Enforcement timeline
This page provides a chronological reference of mandatory enforcement dates under Regulation (EU) 2023/1542 (the EU Battery Regulation). Dates are organised by obligation type and battery category.
This documentation is informational only and does not constitute legal advice. Enforcement dates are subject to change through delegated acts and implementing regulations issued by the European Commission. Consult qualified legal counsel and monitor the Official Journal of the European Union for updates.
Master Timeline Table
| Date | Obligation | Battery Categories | Regulation Reference |
|---|---|---|---|
| 18 Feb 2024 | Regulation enters into force | All | Art. 96 |
| 18 Aug 2024 | EV battery DPP mandatory | EV | Art. 8, Art. 77 |
| 18 Aug 2024 | Carbon footprint calculation methodology delegated act must be published | EV, Industrial | Art. 7(1) |
| 18 Feb 2025 | Carbon footprint declaration mandatory | EV | Art. 7(1) |
| 18 Feb 2025 | Industrial battery DPP mandatory — phased (subject to delegated act) | Industrial | Art. 8, Art. 77 |
| 18 Aug 2025 | Industrial battery DPP mandatory | Industrial | Art. 8, Art. 77 |
| 18 Aug 2025 | LMT battery DPP mandatory | LMT | Art. 8, Art. 77 |
| 18 Aug 2025 | Carbon footprint declaration mandatory | Industrial | Art. 7(2) |
| 18 Feb 2026 | Carbon footprint performance class mandatory | EV | Art. 7(2) |
| 18 Aug 2026 | SLI battery DPP mandatory | SLI | Art. 8 |
| 18 Aug 2026 | Portable battery DPP mandatory | Portable | Art. 8 |
| 18 Aug 2026 | Carbon footprint performance class mandatory | Industrial | Art. 7(2) |
| 1 Jan 2030 | Recycled content minimum thresholds — first tranche | EV, Industrial | Art. 8, Annex VIII |
| 1 Jan 2035 | Recycled content minimum thresholds — second tranche | EV, Industrial | Art. 8, Annex VIII |
| Ongoing | Additional delegated acts may modify or add dates | All | Multiple articles |
Detailed Breakdown by Obligation
Digital Product Passport (DPP)
The DPP mandate is being phased in by battery category. Once the mandatory date has passed for a category, no battery of that type may be placed on the EU market without a valid, accessible DPP.
| Battery Category | DPP Mandatory From | Status (as of April 2026) |
|---|---|---|
| EV batteries | 18 August 2024 | Currently mandatory |
| Industrial batteries | 18 August 2025 | Currently mandatory |
| LMT batteries | 18 August 2025 | Currently mandatory |
| SLI batteries | 18 August 2026 | Upcoming (approx. 4 months) |
| Portable batteries | 18 August 2026 | Upcoming (approx. 4 months) |
Implication for Traceable users: If you manufacture or import EV, industrial, or LMT batteries, the DPP obligation is already in force. Every battery you place on the EU market must have a live, accessible DPP with the required data fields populated. SLI and portable battery manufacturers should begin DPP preparation immediately to ensure readiness before August 2026.
Carbon Footprint Declarations
Carbon footprint declarations are required for EV and industrial batteries. The obligation is split into two phases: first, a declaration of the calculated carbon footprint value; second, the assignment of a carbon footprint performance class (A through E, where A is the lowest footprint) based on thresholds set by delegated act.
| Obligation | Battery Category | Mandatory From |
|---|---|---|
| Carbon footprint declaration (value) | EV | 18 February 2025 |
| Carbon footprint declaration (value) | Industrial | 18 August 2025 |
| Carbon footprint performance class | EV | 18 February 2026 |
| Carbon footprint performance class | Industrial | 18 August 2026 |
Carbon footprint is not required for LMT, SLI, or portable batteries.
Calculation methodology: The carbon footprint must be calculated in accordance with the methodology established in the Commission's delegated act under Article 7(1). The methodology is based on the Product Environmental Footprint (PEF) Category Rules for rechargeable batteries. Operators must retain supporting documentation (a carbon footprint study or LCA report) for the lifetime of the battery plus ten years.
Recycled Content
Minimum recycled content requirements apply to four materials used in battery manufacturing: cobalt, lithium, nickel, and lead. The thresholds are tiered by material and by date.
| Material | Battery Category | Minimum from 2030 | Minimum from 2035 |
|---|---|---|---|
| Cobalt | EV, Industrial | 16% | 26% |
| Lithium | EV, Industrial | 6% | 12% |
| Nickel | EV, Industrial | 6% | 15% |
| Lead | SLI (and others where used) | 85% | 85% |
Notes:
- Lead recycled content at 85% reflects the pre-existing standard for lead-acid SLI batteries and was already the industry norm before the regulation.
- Recycled content declarations must be included in the DPP from the DPP mandatory date for the relevant category. The minimum thresholds only become legally enforceable from 2030.
- From 2030 onwards, batteries that do not meet the minimum recycled content thresholds may not be placed on the EU market.
Supply Chain Due Diligence
Supply chain due diligence obligations under Article 72 apply to industrial and EV batteries. The obligation requires operators to implement a due diligence policy addressing the sourcing of cobalt, cobalt compounds, natural graphite, lithium, lithium compounds, and nickel.
The geographic origin of these materials must be declared in the DPP from the DPP mandatory date for the relevant battery category.
| Obligation | Battery Category | Mandatory From |
|---|---|---|
| Supply chain due diligence policy | EV | 18 August 2024 |
| Supply chain due diligence policy | Industrial | 18 August 2025 |
| Geographic origin in DPP | EV | 18 August 2024 |
| Geographic origin in DPP | Industrial | 18 August 2025 |
Supply chain due diligence is not required for LMT, SLI, or portable batteries.
EU Battery Database Registration
All producers (manufacturers and importers) must register in the EU Battery Database operated by the European Environment Agency (EEA) before placing batteries on the EU market. The registration requirement applies from the regulation's entry into force (18 February 2024), though the database is being implemented in phases.
Registration details (producer registration number, national EPR scheme references) must be recorded in the battery DPP.
Conformity Assessment and CE Marking
CE marking and Declaration of Conformity obligations apply to batteries within scope from the relevant DPP mandatory dates. For battery categories where third-party conformity assessment is required (e.g. for carbon footprint performance class, recycled content verification), the involvement of a notified body is required from the relevant obligation dates.
Delegated Acts and Future Changes
The Battery Regulation delegates significant powers to the European Commission to issue supplementary legislation (delegated acts and implementing acts). These acts may:
- Set the detailed methodology for carbon footprint calculations
- Establish the thresholds for carbon footprint performance classes
- Set the format and minimum data requirements for the DPP (the "battery passport" format)
- Adjust the timeline for specific obligations
- Add requirements for battery categories not fully addressed in the main regulation
Operators should monitor the European Commission's work programme and the Official Journal for delegated acts that may affect their compliance obligations. Traceable monitors regulatory developments and updates the platform's data models and field requirements as new delegated acts come into force.
Practical Preparation Guidance for Traceable Users
If your DPP obligation is already in force (EV, Industrial, LMT)
- Every battery you place on the EU market must have a DPP created and published on Traceable (or another compliant DPP system) before it ships.
- The DPP must be accessible via a QR code affixed to the battery.
- All mandatory data fields for your battery category must be populated — incomplete DPPs do not satisfy the regulation.
- Carbon footprint declarations (for EV and industrial) must be populated from the relevant dates above.
If your DPP obligation is upcoming (SLI, Portable — August 2026)
Recommended preparation timeline:
- Now: Complete your product data inventory — collect battery identifiers, specifications, chemistry data, and supplier information.
- 3 months before deadline: Create draft DPPs for all product lines and identify data gaps.
- 6 weeks before deadline: Have QR codes designed, printed, and tested on physical batteries.
- At deadline: All batteries in your supply chain or warehouse that will be placed on the EU market after the deadline must carry a valid QR code linking to a live DPP.
For all categories: recycled content 2030
Recycled content declarations in the DPP are a data-entry obligation that begins from the DPP mandatory date. The minimum thresholds become enforceable from 2030. Operators should begin engaging with their material suppliers now to obtain verified recycled content data, as third-party verification will be required for cobalt, lithium, nickel, and lead content declarations.