Regulatory Guide
EU Battery Regulation 2023/1542 — Complete Guide for Manufacturers
Last reviewed: September 2026 · Traceable Regulatory Team
Direct answer
EU Battery Regulation 2023/1542 governs every battery placed on the EU market — portable, LMT, EV, industrial, and SLI. In force since 17 August 2023, it replaces the 2006 Battery Directive and introduces lifecycle requirements covering Battery Passports, carbon footprint declarations, recycled-content minimums, and supply-chain due diligence. The first Battery Passport deadline is 18 February 2027 for EV, LMT, and industrial batteries above 2 kWh.
Key Takeaways
- Battery passports are mandatory from February 18, 2027 for LMT, EV, and industrial batteries above 2 kWh.
- The regulation covers all economic operators: manufacturers, importers, and distributors.
- Annex XIII defines the battery passport contents. Of the 71 data points the Commission guidance enumerates, 47 are mandatory for EV at 18 February 2027, 50 for LMT and 32 for industrial above 2 kWh.
- Carbon footprint declaration, recycled content percentages, and supply chain due diligence are required.
- The EU Central Registry launches in July 2026 — passports must connect to it.
The EU Battery Regulation is the most comprehensive battery legislation ever enacted. It governs every stage of the battery lifecycle — from raw material extraction to end-of-life recycling — and introduces the first mandatory Digital Product Passport under EU law. If you manufacture, import, or distribute batteries in the European Union, this regulation defines your compliance obligations for the next decade and beyond.
This guide covers the full scope of Regulation (EU) 2023/1542: its requirements, timelines, the battery passport mandate, carbon footprint rules, due diligence obligations, and what manufacturers must do now to comply.
What Is the EU Battery Regulation?
In short: the EU Battery Regulation has applied since 17 August 2023, replacing the old Batteries Directive and expanding far beyond recycling into sustainability, safety, traceability, due diligence, carbon footprint, and digital transparency.
Regulation (EU) 2023/1542 — the EU Battery Regulation — establishes a complete regulatory framework for batteries placed on the EU market. It was published in the Official Journal of the European Union on 28 July 2023 and entered into force on 17 August 2023.
The regulation replaces Directive 2006/66/EC (the Batteries Directive), which had governed battery waste management in the EU since 2006. The old directive focused primarily on collection and recycling targets. The new regulation goes far beyond waste management. It regulates sustainability, safety, labelling, traceability, due diligence, carbon footprint, recycled content, and digital transparency across the entire battery value chain.
This is a regulation, not a directive. It applies directly in all Member States without national transposition. The requirements are uniform across the EU.
Scope: Which Batteries Are Covered
In short: the regulation defines five battery categories, portable, industrial, EV, LMT, and SLI, and only industrial batteries above 2 kWh, EV batteries, and LMT batteries are subject to the battery passport requirement.
The Battery Regulation applies to all batteries placed on the EU market, regardless of their chemistry, shape, volume, weight, design, or intended use. Article 1 defines five battery categories, each subject to different combinations of requirements.
| Category | What it covers and which duties apply |
|---|---|
| Portable Batteries | Batteries that are sealed, weigh under 5 kg, and are not designed exclusively for industrial use. This includes standard consumer batteries (AA, AAA, button cells) and batteries in consumer electronics. Portable batteries are subject to collection targets, recycling requirements, and labelling rules but are not required to carry a battery passport. |
| Industrial Batteries | Batteries designed for industrial use, including stationary energy storage systems. Industrial batteries with a capacity exceeding 2 kWh are subject to the battery passport requirement, carbon footprint declarations, and due diligence obligations. |
| Electric Vehicle (EV) Batteries | Traction batteries used in hybrid and fully electric vehicles as defined under Regulation (EU) 2018/858. EV batteries are subject to the full suite of requirements: battery passport, carbon footprint declaration, performance classes, recycled content targets, and due diligence obligations. |
| Light Means of Transport (LMT) Batteries | Batteries in electric scooters, e-bikes, and similar light electric vehicles. LMT batteries are subject to the battery passport requirement from 18 February 2027. This category was introduced by the new regulation — the 2006 Directive did not address LMT batteries as a separate category. |
| Starting, Lighting and Ignition (SLI) Batteries | Batteries designed primarily to supply power for starting, lighting, or ignition in vehicles. SLI batteries are subject to labelling and recycled content requirements but are not covered by the battery passport mandate. |
The Battery Passport Requirement
In short: the battery passport, established under Article 77, is the first mandatory Digital Product Passport under EU law and becomes compulsory on 18 February 2027 for industrial batteries above 2 kWh, EV batteries, and LMT batteries.
Article 77 of Regulation (EU) 2023/1542 establishes the battery passport. This is the first mandatory Digital Product Passport under EU law and serves as the reference implementation for all future DPPs under the ESPR framework.
Which Batteries Need a Passport
The battery passport is required for three categories:
- Industrial batteries with a capacity exceeding 2 kWh
- Electric vehicle (EV) batteries
- Light means of transport (LMT) batteries
Portable batteries and SLI batteries are exempt from the passport requirement.
Compliance Deadline
The battery passport becomes mandatory on 18 February 2027. Every battery in the covered categories placed on the EU market on or after that date must have a compliant battery passport. There is no grace period. Batteries placed on the market before the deadline without a passport may remain in circulation but cannot be reintroduced if withdrawn.
What the Battery Passport Must Contain
Annex XIII of the Battery Regulation defines what the battery passport must contain. It is organised as four numbered points, and each point is an access tier rather than a subject area. The European Commission guidance of 28 July 2026 enumerates 71 data points across them, of which 47 are mandatory for EV batteries at February 2027, 50 for LMT and 32 for industrial above 2 kWh. The groupings below are ours, added for readability.
| Content area | What must be included |
|---|---|
| General Battery and Manufacturer Information |
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| Carbon Footprint |
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| Supply Chain Due Diligence |
|
| Material Composition |
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| Performance and Durability |
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| End-of-Life Information |
|
The level of detail required is unprecedented. Manufacturers must be able to populate every data point that applies to their battery category with accurate, verifiable information for every unit placed on the market.
Carbon Footprint Requirements
In short: carbon footprint accountability rolls out in three stages under Article 7, and none of them has commenced. Every date in Article 7 applies from the stated date or 12 to 18 months after the methodology delegated act and format implementing act enter into force, whichever is the latest. That delegated act was due by 18 February 2024 for EV batteries and has not been adopted, so the declaration, the performance-class label and the maximum threshold are all still waiting on it.
The Battery Regulation introduces a phased approach to carbon footprint accountability. Article 7 establishes three stages of increasing stringency.
| Stage | What it requires |
|---|---|
| Stage 1: Carbon Footprint Declaration (From 18 February 2025) | This obligation has not yet commenced. Article 7(1) applies from 18 February 2025 for EV batteries or 12 months after the methodology delegated act and format implementing act enter into force, whichever is the latest. Article 7(1) required that delegated act by 18 February 2024; it remains a draft and has not been published in the Official Journal, so the twelve month period has not started. When it does apply, every EV battery and industrial battery exceeding 2 kWh placed on the EU market must carry a carbon footprint declaration. The declaration must quantify the battery’s carbon footprint across its lifecycle, expressed in kg CO2 equivalent per kWh of total energy provided over the battery’s service life. The calculation must follow the methodology set out in the Commission’s delegated act under Article 7(1). |
| Stage 2: Carbon Footprint Performance Classes (From 18 August 2026) | Article 7(2) applies from 18 August 2026 for EV batteries or 18 months after the relevant acts enter into force, whichever is the latest, so this date is conditional in the same way as Stage 1. When it applies, batteries must be assigned to a carbon footprint performance class. The Commission defines the class boundaries through a delegated act. Each battery must display its performance class on the label and in the battery passport. This enables direct comparison between batteries and creates market pressure toward lower-carbon production. |
| Stage 3: Maximum Carbon Footprint Thresholds (From 18 February 2028) | Article 7(3) applies from 18 February 2028 for EV batteries or 18 months after the relevant acts enter into force, whichever is the latest, and the threshold value itself is set by a further delegated act adopted in accordance with Article 89. Both the date and the value are therefore still open. When it applies, maximum carbon footprint thresholds take effect. Batteries that exceed the threshold cannot be placed on the EU market. The Commission will set the threshold values through delegated acts, effectively banning the highest-carbon batteries from the European market. This is the regulatory mechanism that forces decarbonisation of battery production. |
Due Diligence Requirements
In short: since 18 August 2025, manufacturers of industrial batteries above 2 kWh, EV batteries, and LMT batteries must run OECD-aligned supply chain due diligence on cobalt, lithium, nickel, and natural graphite, with results reflected in the battery passport.
Articles 48 through 52 of the Battery Regulation impose mandatory supply chain due diligence obligations on economic operators placing batteries on the EU market. These requirements target the sourcing of raw materials with known social and environmental risks.
Covered Materials
The due diligence requirements apply to four critical raw materials used in battery manufacturing:
- Cobalt
- Lithium
- Nickel
- Natural graphite
Due Diligence Obligations
Economic operators must establish and implement a supply chain due diligence policy consistent with internationally recognised standards, specifically the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. The obligations include:
- Establishing a management system for supply chain due diligence
- Identifying and assessing risks in the supply chain related to human rights abuses, environmental degradation, and governance failures
- Designing and implementing a strategy to respond to identified risks
- Commissioning independent third-party audits of supply chain due diligence practices
- Publishing annual due diligence reports
These obligations apply from 18 August 2027, moved from 18 August 2025 by Regulation (EU) 2025/1561 amending Article 48(1), for economic operators placing industrial batteries exceeding 2 kWh, EV batteries, and LMT batteries on the EU market. The due diligence results must be reflected in the battery passport.
Recycled Content Targets
In short: binding recycled-content minimums for cobalt, lead, lithium, and nickel phase in from August 2031 and rise further from August 2036, creating a guaranteed demand signal for recycled battery materials.
The Battery Regulation sets binding recycled content targets for key battery materials. Article 8 establishes two compliance milestones.
| Phase | Minimum recycled content |
|---|---|
| Phase 1: From 18 August 2031 |
|
| Phase 2: From 18 August 2036 |
These targets apply to industrial batteries, EV batteries, LMT batteries, and SLI batteries containing cobalt, lead, lithium, or nickel in active materials. Manufacturers must document the recycled content share in the battery passport and verify it through appropriate chain-of-custody or mass-balance methodologies. The recycled content targets are a demand-side driver for the battery recycling industry. They create a guaranteed market for recovered materials and incentivise investment in recycling capacity and technology. |
End-of-Life Requirements
In short: the regulation sets rising collection targets for portable and LMT batteries, and minimum recycling-efficiency and material-recovery rates that recyclers must hit through the early 2030s.
The Battery Regulation establishes comprehensive end-of-life obligations covering collection, recycling efficiency, and material recovery.
| Obligation | Targets and dates |
|---|---|
| Collection Targets | Member States must achieve the following collection rates for portable batteries:
For LMT batteries, separate collection targets apply: 51% by end of 2028 and 61% by end of 2031. |
| Recycling Efficiency | Recyclers must achieve minimum recycling efficiency rates:
|
| Material Recovery Rates | Beyond overall recycling efficiency, the regulation sets material-specific recovery targets:
These targets ensure that critical materials are returned to the supply chain rather than lost in low-value recycling streams. |
Labelling Requirements
In short: batteries need CE marking, a QR code to the passport, chemistry and collection symbols, capacity and manufacturing details, and, from August 2026, a carbon footprint performance class, printed or engraved directly on the battery wherever possible.
Article 13 of the Battery Regulation establishes detailed labelling requirements for all battery categories. The labelling regime is more comprehensive than under the previous Directive and includes both physical marking and digital elements. (Note: Article 13 of the separate ESPR Regulation 2024/1781 covers the EU Central DPP Registry, a different obligation under a different regulation.)
Mandatory Label Elements
- CE marking confirming conformity with applicable EU requirements
- QR code linking to the battery passport (for passport-eligible batteries)
- Separate collection symbol (crossed-out wheeled bin)
- Battery chemistry symbol (Cd for cadmium, Pb for lead, where applicable)
- Rated capacity (Ah) and nominal voltage
- Date of manufacture (month and year)
- Manufacturer name or registered trade mark and postal address
- Battery weight
- Substance of concern symbols (where applicable)
- Carbon footprint performance class label (from August 2026 for EV and industrial batteries >2 kWh)
Labels must be printed or engraved on the battery in a visible, legible, and indelible manner. Where the battery size makes direct printing impractical, labels may be affixed to the packaging or accompanying documentation, subject to specific conditions.
Battery Passport Data Carrier
In short: the passport must be reachable via an ISO/IEC 18004 QR code durable enough to remain scannable for the battery’s full operational life, typically 8 to 15 years for EV and industrial batteries.
The battery passport must be accessible through a data carrier affixed to the battery. Article 77(3) specifies the technical requirements.
The data carrier must be a QR code compliant with ISO/IEC 18004. The QR code must be placed on the battery itself or, where physical constraints prevent this, on the battery’s packaging. The QR must encode a unique identifier that resolves to the battery passport hosted by the manufacturer or their authorised DPP service provider.
The QR code must remain scannable for the expected operational lifetime of the battery. For EV and industrial batteries, this means durability of at least 8 to 15 years under normal operating conditions. Manufacturers must select printing, engraving, or labelling methods that can withstand the battery’s operating environment, including temperature variations, vibration, and chemical exposure.
The unique identifier must comply with the ISO/IEC 15459 series (15459-1..6:2014) or their equivalent, per Article 77(3) of Regulation (EU) 2023/1542; GS1 is a recognised issuing agency under ISO/IEC 15459, so GS1 Digital Link is one conforming implementation. It must be registered in the EU’s battery passport system infrastructure before the battery is placed on the market.
Who Is Responsible
In short: manufacturers carry primary compliance responsibility, importers and distributors must verify conformity before the battery reaches the market, and non-EU manufacturers can appoint an EU-based authorised representative.
The Battery Regulation places primary compliance responsibility on the economic operator who places the battery on the EU market. Chapter VI (Articles 38-47) defines the obligations of each actor in the supply chain.
| Economic operator | Duties |
|---|---|
| Manufacturers | The manufacturer bears primary responsibility for all substantive requirements: design, conformity assessment, labelling, carbon footprint declaration, battery passport creation, due diligence, and recycled content verification. The manufacturer must draw up a technical file, apply the CE marking, and issue the EU Declaration of Conformity before placing the battery on the market. |
| Importers | Importers must verify that the manufacturer has completed all conformity procedures, that the battery carries the correct labelling and CE marking, and that a compliant battery passport exists (where required). If the importer has reason to believe a battery does not comply, they must not place it on the market until compliance is established. |
| Distributors | Distributors must verify that the battery bears the required labelling, CE marking, and QR code before making it available on the market. Distributors must also ensure that storage and transport conditions do not jeopardise battery compliance. |
| Authorised Representatives | A non-EU manufacturer may designate an authorised representative established in the EU to perform specific tasks on their behalf. The authorised representative’s details must be recorded in the battery passport. |
Key Dates Timeline
The Battery Regulation rolls out obligations in phases. Manufacturers must track multiple compliance deadlines simultaneously.
- 17 August 2023: Regulation enters into force
- 18 February 2024: Requirements on removability and replaceability of portable batteries take effect (applies to new product designs)
- 18 February 2025 (conditional, not started): Carbon footprint declaration for EV batteries and industrial batteries >2 kWh. Applies from this date or 12 months after the Article 7(1) acts enter into force, whichever is the latest. The delegated act is still a draft.
- 18 August 2027: Supply chain due diligence obligations apply. Moved from 18 August 2025 by Regulation (EU) 2025/1561, which amended Article 48(1).
- 18 August 2026 (conditional): Carbon footprint performance classes for EV and industrial batteries >2 kWh, under Article 7(2), subject to the same delegated act trigger.
- 18 February 2027: Battery passport mandatory for industrial batteries >2 kWh, EV batteries, and LMT batteries
- 18 February 2028 (conditional): Maximum carbon footprint thresholds under Article 7(3). Batteries exceeding the threshold cannot be placed on the market. Both the date and the threshold value depend on delegated acts not yet adopted.
- 31 December 2027: 63% collection rate for portable batteries; 90%/50% material recovery targets for cobalt/copper/lead/nickel and lithium respectively
- 31 December 2030: 73% collection rate for portable batteries; lithium-based battery recycling efficiency increases to 70%
- 18 August 2031: First recycled content targets apply (16% cobalt, 85% lead, 6% lithium, 6% nickel); 95%/80% material recovery targets
- 18 August 2036: Increased recycled content targets (26% cobalt, 85% lead, 12% lithium, 15% nickel)
Penalties and Enforcement
In short: market surveillance authorities can force corrective action, recalls, or market withdrawal, customs can hold non-compliant batteries at the border, and Member States must set penalties strong enough to outweigh any benefit of non-compliance.
Article 76 of the Battery Regulation empowers market surveillance authorities to take corrective action against non-compliant batteries. The enforcement provisions are robust and designed to ensure uniform application across the internal market.
| Mechanism | How it operates |
|---|---|
| Market Surveillance Powers | Market surveillance authorities can require economic operators to take corrective action, withdraw non-compliant batteries from the market, recall batteries already sold, prohibit further placement on the market, and impose administrative fines. They have the power to access battery passport data, request technical documentation, and conduct physical testing. |
| Customs Enforcement | Batteries entering the EU customs territory are subject to compliance checks. Customs authorities can verify the existence of battery passports, check labelling compliance, and hold non-compliant shipments at the border. For manufacturers with global supply chains, this creates a hard enforcement point that cannot be bypassed. |
| Penalty Regimes | Member States are required to establish rules on penalties for infringement of the Battery Regulation. Penalties must be effective, proportionate, and dissuasive. While specific fine amounts are set at national level, the regulation ensures that the economic benefit of non-compliance is always exceeded by the penalty. Repeat non-compliance and failure to cooperate with market surveillance authorities are aggravating factors. |
📄 Download the EU Battery Passport Compliance Checklist (PDF) — a one-page, seven-section checklist covering everything below.
How to Prepare: Practical Steps
In short: with the February 2027 deadline under a year out, start now with a regulatory-exposure classification, an Annex XIII data audit, supplier engagement, platform selection, carbon footprint processes, due diligence setup, and a pilot passport.
The February 2027 battery passport deadline is less than twelve months away. Manufacturers who have not begun preparation face significant risk. Here is a practical action plan.
- Determine Your Regulatory Exposure. Classify every battery you place on the EU market against the five categories defined in the regulation. Identify which batteries require a passport, which are subject to carbon footprint declarations, and which must meet recycled content targets. Map each product line to the applicable deadlines.
- Audit Your Data Against Annex XIII. Map every data point that is mandatory for your battery category at February 2027, 47 for EV, 50 for LMT or 32 for industrial above 2 kWh, against the data you currently hold in your product information systems. For each data point, determine whether the data exists, whether it is in the correct format, and whether it is verifiable. This audit will reveal the gaps you need to close.
- Engage Your Supply Chain. Many Annex XIII data points require information from upstream suppliers — cell chemistry details, raw material sourcing data, component-level carbon footprint contributions, and substance of concern disclosures. Begin formalising data-sharing requirements with suppliers now. Include battery passport data obligations in new supplier contracts and update existing agreements.
- Select a Battery Passport Platform. The battery passport is a digital infrastructure requirement. You need a platform that can create, host, and manage battery passports at scale. Key capabilities include: Annex XIII data model support, QR code generation compliant with ISO/IEC 18004, tiered access control, integration with your ERP and manufacturing execution systems, and readiness for the EU central battery passport registry. Traceable provides this infrastructure, purpose-built for Battery Regulation compliance.
- Implement Carbon Footprint Processes. If you are placing EV or industrial batteries exceeding 2 kWh on the market, the carbon footprint declaration is already mandatory. Ensure your carbon footprint calculation methodology complies with the Commission’s delegated act under Article 7(1). Prepare for performance class labelling (August 2026) and maximum threshold compliance (February 2028).
- Establish Due Diligence Processes. Implement a supply chain due diligence system aligned with the OECD Due Diligence Guidance. Map your supply chain for cobalt, lithium, nickel, and natural graphite. Identify risk areas, implement mitigation measures, commission third-party audits, and prepare your first annual due diligence report. These obligations apply from August 2025.
- Run a Pilot. Select a battery product line and create a complete battery passport. Populate all Annex XIII data points, generate the QR code, test scanning workflows, validate access tiers, and review data completeness. Use the pilot to surface integration issues, data quality problems, and process gaps before your full-scale rollout.
The Strategic Context
In short: the battery passport isn’t an isolated rule, it’s the architectural template the rest of the ESPR’s Digital Product Passport framework is built on, and automotive OEMs are already requiring passport readiness from suppliers as a procurement condition.
The Battery Regulation is not an isolated initiative. It is part of a broader EU strategy to secure critical raw material supply chains, accelerate the clean energy transition, and establish the EU as a leader in circular economy regulation.
The battery passport is the first mandatory Digital Product Passport under EU law. Its architecture, data model, and access framework will shape every subsequent DPP under the ESPR. Manufacturers who build robust battery passport capabilities now are investing in infrastructure that will serve them across their entire product portfolio as ESPR delegated acts expand DPP requirements to other categories.
Compliance with the Battery Regulation is also a competitive differentiator. EU and global automotive OEMs are increasingly requiring battery passport readiness from their suppliers as a procurement condition. Manufacturers who can demonstrate compliance credibly and early will secure supply contracts that those still scrambling to comply will miss.
This guide reflects the regulatory position as of March 2026. Delegated acts, implementing measures, and technical standards under the Battery Regulation are subject to ongoing development. Subscribe to Regulatory Radar on traceable.digital for updates on battery passport specifications, carbon footprint methodology developments, and compliance deadline tracking.
Readiness Assessment
You know what it requires. Now find out if you meet it.
Five questions, about two minutes. You get a score for each area and a numbered action plan for the gaps.
Score Your ReadinessWhat This Means For Your Business
This regulation directly affects every company that manufactures, imports, or distributes batteries on the EU market. The compliance burden is significant: you need to collect data from across your supply chain, calculate carbon footprints, declare recycled content percentages, and make all of this available in a machine-readable format via QR code.
Non-compliance means your batteries cannot legally be placed on the EU market. Market surveillance authorities can order product withdrawal, block imports at customs, and impose financial penalties.
Action Steps
- Determine your battery classification (LMT, EV traction, or industrial) and identify the applicable template.
- Audit existing data against Annex XIII requirements — most manufacturers already have 40-60% of the required data.
- Contact your cell and raw material suppliers to begin upstream data collection.
- Create a Traceable account and enter your first battery using the appropriate template.
- Plan for EU Central Registry connection when it launches in July 2026.
- Target full compliance at least 3 months before the February 2027 deadline.
Technical documentation
Implementation detail for the requirements above, on our documentation site.
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Annex XIII data points, field by field ↗
Every data point in the battery passport annex, with its access tier and the article that mandates it.
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Which batteries are in scope ↗
Category boundaries between EV, LMT, industrial, SLI and portable, and what each one triggers.
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Obligation timeline ↗
What applies from 18 February 2027 and what is still waiting on a delegated act.
Frequently Asked Questions
Regulation (EU) 2023/1542, adopted 12 July 2023 and in force since 17 August 2023, replaces the 2006 Battery Directive. It introduces lifecycle-wide requirements for every battery placed on the EU market — portable, LMT (light means of transport), EV, industrial, and SLI (starter, lighting, ignition). The regulation mandates Battery Passports, carbon footprint declarations, recycled content minimums, and due diligence on battery supply chains.
Article 77 requires a Digital Product Passport for every EV battery, every LMT battery, and every industrial battery with capacity greater than 2 kWh placed on the EU market from 18 February 2027. Portable batteries and SLI batteries are not in scope of the Passport requirement but remain subject to other obligations including carbon footprint, recycled content, and due diligence under separate articles.
The binding Battery Passport deadline is 18 February 2027 under Article 77(1) of Regulation 2023/1542, and that date is fixed. The carbon footprint dates are not: every date in Article 7 applies from the stated date or 12 to 18 months after the methodology delegated act and format implementing act enter into force, whichever is the latest. The Article 7(1) delegated act was due by 18 February 2024 for EV batteries and is still a draft, so the declaration obligation has not commenced. Recycled content disclosure under Article 8(1) is conditional in the same way, from 18 August 2028 or 24 months after its delegated act. The binding recycled content minimums are fixed: 16% cobalt, 85% lead, 6% lithium and 6% nickel from 18 August 2031 under Article 8(2), rising to 26% cobalt, 85% lead, 12% lithium and 15% nickel from 18 August 2036 under Article 8(3).
Annex XIII specifies the mandatory fields. The passport covers battery identification and chemistry, nominal capacity and voltage, weight, manufacturer and facility, compliance and conformity documentation, carbon footprint per functional unit, recycled content per critical raw material, supply chain due diligence evidence, performance and durability parameters, state of health and expected lifetime, and end-of-life handling instructions. Access is tiered: consumers see a subset, authorities and certified operators see the full record.
The economic operator placing the battery on the EU market — the manufacturer for EU-made batteries, the importer or authorised representative for batteries manufactured outside the EU. Distributors must verify that a Battery Passport exists before making the battery available. When a battery is repurposed, remanufactured, or reused, the economic operator performing that action becomes responsible for updating the passport with a new status and new responsible party.
The Battery Regulation (2023/1542) is a directly applicable, sector-specific regulation that already covers every requirement for batteries including the Battery Passport. ESPR (2024/1781) is a horizontal framework that introduces product passports for other categories — textiles, tyres, iron, steel, electronics, furniture — via category-specific delegated acts. Batteries are formally excluded from ESPR because they are fully regulated under 2023/1542. Both use the same DPP architecture, GS1 Digital Link carrier, and EU Central Registry.
Article 7 requires a carbon footprint declaration — calculated with the Product Environmental Footprint (PEF) methodology and expressed in kg CO2-eq per kWh of total energy provided over the service life — on EV batteries from 18 February 2025, on rechargeable industrial batteries above 2 kWh from 18 August 2026, and on LMT batteries from 18 August 2028. Performance classes and declaration-verification requirements follow in subsequent implementing acts.
Article 8 sets recycled-content minimums for EV and industrial batteries for four critical raw materials. From 18 August 2031: 16% cobalt, 6% lithium, 6% nickel, 85% lead. From 18 August 2036 (subject to Commission review): 26% cobalt, 12% lithium, 15% nickel, 85% lead. Producers must include recycled-content percentages in the Battery Passport and in the technical documentation accompanying the battery.