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. SLI batteries have no battery-passport obligation under Article 77 of Regulation (EU) 2023/1542 — there is no Article 77 battery passport for this category at any date. SLI batteries do, however, remain subject to other obligations, including the recycled-content obligation under Article 8, labelling, CE marking and Declaration of Conformity, and extended producer responsibility. There is no carbon footprint declaration or performance-class requirement for SLI batteries under Article 7.
This documentation is provided for informational purposes only. It is not legal advice and does not constitute a compliance guarantee, certification, or attestation of conformity with Regulation (EU) 2023/1542. Operators remain solely responsible for their own compliance and should consult qualified regulatory counsel.
Definition
SLI batteries are defined in Article 3(1)(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) |
No Battery-Passport Obligation
SLI batteries have no battery-passport (DPP) obligation under Article 77 of the Regulation. Article 77(1) sets a single battery-passport start date of 18 February 2027 that applies only to LMT batteries, industrial batteries above 2 kWh and EV batteries. SLI batteries are not in that list, so no battery passport is required for SLI batteries at any date.
Dates that some sources attribute to an "SLI DPP" (for example 18 August 2026) do not exist in the Regulation. SLI batteries do remain subject to the other obligations described on this page — recycled content (Article 8), labelling, CE marking and Declaration of Conformity, and extended producer responsibility.
Regulatory Burden Compared to EV and Industrial Batteries
SLI batteries carry a lower overall burden than EV or industrial batteries, most notably because they have no battery-passport obligation:
| Obligation | SLI Batteries | EV / Industrial (>2 kWh) Batteries |
|---|---|---|
| Battery passport (Art. 77) | No Art. 77 obligation | Yes — from 18 Feb 2027 |
| Carbon footprint declaration (Art. 7) | No | Yes |
| Carbon footprint performance class (Art. 7) | No | Yes |
| Supply-chain due diligence (Art. 48) | Applies from 18 Aug 2027 (postponed by Regulation (EU) 2025/1561 from 18 Aug 2025), subject to the turnover exemption in the first paragraph of Article 47 (in practice limited for lead-acid SLI because they contain little/none of the Annex X regulated materials — cobalt, natural graphite, lithium, nickel). | Yes |
| Recycled content (Art. 8) — cobalt, lithium, nickel, lead | In scope — declaration from 18 Aug 2028; minimum shares from 18 Aug 2031, rising 18 Aug 2036 | Yes |
| Producer 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
- Declaration of the recycled-content figure (declared and, in due course, third-party verified) under Article 8; SLI batteries have no Article 77 battery passport, so the figure is recorded in the operator's Article 8 documentation rather than in a battery passport
Under Article 8, the recycled-content declaration applies from 18 August 2028 and the enforceable minimum shares (including the lead minimum) apply from 18 August 2031, rising from 18 August 2036. These dates are set by the Regulation and its implementing acts; consult the current Official Journal text for the figures applicable to each material and date. Third-party verification of recycled-content data will be required.
EU Battery Database Registration
All SLI battery producers (manufacturers and importers) must register as producers before placing SLI batteries on the EU market. Producer registration is made in the national producer register of each Member State where batteries are placed on the market (Article 55).
Failure to register means the battery cannot legally be placed on the EU market. SLI batteries have no Article 77 battery passport, so the registration number is recorded in the operator's own records and provided to authorities on request rather than in a battery passport.
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 / data carrier | Not applicable — SLI batteries have no Article 77 battery passport, so no battery-passport data carrier is required |
Because SLI batteries have no Article 77 battery passport, there is no battery-passport QR code requirement for this category. The physical labels above (separate-collection symbol, hazard pictograms, lead symbol, CE marking and, where applicable, capacity) still apply under the Regulation's labelling rules.
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 must be kept available and provided to authorities on request. SLI batteries have no Article 77 battery passport in which to record the DoC reference.
Extended Producer Responsibility
SLI batteries are subject to extended producer responsibility (EPR) requirements under Chapter VIII of the regulation. Producers must:
- Register in the national producer register of 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 available to consumers and authorities. SLI batteries have no Article 77 battery passport in which to record this information.
Preparation Guidance for SLI Battery Manufacturers
SLI batteries have no Article 77 battery-passport obligation, so there is no DPP publication deadline to plan for. The obligations that do apply to SLI batteries can be prepared for as follows:
- Producer registration: Confirm your producer registration status in the national producer register of each Member State where you place batteries on the market. If not registered, begin the process before placing batteries on the market.
- Recycled content (Article 8): Collect and verify recycled-content data from your suppliers ahead of the 18 August 2028 declaration date, and track the minimum shares that apply from 18 August 2031.
- Labelling and CE marking: Ensure the physical labels (separate-collection symbol, hazard pictograms, lead symbol, CE marking and, where applicable, capacity) are correct on each battery model.
- Declaration of Conformity: Maintain a current EU Declaration of Conformity for each battery model and retain it for 10 years after the last battery to which it applies is placed on the market.
- Extended producer responsibility: Confirm membership of a collective take-back scheme and that collection and reporting obligations are met.
Traceable can help SLI operators capture and structure this data, but doing so does not by itself make a product compliant — this is not a compliance guarantee.