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EURegulation guide

# EU Battery Regulation 2023/1542

The EU Battery Regulation replaced the old Battery Directive and introduces a phased set of requirements — labelling, carbon footprints, digital battery passports, and recyclability targets — that affect any product placed on the EU market that contains a battery.

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## Implementation timeline

Aug 2023

Regulation entered into force

Feb 2024

Labelling requirements for capacity, chemistry, and removability began applying to LMT and industrial batteries

Aug 2024

Hazardous substance labelling, QR code, and recycled content targets apply to portable batteries

Feb 2025

Carbon footprint declaration requirements begin for EV and industrial batteries

2026 onwards

Digital battery passport requirements phase in for LMT, EV, and industrial batteries (specific dates via delegated acts)

2027 onwards

Recycled content mandatory requirements phase in by category

## Battery categories and what they mean for your product

### Portable batteries

Batteries in smartphones, laptops, wearables, IoT devices, consumer electronics

Must be removable and replaceable by end user under the Regulation — a requirement phasing in with product-specific implementing acts.

### Light means of transport (LMT) batteries

Batteries in e-bikes, e-scooters, e-mopeds

Higher labelling requirements, carbon footprint declarations, and battery passport requirements apply earlier.

### Industrial batteries

Batteries > 2 kWh not in EVs or LMTs — UPS systems, energy storage

Carbon footprint declarations and battery passport requirements apply from 2025/2026.

### EV batteries

Traction batteries in electric vehicles

Most stringent requirements including mandatory recycled content, carbon footprint, and battery passport.

## Battery labelling requirements

01

CE marking (where applicable under RED, LVD, or other directives)

02

Crossed-out wheelie bin symbol with collection and recycling information

03

Battery chemistry symbol (Li-ion, NiMH, etc.)

04

Capacity (Wh for rechargeable, Ah for non-rechargeable)

05

QR code linking to publicly available battery information

06

Symbol indicating the battery can be removed by the end user (where applicable)

07

Hazardous substance warning symbols if applicable (Pb, Hg, Cd content thresholds)

## Frequently asked questions

### Does the Battery Regulation apply to batteries inside products?

Yes. The Battery Regulation applies to all batteries placed on the EU market — including batteries that are incorporated in or added to appliances, vehicles, or other products. The obligations fall on the battery manufacturer and on the manufacturer of the product containing the battery.

### What is the digital battery passport?

The digital battery passport is a data record accessible via a QR code on the battery or its packaging. It contains information on the battery's chemistry, capacity, carbon footprint, recycled content, state of health, and supply chain. Passport requirements phase in for LMT, industrial, and EV batteries through delegated acts from 2026 onwards.

### Is user-removability of batteries required now?

The Battery Regulation requires portable batteries to be removable and replaceable by end users. However, this applies through product-specific implementing regulations — the timeline and exact products in scope depend on delegated acts still being developed. The overall direction is clear: design for replaceability.

### How does the Battery Regulation interact with CE marking?

CE marking under RED, LVD, or other applicable directives is still required for the product. The Battery Regulation adds additional obligations on top of CE marking requirements for the battery component itself — labelling, carbon footprint declarations, battery passports, and registration duties.

**Disclaimer:** Educational resource only. The Battery Regulation's implementing and delegated acts are still being published. Verify the current timeline and requirements against the official Regulation (EU) 2023/1542 and European Commission guidance.

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