed on the market on or after 18 Aug 2027

From 18 August 2027 (Art. 48(1), amended text marked M2).

Battery due diligence third-party-verification

Test required

Third-party verification and periodic audit of the battery due diligence policy by a notified body (Art. 51)

• Your role: Manufacturer or Importer

Depends on: economic operator role

Takes effect 18 Aug 2027

Applies to products placed on the market on or after 18 Aug 2027

From 18 August 2027 (Art. 48(1), amended text marked M2).

Art. 77(10)

Registration required

Unique identifier of the battery passport uploaded to the registry referred to in Article 13(1) of Regulation (EU) 2024/1781

• Your role: Manufacturer or Importer

Depends on: economic operator role

Takes effect 18 Feb 2027

Applies to products placed on the market on or after 18 Feb 2027

Art. 77(10)

Registration required

Unique identifier of the battery passport uploaded to the registry referred to in Article 13(1) of Regulation (EU) 2024/1781

• Your role: Manufacturer or Importer
• Rated energy more than 2000 Wh

Depends on: economic operator role, rated energy wh

Takes effect 18 Feb 2027

Applies to products placed on the market on or after 18 Feb 2027

Art. 77(4)

Must meet the conditions of The information in the battery passport is accurate, complete and up to date

• Your role: Manufacturer or Importer

Depends on: economic operator role

Takes effect 18 Feb 2027

Applies to products placed on the market on or after 18 Feb 2027

Battery due diligence management-system

Must meet the conditions of Management system: policy per Annex X raw materials and risk categories, traceability system, supplier contracts, grievance mechanism (Art. 49)

• Your role: Manufacturer or Importer

Depends on: economic operator role

Takes effect 18 Aug 2027

Applies to products placed on the market on or after 18 Aug 2027

From 18 August 2027 (Art. 48(1), amended text marked M2).

Battery due diligence policy

Must meet the conditions of Set up and implement a battery due diligence policy (Art. 48 to 50, 52)

• Your role: Manufacturer or Importer

Depends on: economic operator role

Takes effect 18 Aug 2027

Applies to products placed on the market on or after 18 Aug 2027

From 18 August 2027 (Art. 48(1), amended text marked M2).

Battery due diligence risk-management

Must meet the conditions of Risk management: identify and assess supply-chain risks, implement a response strategy and risk management plan (Art. 50)

• Your role: Manufacturer or Importer

Depends on: economic operator role

Takes effect 18 Aug 2027

Applies to products placed on the market on or after 18 Aug 2027

From 18 August 2027 (Art. 48(1), amended text marked M2).

Art. 77(4)

Must meet the conditions of The information in the battery passport is accurate, complete and up to date

• Your role: Manufacturer or Importer
• Rated energy more than 2000 Wh

Depends on: economic operator role, rated energy wh

Takes effect 18 Feb 2027

Applies to products placed on the market on or after 18 Feb 2027

Battery passport (Annex XIII), accessible by QR code

Disclosure to consumer

Battery passport: electronic record with the Annex XIII information, accessible through the QR code, unique identifier uploaded to the registry (Art. 77)

• Your role: Manufacturer or Importer
• Rated energy more than 2000 Wh

Depends on: economic operator role, rated energy wh

Takes effect 18 Feb 2027

Applies to products placed on the market on or after 18 Feb 2027

Carbon footprint label-class (Art. 7)

Label required

carbon footprint of the battery (kg CO2e per kWh); carbon footprint performance class

• Rated energy more than 2000 Wh
• Rechargeable
• Your role: Manufacturer or Importer or Distributor

Depends on: rated energy wh, rechargeable, economic operator role

Takes effect 18 Aug 2027

Applies to products placed on the market on or after 18 Aug 2027

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)

Must meet the conditions of Annex IV Part A minimum values laid down in the delegated act under Art. 10(5)

• Rated energy more than 2000 Wh
• Rechargeable
• Your role: Manufacturer or Importer or Distributor

Depends on: rated energy wh, rechargeable, economic operator role

Takes effect 18 Aug 2027

Applies to products placed on the market on or after 18 Aug 2027

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.

QR code (Annex VI Part C)

Label required

QR code giving access to the battery passport (LMT, industrial over 2 kWh, electric vehicle) or the Art. 13 information, declaration of conformity and waste-prevention information (other batteries)

• Your role: Manufacturer or Importer or Distributor

Depends on: economic operator role

Takes effect 18 Feb 2027

Applies to products placed on the market on or after 18 Feb 2027

Art. 11 removable-replaceable-lmt

Must meet the conditions of LMT batteries and their cells are readily removable and replaceable by an independent professional at any time during the product's lifetime

• Your role: Manufacturer or Importer
• Battery is incorporated in an appliance or vehicle

Depends on: economic operator role, battery incorporated in appliance

Takes effect 18 Feb 2027

Applies to products placed on the market on or after 18 Feb 2027

Article 11 applies from 18 February 2027 (Art. 96(2)(a)).

Art. 11 removable-replaceable-lmt

Must meet the conditions of LMT batteries and their cells are readily removable and replaceable by an independent professional at any time during the product's lifetime

• Your role: Manufacturer or Importer
• Contains a battery
• Battery category: LMT battery (e-bike, e-scooter)

Depends on: economic operator role, contains battery, battery category

Takes effect 18 Feb 2027

Applies to products placed on the market on or after 18 Feb 2027

Article 11 applies from 18 February 2027 (Art. 96(2)(a)).

Art. 11 removable-replaceable-portable

Must meet the conditions of Portable batteries incorporated in the product are readily removable and replaceable by the end-user at any time during the product's lifetime (commercially available tools; entire batteries, not cells)

• Contains a battery
• Battery category: Portable battery
• Your role: Manufacturer or Importer

Depends on: contains battery, battery category, economic operator role

Takes effect 18 Feb 2027

Applies to products placed on the market on or after 18 Feb 2027

Article 11 applies from 18 February 2027 (Art. 96(2)(a)).