SLI Batteries — Starter, Lighting, and Ignition
SLI batteries are the traditional 12 V and 24 V lead-acid batteries used in conventional combustion engine vehicles. Their DPP obligation under Regulation (EU) 2023/1542 will become mandatory on 18 August 2026. SLI batteries carry a lower overall regulatory burden than EV or industrial batteries: there is no carbon footprint performance class requirement and no supply chain due diligence obligation for cobalt, lithium, or nickel.
This documentation is informational only and does not constitute legal advice. Consult qualified legal counsel for compliance decisions specific to your products and market.
Definition
SLI batteries are defined in Article 3(12) of the regulation as batteries specifically designed to provide power primarily for starting an internal combustion engine (starting), powering a vehicle's lighting systems (lighting), or supplying the ignition system (ignition) of a vehicle, and which may also power some of the vehicle's auxiliary equipment.
The SLI classification is purpose-based. The key characteristic is that the battery's primary designed function is starting the engine — not propelling the vehicle. A lead-acid 12 V battery in a conventional petrol car is an SLI battery. The same physical battery installed as auxiliary storage in a battery electric vehicle would be classified differently.
Typical SLI battery applications
| Application | Battery Type |
|---|---|
| 12 V starter battery in passenger car, van, or truck | Flooded lead-acid, AGM, EFB |
| 12 V or 24 V starter battery in motorcycle | Flooded lead-acid, AGM, lithium-ion |
| 24 V or 48 V battery in HGV or bus | Lead-acid (multiple cells) |
| Marine starter battery | Flooded lead-acid, AGM |
| Start-stop vehicle batteries (requiring fast charge acceptance) | AGM or EFB |
| Mild hybrid (MHEV) 48 V auxiliary battery | Lead-acid or lithium-ion (where ≤2 kWh and not primary traction) |
DPP Enforcement Date: 18 August 2026
The SLI battery DPP obligation will become mandatory on 18 August 2026 — approximately four months from the date of this documentation. Operators who manufacture or import SLI batteries for the EU market should be in active preparation now.
Every SLI battery placed on the EU market on or after 18 August 2026 must have a valid, accessible DPP. Batteries placed on the market before that date are not retrospectively required to have a DPP, but stock that has not yet been placed on the market (i.e. in distributor warehouses awaiting sale) after 18 August 2026 must comply.
Regulatory Burden Compared to EV and Industrial Batteries
SLI batteries have a significantly lower DPP data burden than EV or industrial batteries:
| Obligation | SLI Batteries | EV/Industrial Batteries |
|---|---|---|
| DPP mandatory | Yes (from 18 Aug 2026) | Yes (already mandatory) |
| Carbon footprint declaration | No | Yes |
| Carbon footprint performance class | No | Yes |
| Supply chain due diligence (cobalt, lithium, nickel) | No | Yes |
| Recycled content — cobalt, nickel, lithium | No | Yes |
| Lead recycled content (85% minimum) | Yes | Yes (where lead used) |
| EU Battery Database registration | Yes | Yes |
| EPR take-back scheme | Yes | Yes |
| CE marking and DoC | Yes | Yes |
Lead Recycled Content
The lead recycled content requirement — a minimum of 85% recycled lead — applies to all batteries containing lead, including SLI batteries. This threshold reflects a pre-existing industry standard: the lead-acid battery industry already operates at or above 85% recycled lead content in Europe through well-established collection and smelting infrastructure.
For most SLI battery manufacturers, the 85% lead recycled content requirement is not a new compliance burden but does require:
- Verification and documentation of the actual recycled lead content in each production batch
- Inclusion of the declared (and eventually verified) figure in the DPP
The 85% threshold is effective from the DPP mandatory date (18 August 2026). Third-party verification of lead recycled content will be required — the regulation's verification requirements for recycled content apply across all categories where recycled content declarations are mandated.
EU Battery Database Registration
All SLI battery producers (manufacturers and importers) must register in the EU Battery Database, operated by the European Environment Agency (EEA), before placing SLI batteries on the EU market. Registration must be completed before the DPP mandatory date.
The producer's registration number must be included in every SLI battery DPP. Failure to register in the EU Battery Database means the battery cannot legally be placed on the EU market, regardless of whether a DPP is present.
Labelling Requirements
SLI batteries must carry the following labels on the physical battery:
| Label | Requirement |
|---|---|
| Crossed-out wheelie bin symbol | Mandatory — indicates separate collection obligation, must not be disposed of as general waste |
| Chemical hazard symbols | CLP hazard pictograms where applicable (e.g. corrosive symbol for sulphuric acid in flooded lead-acid batteries) |
| Lead content symbol | "Pb" symbol indicating presence of lead |
| CE marking | Mandatory |
| Capacity | For consumer-facing SLI batteries: capacity declaration (Ah) |
| QR code | Mandatory from 18 August 2026 — links to DPP |
The QR code must be permanently affixed to the battery and must remain legible for the battery's lifetime. For SLI batteries, which are typically installed under a vehicle's bonnet in demanding thermal and chemical environments, the durability of the QR code label is a practical consideration that should be addressed in product design.
EU Declaration of Conformity
SLI battery manufacturers must issue an EU Declaration of Conformity (DoC) confirming that the battery meets all applicable requirements of the regulation. The DoC must:
- Identify the battery model to which it applies
- List the applicable requirements of the regulation that have been assessed
- Reference the harmonised standards and/or technical specifications applied
- Be signed by a person with appropriate authority within the manufacturing organisation
- Be retained for ten years after the last battery to which it applies was placed on the market
The DoC reference number and date must be included in the DPP.
Extended Producer Responsibility
SLI batteries are subject to extended producer responsibility (EPR) requirements under Chapter VIII of the regulation. Producers must:
- Register in the EU Battery Database in each member state where batteries are placed on the market (or use a pan-EU collective scheme where available)
- Join or establish a collective take-back scheme that organises collection of end-of-life SLI batteries from collection points (garages, automotive retailers, recycling centres)
- Fund the costs of collection, sorting, and recycling
- Meet collection rate targets set by the regulation and national implementing legislation
- Report annually on volumes placed on the market and volumes collected
The SLI battery sector has well-established take-back and recycling infrastructure across most EU member states. Producers must ensure their EPR scheme registration is documented and that the scheme's contact details and collection point information are included in the DPP.
Preparation Timeline for SLI Battery Manufacturers
With approximately four months until the 18 August 2026 DPP mandatory date, the recommended preparation steps are:
- Now: Confirm your producer registration status in the EU Battery Database. If not registered, begin the registration process immediately.
- Now: Inventory all SLI battery models currently in production for the EU market and create draft DPPs for each model in Traceable.
- Next 4–6 weeks: Collect and verify lead recycled content data from your suppliers. Obtain verification documentation.
- 6 weeks before deadline: Finalise QR code design, material specification, and label placement on physical batteries. Order QR code labels for your production line.
- 4 weeks before deadline: Test QR code scannability on physical batteries (check durability, readability, link resolution).
- 2 weeks before deadline: Publish all DPPs in Traceable and confirm that QR codes link correctly to live, accessible DPP records.
- At deadline: All batteries in your pipeline entering the EU market from 18 August 2026 must carry a valid QR code and have an accessible DPP.