SLI Batteries — Starter, Lighting, and Ignition
SLI batteries are batteries "specifically designed to supply electric power for starting, lighting, or ignition" (Article 3(1), point (12)), such as the 12 V and 24 V 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 supply electric power for starting, lighting, or ignition and that can also be used for auxiliary or backup purposes in vehicles, other means of transport or machinery".
The SLI classification is purpose-based. The key characteristic is that the battery is "specifically designed to supply electric power for starting, lighting, or ignition" (Article 3(1)(12)); starting the engine is one of those functions, not the only one. A lead-acid 12 V battery in a conventional petrol car is an SLI battery. The definition also covers a battery that "can also be used for auxiliary or backup purposes in vehicles, other means of transport or machinery", so using an SLI battery for auxiliary storage does not by itself change its category.
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 specifically designed for starting, lighting or ignition; the SLI definition has no capacity threshold) |
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 August 2028 or 24 months after the date of entry into force of the delegated act referred to in the third subparagraph, whichever is the latest; 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 from 18 August 2031 to SLI batteries, electric vehicle batteries and industrial batteries with a capacity greater than 2 kWh, except those with exclusively external storage, that contain cobalt, lead, lithium or nickel in active materials, and from 18 August 2036 also to LMT batteries (Article 8(2) and (3)); it does not apply to portable 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 for each battery model per year and per manufacturing plant
- 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 or 24 months after the date of entry into force of the delegated act referred to in the third subparagraph, whichever is the latest, and the enforceable minimum shares (including the lead minimum) apply from 18 August 2031, rising from 18 August 2036. These dates and figures are set in Article 8; 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, importers, distributors or other persons meeting the definition in Article 3(1), point (47)) 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 |
| Hazardous substances | From 18 August 2026 or 18 months after the date of entry into force of the implementing act referred to in paragraph 10, whichever is the latest (Article 13(1)), the label contains "the hazardous substances present in the battery, other than mercury, cadmium or lead" (Annex VI, Part A, point 8) |
| Lead content symbol | "Pb" where the battery contains more than 0.004 % lead (Article 13(5)) |
| CE marking | Mandatory |
| Capacity | From 18 August 2026 or 18 months after the date of entry into force of the implementing act referred to in paragraph 10, whichever is the latest, a label containing information on the battery's capacity (Article 13(2)) |
| QR code | Mandatory from 18 February 2027 under Article 13(6) and Annex VI, Part C. SLI batteries have no Article 77 battery passport; the QR code gives access to the information in Article 13(6), point (b), and, under point (c), "the amount of cobalt, lead, lithium or nickel recovered from waste and present in active materials in the battery, calculated in accordance with Article 8" |
SLI batteries have no Article 77 battery passport, but Article 13(6) still applies: "From 18 February 2027, all batteries shall be marked with a QR code as described in Part C of Annex VI." The physical labels above (separate-collection symbol, hazardous substances, lead symbol, CE marking, the QR code and capacity) 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
- Take back waste SLI batteries free of charge and ensure they are collected separately, including through collection points set up with distributors, end-of-life vehicle treatment facilities and public authorities (Article 61(1)); producers may appoint a producer responsibility organisation (Article 57(1))
- Fund the costs of collection, sorting, and recycling
- 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, hazardous substances, lead symbol, CE marking and 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 how the take-back and separate-collection obligations in Article 61 and the reporting obligations in Article 75(2) are met, directly or through a producer responsibility organisation.
Portable and SLI battery passports cannot currently be created on the production platform: the categories are hidden and creation is rejected with "This product category is not available yet". They are available on staging only. Where an SLI template is available, it can help capture and structure this data, but doing so does not by itself make a product compliant. This is not a compliance guarantee.