EU Battery Regulation 2023/1542, explained.
The first EU law that regulates a product across its entire life, from mined cobalt to recycled cell. What it requires, from whom, and when. Without the legalese.
What it is
Regulation (EU) 2023/1542 replaces the 2006 Battery Directive. The switch from directive to regulation matters: a regulation applies directly in all 27 member states, identically, with no national transposition. One market, one rulebook.
Its scope is the full lifecycle: design, carbon footprint, raw material sourcing, production, labelling, use, collection and recycling. No earlier EU product law went this far.
Who must comply
Everyone who places batteries on the EU market: manufacturers, importers and distributors. Where the battery is produced is irrelevant. A pack made outside the EU must satisfy exactly the same requirements as one made inside it.
It also covers batteries inside products. If your device, vehicle or machine ships with a battery, the battery obligations ship with it.
The six battery categories
The Regulation distinguishes portable batteries, SLI (starting, lighting, ignition), LMT (light means of transport, think e-bikes and scooters), EV batteries, industrial batteries above 2 kWh and industrial batteries with external storage. Obligations differ per category.
The heaviest obligations, including the battery passport, fall on EV, LMT and industrial >2 kWh batteries.
The five obligation themes
Carbon footprint: a verified declaration per battery model per plant, phased in per category from February 2025.
Recycled content: documented shares of recycled cobalt, lithium, nickel and lead, with hard minimums from August 2028.
Due diligence: audited supply chain policies for cobalt, lithium, nickel and natural graphite, mandatory from August 2027.
Labelling: CE marking, the separate collection symbol and, from August 2026, a QR code on every battery.
The battery passport: a digital product passport per individual battery, mandatory from February 2027.
The battery passport
From 18 February 2027, every EV, LMT and industrial >2 kWh battery placed on the EU market needs its own digital passport: a per-battery record carrying the data points of Annex XIII, from chemistry and carbon footprint to recycled content and state of health.
The QR code on the battery opens it. Part of the data is public for anyone who scans; the rest is tiered for recyclers, second-life operators and market surveillance authorities.
Enforcement and penalties
Member states appoint market surveillance authorities and set their own penalties. The instrument that matters is market access: non-compliant batteries can be refused, withdrawn or recalled from the EU market.
The practical risk is not a fine in year one. It is a shipment that does not clear, or a customer that cannot buy from you because their compliance team says no.
Where do you stand?
Upload a spec sheet and see your battery scored against all 74 Annex XIII requirements. Free, no account.