Regulation (EU) 2023/1542

The EU Battery Regulation, without the legalese.

Regulation (EU) 2023/1542 ties market access to a battery's data. Here is what the passport requires, who it applies to and exactly when — with every date cited to the article and CELEX identifier it comes from, so you can check us.

2023/1542
The Batteries Regulation, which replaced Directive 2006/66/EC. Work from the consolidated text: the original 2023 Official Journal version is missing Article 77(10), which was added later by corrigendum.
Source: CELEX 02023R1542-20250731
Art. 77(1)
The article that creates the battery passport and fixes its scope — LMT batteries, electric vehicle batteries and industrial batteries above 2 kWh.
Source: CELEX 32023R1542
The date a passport becomes a condition of placing those batteries on the EU market.
Source: Art. 77(1) · CELEX 32023R1542

The compliance timeline

Verified against EUR-Lex rather than reproduced from a vendor deck. Several of these deadlines have already been missed by the Commission, and one of the dates below is not a fixed date at all.

In force
Adopted and applying today.
Upcoming
A statutory date that has not yet been reached.
Overdue
The deadline has passed and the act has still not been adopted.
Conditional
The date is contingent on an act that does not yet exist, so it is expected to move.
  1. Overdue

    EV carbon-footprint methodology was due

    Article 7(1) required the Commission to adopt, by this date, the delegated act setting the carbon-footprint calculation methodology for electric vehicle batteries. A draft was published for feedback in April 2024 and remains unadopted. As of July 2026 no delegated or implementing act has been adopted under Article 7 at all, so the declaration obligation has not in fact taken effect.

    Source: Art. 7(1), fourth subpara., point (a) · CELEX 32023R1542

  2. Overdue

    Industrial-battery methodology was due

    The same obligation for rechargeable industrial batteries, other than those with exclusively external storage, fell due on this date and is likewise unadopted. The Article 7(2) performance-class delegated act for EV batteries carried the same deadline and is also outstanding. One correction worth making: Commission Delegated Regulation (EU) 2025/606 is widely cited as a carbon-footprint act. It is not — it sets recycling-efficiency and material-recovery methodology under Article 71(4).

    Source: Art. 7(1), fourth subpara., point (b); Art. 7(2) · CELEX 32023R1542

  3. In force

    Due diligence postponed by two years

    Regulation (EU) 2025/1561 of the European Parliament and of the Council of 18 July 2025 — a co-decided regulation, not a Commission delegated act — entered into force the day after publication and postponed the Article 48 supply-chain due-diligence obligations from 18 August 2025 to 18 August 2027.

    Source: Regulation (EU) 2025/1561, Art. 1 · CELEX 32025R1561

  4. Upcoming

    Commission due-diligence guidelines due

    The same regulation moved the deadline for the Commission's due-diligence guidelines from 18 February 2025 to this date. The guidelines are what operators need in order to build an Article 48 policy that will survive verification.

    Source: Art. 48, as amended by Regulation (EU) 2025/1561 · CELEX 32025R1561

  5. Upcoming

    Passport registry rules enter into force

    Commission Implementing Regulation (EU) 2026/1778 of 16 July 2026 lays down the implementation arrangements for the digital product passport registry set up under the Ecodesign Regulation (EU) 2024/1781, and batteries under Article 77 are expressly within its scope. It reaches battery makers through Article 77(10) of the Batteries Regulation — a paragraph that exists only in the consolidated text, added by corrigendum — which requires the operator placing the battery on the market to upload the unique identifier into that registry. Treat Article 77(10) and this regulation as one workflow.

    Source: Implementing Regulation (EU) 2026/1778, Art. 24; Art. 77(10) · CELEX 32026R1778

  6. Upcoming

    Recycled-content methodology delegated act due

    Article 8(1) requires a delegated act establishing the methodology for calculating and verifying recycled content. No draft has been published for feedback and adoption is only planned for the third quarter of 2026, so this deadline is expected to be missed. It matters beyond itself: the declaration duty below runs from whichever is later, 18 August 2028 or 24 months after this act enters into force.

    Source: Art. 8(1), third subpara. · CELEX 32023R1542

  7. Upcoming

    Access-rights implementing act due

    Article 77(9) requires the Commission to adopt, by this date, an implementing act specifying who counts as a person with a legitimate interest and what passport data they may access, download, share, publish and re-use. The file is still at planning stage, no draft has been published for feedback, and the Commission's own roadmap targets the fourth quarter of 2026 — so this deadline will be missed. Until the act is adopted, the middle access tier cannot be operationalised.

    Source: Art. 77(9), first subpara. · CELEX 32023R1542

  8. Upcoming

    The battery passport becomes mandatory

    From this date every LMT battery, every industrial battery with a capacity greater than 2 kWh and every electric vehicle battery placed on the EU market or put into service must have an electronic record — the battery passport. SLI batteries and portable batteries are outside the obligation. The economic operator placing the battery on the market is responsible for the passport data being accurate, complete and up to date.

    Source: Art. 77(1) · CELEX 32023R1542

  9. Upcoming

    Member States appoint registry administrators

    Article 7(1) of Implementing Regulation (EU) 2026/1778 requires every Member State to appoint a designated national administrator to act as the single official contact point for the Commission on registry access rights — falling on the same day the passport obligation itself begins.

    Source: Implementing Regulation (EU) 2026/1778, Art. 7(1) · CELEX 32026R1778

  10. Upcoming

    Supply-chain due diligence applies

    The Article 48 due-diligence policy obligations take effect for economic operators, two years later than originally legislated. Nothing in the deferral changed the substance of what a policy has to cover — only when it has to be in place.

    Source: Art. 48, as amended by Regulation (EU) 2025/1561 · CELEX 32025R1561

  11. Conditional

    Recycled-content declaration — date not yet fixed

    Article 8(1) requires industrial batteries above 2 kWh other than those with exclusively external storage, electric vehicle batteries and SLI batteries containing cobalt, lead, lithium or nickel to carry a recycled-content declaration from 18 August 2028, or 24 months after the enabling delegated act enters into force, whichever is the latest. That act was due by 18 August 2026 and remains unadopted, so every month of delay pushes this date back. Plan against it as a floor, not a fixture.

    Source: Art. 8(1), first subpara. · CELEX 32023R1542

  12. Upcoming

    Minimum recycled-content shares apply

    Minimum shares of recycled cobalt (16%), lead (85%), lithium (6%) and nickel (6%) apply to industrial batteries above 2 kWh other than those with exclusively external storage, electric vehicle batteries and SLI batteries. LMT batteries sit outside these shares — not through an express exclusion, but because Article 8(2) simply does not list them.

    Source: Art. 8(2) · CELEX 32023R1542

  13. Upcoming

    LMT recycled-content declaration begins

    The second subparagraph of Article 8(1) defers the declaration duty for LMT batteries to this date, five years behind the general one.

    Source: Art. 8(1), second subpara. · CELEX 32023R1542

  14. Upcoming

    Shares rise — and LMT batteries are included

    Minimum shares rise to 26% cobalt, 85% lead, 12% lithium and 15% nickel. Article 8(3) expressly names LMT batteries this time, so the earlier carve-out does not survive to 2036. Any source that says LMT batteries are excluded from recycled-content shares without a date attached is only half right.

    Source: Art. 8(3) · CELEX 32023R1542

Every date on this page comes from the operative text of the instrument cited beside it, verified against EUR-Lex in July 2026. Where an act is overdue, or a date is contingent on an act that does not yet exist, we say so rather than round it into a clean number. Dates in this area move — the due-diligence obligation has already slipped by two years. Battery Digital Passport is not affiliated with the European Commission and this page is not legal advice.

Who sees what: tiered access

The regulation deliberately does not make everything public. Article 77(2) serves passport data in tiers, so that commercial and safety-sensitive information reaches only those entitled to it. One of those tiers has not yet been legally defined.

  1. Tier 1

    Public

    Anyone who scans the QR code: manufacturer and model, battery category, chemistry family, the carbon-footprint declaration and class, recycled-content shares and basic safety information.

    Art. 77(2)

  2. Tier 2

    Legitimate interest

    Repairers, remanufacturers, second-life operators and recyclers, plus the Commission: detailed composition, dismantling and safety guidance, and the state-of-health data needed to do the work.

    Not yet settledArticle 77(9) required the Commission to adopt, by 18 August 2026, an implementing act specifying exactly who qualifies as a person with a legitimate interest and what they may access, download, share, publish and re-use. As of July 2026 that act is at planning stage with no published draft, and the Commission's roadmap targets the fourth quarter of 2026. Until it lands, the boundary of this tier is a design assumption rather than settled law — including ours. We track the file and will update this page when it is adopted.

    Art. 77(2)(c) · Annex XIII, points 2 and 4

  3. Tier 3

    Authorities

    Notified bodies, market surveillance authorities and the Commission: the full record, including conformity documentation and due-diligence reporting.

    Art. 77(2)

What non-compliance costs

Article 77(1) is drafted as a condition of market access: from 18 February 2027 a covered battery placed on the EU market or put into service shall have a battery passport. There is no grace period in the text. Article 77(4) puts responsibility for that data being accurate, complete and up to date on the economic operator placing the battery on the market — it may authorise another operator in writing to act on its behalf, but the exposure stays where it is. Penalties are set by each Member State and therefore vary; the loss of market access does not.

Source: Art. 77(1) · Art. 77(4)

Open standards, and no vendor lock-in

Article 77(5) requires all passport information to be based on open standards and in an interoperable format, transferable through an open interoperable data exchange network without vendor lock-in, machine-readable, structured and searchable. The phrase vendor lock-in is in the operative text, not our gloss. Article 78(e) goes further: the passport must remain available after the economic operator ceases to exist or ceases its activity in the Union — while specifying no custodian, escrow arrangement or duration for achieving that. On standards: the six CEN/CLC/JTC 24 digital product passport standards, EN 18216, 18219, 18220, 18221, 18222 and 18223, were cited in the Official Journal by Implementing Decision (EU) 2026/1736 in support of the Ecodesign Regulation (EU) 2024/1781 only. No equivalent citation has been made under the Batteries Regulation, so they confer no presumption of conformity for battery passports today.

Source: Art. 77(5) · Art. 78(e)

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