Regulation (EU) 2023/1542
Batteries Regulation: what does it ask of you?
- Who it applies to
- Every company that makes batteries or has them made under its brand, imports, sells or ships them, supplies cells, or sells products with portable or LMT batteries. The producer is whoever first supplies them in a Member State.
- The dates
- The Regulation applies from 18 February 2024, directly, with no national transposition. Producer responsibility applies from 18 August 2025, and the later design, label and passport duties each have their own day below.
- The one thing to do
- Make batteries conform to Articles 6 to 14, assess conformity, draw up the documentation and the declaration, mark them, and register as a producer where you supply.
Two answers give the duties your role carries for one kind of battery, through the same determination the portal runs.
Answer above to read the determination for your case; the full tool takes your answers with it.
See the dutiesAt a glance
Who carries which article
A company is often several of these at once, and each brings its own articles. The portal asks which, then asks about the batteries.
| Role | Articles | Duties |
|---|---|---|
| Manufacturer | 6, 7, 8, 9, 10, 12, 13, 14, 17, 18, 20, 38, 45, 40, 46, 47, 48, 52, 77, 78 | 50 |
| Authorised representative | 40, 46 | 5 |
| Importer | 41, 44, 46, 47, 48, 52, 77, 78 | 20 |
| Distributor | 42, 44, 46, 62, 74 | 13 |
| Fulfilment service provider | 43, 46 | 3 |
| Supplier of cells and modules | 39 | 1 |
| Maker of products with batteries | 11 | 4 |
| Producer | 55, 56, 57, 59, 60, 61, 74, 75 | 11 |
The day each later duty applies
Everything else applies from 18 February 2024. Where a day is marked or later, the Commission's own act can push it back.
| From | Article | Duty |
|---|---|---|
| 10(1) | Document the Annex IV performance and durability values | |
| 12(2) | Prove storage system safety in the technical documentation | |
| 14(1) | Hold state of health data in the battery management system | |
| 14(2) | Give buyers read-only access to that data | |
| 17(1) | Carry out the conformity assessment, module A, D1 or G | |
| or later | 7(1) | Draw up a carbon footprint declaration per model and plant |
| 13(4) | Mark the separate collection symbol on every battery | |
| 55(2) | Register in each Member State you first supply | |
| 55(12) | Report changes to your registration without undue delay | |
| 56(1) | Carry extended producer responsibility in each Member State | |
| 56(3) | Appoint a representative for producer responsibility | |
| 57(1) | Appoint a producer responsibility organisation, if you wish | |
| 59(1) | Collect waste portable batteries in each Member State | |
| 59(3) | Meet the collection targets for waste portable batteries | |
| 60(1) | Collect waste LMT batteries in each Member State | |
| 61(1) | Take back waste SLI, industrial and EV batteries free | |
| 62(1) | Take back waste batteries from end-users free of charge | |
| 62(4) | Provide collection points where you sell at a distance | |
| 62(5) | Offer take-back at the point of delivery | |
| 74(1) | Inform end-users on prevention and waste batteries | |
| 74(4) | Show end-users the waste battery information in your shops | |
| 75(1) | Report each calendar year to the competent authority | |
| or later | 7(2) | Label the carbon footprint and its performance class |
| or later | 13(1) | Label the battery with the Annex VI Part A information |
| or later | 13(2) | Label the battery's capacity |
| or later | 13(3) | Label the minimum average duration and non-rechargeable |
| 11(1) | Make portable batteries removable by the end-user | |
| 11(5) | Make LMT batteries replaceable by a professional | |
| 11(7) | Offer the batteries as spare parts for five years | |
| 11(8) | Never use software to block a battery replacement | |
| 13(6) | Mark every battery with a QR code | |
| 77(1) | Give each battery an electronic battery passport | |
| 77(4) | Keep the passport accurate, complete and up to date | |
| 77(10) | Upload the battery's unique identifier to the EU registry | |
| 78 | Build the passport to the essential requirements | |
| or later | 10(2) | Meet the minimum values for industrial batteries |
| 48(1) | Set up and implement battery due diligence policies | |
| 48(2) | Have the policies verified and audited by a notified body | |
| 48(3) | Keep the due diligence documentation | |
| 52(3) | Publish a yearly report on the due diligence policy | |
| or later | 7(3) | Stay below the maximum life cycle carbon footprint |
| or later | 8(1) | Document the recycled cobalt, lead, lithium and nickel |
| or later | 9(1) | Meet the minimum performance and durability values |
| or later | 10(3) | Meet the minimum values for LMT batteries |
| 8(2) | Meet the minimum shares of recycled content | |
| 8(3) | Meet the higher shares of recycled content |
The carbon footprint, by category
Article 7 gives each category its own day for the declaration, the performance class and the maximum. The table above shows the earliest; each day can move with the Commission's acts.
| Category | Declaration, 7(1) | Performance class, 7(2) | Maximum, 7(3) |
|---|---|---|---|
| Electric vehicle batteries | |||
| Rechargeable industrial batteries above 2 kWh | |||
| LMT batteries | |||
| Industrial batteries with only external storage |
The EU declaration of conformity
Article 18(2) gives the declaration the model structure of Annex IX, kept up to date and in the language the Member State requires. These are its points, in the Regulation's words:
- 1. Battery model (product, category, and batch or serial number):
- 2. Name and address of the manufacturer and, where applicable, its authorised representative:
- 3. This declaration of conformity is issued under the sole responsibility of the manufacturer.
- 4. Object of the declaration (description of the battery and identification allowing traceability, and which may, where appropriate, include an image of the battery):
- 5. The object of the declaration described in point 4 is in conformity with the relevant Union harmonisation legislation: … (reference to the other Union acts applied).
- 6. References to the relevant harmonised standards or the common specifications used or references to the other technical specifications in relation to which conformity is declared:
- 7. The notified body … (name, address, number) … performed … (description of intervention) … and issued the certificate(s): … (details, including its date, and, where appropriate, information on the duration of and conditions for its validity).
- 8. Additional information
The technical documentation
Article 38(2) has the manufacturer draw up the technical documentation before placing a battery on the market. Module A of Annex VIII lists what it contains:
- a a general description of the battery and its intended use;
- b the conceptual design and manufacturing drawings and schemes of components, sub-assemblies and circuits;
- c the descriptions and explanations necessary for the understanding of the drawings and schemes referred to in point (b) and the operation of the battery;
- d a specimen of the label required in accordance with Article 13;
- e a list of the harmonised standards referred to in Article 15, applied in full or in part, including an indication of which parts have been applied, a list of the common specifications referred to in Article 16, applied in full or in part, including an indication of which parts have been applied, and a list of other relevant technical specifications used for measurement or calculation purposes;
- f where the harmonised standards and the common specifications referred to in point (e) have not been applied or are not available, a description of the solutions adopted to meet the applicable requirements laid down in Articles 6, 9, 10, 12, 13 and 14 or to verify the compliance of batteries with those requirements;
- g the results of design calculations made and the examinations carried out, and the technical or documentary evidence used; and
- h the test reports.
Registration, in each Member State
Each Member State keeps its own register of producers, and a producer applies in each one where it first makes a battery available. The application carries Article 55(3):
- a) name, and brand names if available, under which the producer operates in the Member State and address of the producer, including postal code and place, street and number, country, telephone number, if any, web and email address, indicating a single contact point;
- b) national identification code of the producer, including its trade register number or equivalent official registration number and the European or national tax identification number;
- c) the category, or categories, of batteries that the producer intends to make available on the market for the first time within the territory of a Member State, namely portable batteries, industrial batteries, LMT batteries, electric vehicle batteries, or SLI batteries, and their chemistry;
- d) information on how the producer meets its responsibilities laid down in Article 56 and the requirements under Articles 59, 60 and 61, respectively: (i) for portable batteries or LMT batteries, the requirements of point (d) shall be met by providing: information in written form on the measures put in place by the producer to fulfil the producer responsibility obligations laid down in Article 56, the measures put in place to fulfil the separate collection obligations laid down in Article 59(1) or Article 60(1) with regard to the amount of batteries the producer makes available on the market in the Member State, and on the system to ensure that the data reported to the competent authorities are reliable; where applicable, the name and contact details, including postal code and place, street and number, country, telephone number, web and email address and the national identification code of the producer responsibility organisation appointed by the producer to fulfil its extended producer responsibility obligations in accordance with Article 57(1) and (2), including the trade register number or an equivalent official registration number and the European or national tax identification number of the producer responsibility organisation, and the represented producer’s mandate; (ii) for SLI batteries, industrial batteries and electric vehicle batteries, the requirements of point (d) shall be met by providing: information in written form on the measures put in place by the producer to fulfil the producer responsibility obligations laid down in Article 56, the measures put in place to fulfil the collection obligations laid down in Article 61(1) with regard to the amount of batteries the producer makes available on the market in the Member State and on the system to ensure that the data reported to the competent authorities are reliable; where applicable, the name and contact details, including postal code and place, street and number, country, telephone number, web and email address and the national identification code of the producer responsibility organisation appointed by the producer to fulfil its extended producer responsibility obligations in accordance with Article 57(1) and (2), including the trade register number or an equivalent official registration number and the European or national tax identification number of the producer responsibility organisation, and the represented producer’s mandate.
- e) a statement by the producer or, where applicable, authorised representative for extended producer responsibility or the producer responsibility organisation appointed in accordance with Article 57(1), stating that the information provided is true.
Battery due diligence
From 18 August 2027, manufacturers and importers from EUR 40 million in net turnover, alone or as a group, run a due diligence policy. It covers cobalt, natural graphite, lithium and nickel. A notified body verifies it, and a report is published every year. Regulation (EU) 2025/1561 moved the day by two years.
A regulation, with national registers
Regulation (EU) 2023/1542 applies directly in every Member State, with nothing transposed. The register of producers, the producer responsibility schemes and the penalties are still each Member State's. We have not yet read the national registers, so this page names none.
Read from the consolidated version 02023R1542-20260813 on 18 October 2026, in six languages. It carries Regulations (EU) 2024/1781, 2025/1561 and 2026/1738 and every language's corrigenda. EUR-Lex
Questions people ask
- Our product has a battery inside. Does the Regulation reach us?
- Yes. Article 1(3) covers batteries built into products. For portable and LMT batteries, Article 11 makes them removable and replaceable from 18 February 2027. Supplying them first in your Member State makes you a producer there.
- When does the battery passport apply?
- From 18 February 2027, Article 77(1), for every LMT battery, industrial battery above 2 kWh and electric vehicle battery. The same day, every battery carries a QR code, Article 13(6).
- Does battery due diligence apply to us?
- From 18 August 2027, to manufacturers and importers with a net turnover of EUR 40 million or more, or in a group above it, Articles 47 and 48. Batteries placed on the market before their second life are left out.
- Do we register once for the whole EU?
- No. A producer registers in each Member State where it first makes a battery available, Article 55(2). Selling directly to end users elsewhere, it appoints a representative in each, Article 56(3).
- Does the Regulation replace the Batteries Directive?
- Yes. Directive 2006/66/EC is repealed from 18 August 2025, Article 95, the day producer responsibility applies. The Regulation itself applies from 18 February 2024, directly, without national transposition.
Keep the battery files and the registers in one place
StandardOS holds your battery duties and the evidence for each. It drafts the declaration and the technical documentation per battery model and the register sheet per Member State, next to the other frameworks you run.
What it asks of you
88 requirements in 2 groups
Obligations
82- 6(1) Keep restricted substances within the Annex I limits
- 7(1) Draw up a carbon footprint declaration per model and plant
- 7(2) Label the carbon footprint and its performance class
and 79 more
Clauses
6- 13(7) Print the labels and QR code legibly and indelibly
- 38(11) Repurposing or remanufacturing makes you the manufacturer
- 40(1) Put the representative's mandate in writing, both signing
and 3 more
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