EU battery regulation – Requirements, obligations, and implementation with VRI
The EU Battery Regulation (EU 2023/1542) brings significant changes for all companies that develop, manufacture, or place batteries on the market.
The new regulation may be complex – but it need not present a risk to your business. What matters is clarifying the manufacturer role early, deriving the correct obligations, and fully documenting technical requirements. VRI ensures that you act in compliance with regulations at all times, are protected from liability, and maintain all records cleanly for market surveillance authorities.
Last updated: 7 October 2026 | Basis: Battery Regulation (EU) 2023/1542, Batterierecht-Durchführungsgesetz (BattDG) | Source: EUR-Lex, Gesetze im Internet
What are the goals of the new battery regulation?
The EU battery regulation (EU 2023/1542) aims to establish uniform, binding requirements for safety, sustainability, and traceability of batteries in the EU internal market.
Key points include the introduction of a digital battery passport, stricter labeling and recycling requirements, and comprehensive documentation and record-keeping obligations. In short: The regulation sets technical, environmental, and informational minimum standards to strengthen consumer protection, circular economy principles, and market transparency.
What are the implications for businesses?
Companies that develop, manufacture, or place batteries on the market face significantly expanded obligations: they must categorize products, maintain comprehensive technical documentation, provide compliant labeling, and maintain digital product information (battery passport).
For manufacturers, importers, and OEM partners, this means: increased documentation requirements, clear allocation of responsibilities, and often necessary adaptations in development, production, and supply chain processes. At the same time, the regulation creates opportunities – such as improved market access and competitive advantages for those who implement compliance early and efficiently.
What does the new EU battery regulation govern?
The new Battery Regulation (EU) 2023/1542 governs sustainability, safety, performance, labeling, take-back and recycling of batteries across all categories: portable, SLI, industrial and electric vehicle batteries as well as batteries for light means of transport (LMT batteries).
The EU Battery Regulation applies directly and uniformly in all Member States and replaced the previous Batteries Directive 2006/66/EC with effect from 18 August 2025. Individual provisions of the Directive continue to apply for a transitional period.
In Germany, it has been supplemented since 7 October 2025 by the German implementing act, the Batterierecht-Durchführungsgesetz (BattDG), which replaced the previous Battery Act (BattG).
The digital battery passport is coming: transparency becomes mandatory
A central element of the new EU Battery Regulation is the digital battery passport. From 18 February 2027, it will be mandatory for LMT batteries, industrial batteries with a capacity above 2 kWh and electric vehicle batteries, and must be accessible via a QR code on the product.
All other batteries, i.e. portable batteries, SLI batteries and industrial batteries up to 2 kWh, do not need a battery passport, but they do need the QR code.
The battery passport contains, among other things:
- Technical data and battery specifications
- Information on material composition and material origin
- Sustainability information (e.g., carbon footprint)
- Disposal and recycling information
- EU declaration of conformity
Companies must ensure that all information is complete, up-to-date, and digitally available – with clear processes and structured data. VRI supports you in standards-compliant preparation and digital provisioning of all battery passport-relevant content.
What are the manufacturer obligations under the EU battery regulation?
In everyday usage, the obligations for batteries are simply called manufacturer obligations, but the EU Battery Regulation divides them between two roles: the manufacturer bears the product obligations, the producer bears extended producer responsibility for registration, take-back and waste management.
These requirements form the foundation for all battery regulation compliance obligations throughout the entire product lifecycle.
A manufacturer is anyone who manufactures a battery or has it designed or manufactured, and markets it under their own name or trademark or puts it into service for their own purposes. The manufacturer bears the product obligations under Article 38: conformity assessment, technical documentation, EU declaration of conformity, CE marking and retention of the documentation for ten years. Importers and distributors are considered manufacturers if they place a battery on the market under their own name or trademark, modify it in a way that may affect its compliance, or change its intended purpose (Article 44).
A producer is anyone who makes a battery available for the first time in a Member State, including batteries incorporated into an appliance or vehicle. This can also be an importer or the company that sells the battery built into its own device. The producer bears extended producer responsibility: registration (in Germany under Section 5 BattDG), take-back and financing of waste management.
If a battery is sold under a customer's brand, the customer is the manufacturer and bears the product obligations. Who bears extended producer responsibility in a Member State depends on who makes the battery available there for the first time, either on its own or incorporated into a device. In such OEM scenarios, specialised manufacturing partners such as VRI often take on large parts of the technical implementation, for example:
- Classification and categorisation of the battery
- Provision of technical data and test reports
- Support with registration, labelling and documentation
This way, responsibility as manufacturer remains with the customer, while the technical implementation stays in expert hands.
Manufacturers must be able to demonstrate that every battery meets the requirements of the EU Battery Regulation. This includes, among other things:
- Technical test reports
- Conformity documentation
- Safety and performance evidence
- Labeling and recycling information
- Complete technical product file
This documentation must be retained for at least ten years.
Obligations do not end when the battery is placed on the market. The regulation defines responsibilities over the entire service life, including:
- Cooperation with market surveillance authorities
- Take-back and recycling obligations
- Updates to product and safety information
- Evidence of sustainability and material use
- Ongoing adaptation to new regulatory requirements
Responsibility is divided between the two roles: the manufacturer is accountable for compliance and product information, the producer for registration, take-back and waste management.
Labeling and battery passport: deadlines and requirements
The labeling and information requirements of the EU Battery Regulation take effect in staggered stages. Two deadlines matter for manufacturers. However, they follow different rules.
General label: deadline tied to the implementing act
The requirements under Article 13(1) to (3) apply from 18 August 2026 or 18 months after the entry into force of the implementing act under Article 13(10) — whichever is later.
Status as of 07.October 2026: This implementing act has not yet been published in the Official Journal. A draft has been available since 15 December 2025. As 18 August 2026 has passed, the requirements under Article 13(1) to (3) will only apply 18 months after its entry into force. We monitor the situation continuously and will update this section as soon as the act enters into force.
In terms of content, the general label under Annex VI Part A requires: manufacturer, battery category, battery identification, place and date of manufacture, weight, capacity, chemical composition and the appropriate extinguishing agent. Two declaration requirements are added: hazardous substances contained other than mercury, cadmium and lead, as well as critical raw materials above 0.1 percent by weight. Rechargeable portable batteries, LMT batteries and SLI batteries must additionally state their capacity, while non-rechargeable portable batteries must carry the indication "non-rechargeable" together with the minimum average duration.
18 February 2027: QR code — this deadline is fixed
From 18 February 2027, the QR code on the product becomes mandatory. Unlike the general label, this deadline carries no reservation clause; it applies irrespective of the implementing act.
The destination of the code depends on the battery category: for light means of transport (LMT) batteries, industrial batteries above 2 kWh and electric vehicle batteries, it leads to the digital battery passport. For all other batteries, including portable batteries and industrial batteries up to 2 kWh, it points to the labeling information, the EU declaration of conformity and the information on the management of waste batteries. For SLI batteries, it also provides the amount of cobalt, lead, lithium or nickel recovered from waste and present in the battery's active materials.
How VRI implements the EU battery regulation for Its customers
To enable companies to reliably meet the complex requirements of the EU battery regulation, VRI has developed a clearly structured, comprehensively documented process. This encompasses all steps – from initial battery classification through regulatory conformity verification to long-term market surveillance. Customers benefit from high legal certainty, efficient workflows, and reliable technical expertise.
At the outset, it is determined who is the manufacturer within the meaning of the regulation, VRI itself or the customer (OEM scenario), and who, as producer, bears extended producer responsibility in each Member State.
- Checking under whose name the battery is placed on the market
- Checking who makes the battery available for the first time in which Member State
- Deriving the regulatory obligations
- Ensuring that all documentation and evidence obligations are correctly assigned
This clarification forms the basis for all subsequent steps and defines who bears which responsibility.
Each battery is then assigned to one of the five battery categories of the regulation:
- Portable battery
- Battery for light means of transport (LMT battery), e.g. for e-bikes and e-scooters
- SLI battery (starting, lighting and ignition)
- Electric vehicle battery
- Industrial battery (up to or above 2 kWh)
Correct classification determines which obligations and requirements apply, such as labelling, performance evidence or take-back requirements.
The next step is the conformity assessment under the Battery Regulation.
The procedure is governed by Article 17. For most requirements, internal production control applies (Module A). The manufacturer assesses conformity itself. Carbon footprint and recycled content, by contrast, require a notified body (Module D1 or G). These two requirements apply only to certain categories, including electric vehicle, LMT and industrial batteries above 2 kWh, and their date of application depends on delegated acts. The assessment covers:
- Restrictions of substances (Article 6)
- Performance and durability (Articles 9 and 10)
- Safety of stationary battery energy storage systems (Article 12)
- Labelling and information requirements (Articles 13 and 14)
- Carbon footprint and recycled content (Articles 7 and 8), where applicable to the category
Independently of this, the UN 38.3 transport test required under dangerous goods law for lithium batteries is taken into account.
Internal quality assurance documents all results comprehensively and creates a traceable conformity file.
After technical approval, the label is created and checked. It includes:
- CE marking
- Symbol of the crossed-out wheeled bin
- Chemical symbol Cd or Pb where the thresholds under Article 13(5) are exceeded
- Manufacturer information (VRI or customer brand)
- Capacity and system information
- QR code giving access to digital product information (from 18 February 2027)
Legibility and durability are checked against the requirements of the EU Battery Regulation. The format requirements will follow once the implementing act has entered into force.
Once the conformity assessment is complete, the EU declaration of conformity is drawn up. It is issued by the manufacturer: by VRI for batteries under the VRI name, and by the customer in the OEM case, with VRI preparing the declaration. It includes:
- Complete product and manufacturer information
- All applied legislation and standards
- Signature of the responsible person
- Electronic format, on paper on request, in the language required by the Member State concerned
- Digital access via the QR code from 18 February 2027
This provides a complete and verifiable declaration for each battery model.
Finally, a complete product file is archived for at least ten years.
This includes:
- Classification
- Inspection and test reports
- Label approvals
- Conformity documentation
- EU declarations of conformity
In parallel, the compliance department continuously monitors:
- Legislative changes
- Market feedback
- Take-back and recycling data
When changes occur, the product file is updated so that each battery continues to meet the applicable requirements.
Certainty, clarity and compliance from a single source
To meet the requirements of the EU Battery Regulation with confidence, you need clear structures and sound expertise. VRI provides both.
With a clearly structured process, in-depth understanding of standards and repeatable compliance workflows, we support you from the initial classification through to the complete declaration of conformity. We also remain your partner after market launch.
Get in touch with us! We'd be glad to help.
Steffen Weller
Vertriebsleiter / Sales Director
Official legal basis
The full text of the Battery Regulation (EU) 2023/1542 is available on the European Union's EUR-Lex portal, the German implementing act (BattDG) on the "Gesetze im Internet" portal (German only):
Official EU Battery Regulation in the EUR-Lex portal
Batterierecht-Durchführungsgesetz (BattDG) on Gesetze im Internet (German only)