Enforcement timeline
This page provides a chronological reference of key obligation dates under Regulation (EU) 2023/1542 (the EU Battery Regulation). Dates are organised by obligation type and battery category.
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 or any other regulation. Several dates below depend on delegated or implementing acts that the European Commission has not yet adopted, and are subject to change. Operators remain solely responsible for their own compliance and should consult qualified regulatory counsel and monitor the Official Journal of the European Union.
Master Timeline Table
| Date | Obligation | Battery Categories | Regulation Reference |
|---|---|---|---|
| 18 Feb 2024 | Regulation entered into force | All | Art. 96 |
| 18 Aug 2027 | Supply chain due diligence policy obligations apply (subject to the SME exemption in Article 47, first paragraph), as amended by Regulation (EU) 2025/1561 | EV, industrial, LMT, SLI | Art. 48 (Ch. VII, Arts 47–53) |
| 18 Feb 2027 | Battery passport (DPP) mandatory — single start date | LMT, industrial >2 kWh, EV | Art. 77(1) |
| 18 Aug 2028 | Recycled-content declaration | industrial >2 kWh (except exclusively external storage), EV, SLI | Art. 8(1) |
| 18 Aug 2031 | Recycled-content minimum shares — first thresholds (16% Co, 85% Pb, 6% Li, 6% Ni) | industrial >2 kWh (except external storage), EV, SLI | Art. 8(2) |
| 18 Aug 2033 | Recycled-content declaration | LMT | Art. 8(1) second subparagraph |
| 18 Aug 2036 | Recycled-content minimum shares — second thresholds (26% Co, 85% Pb, 12% Li, 15% Ni) | industrial >2 kWh (except external storage), EV, LMT, SLI | Art. 8(3) |
| Carbon footprint (see below) | Declaration + performance class, phased | EV, industrial >2 kWh, LMT | Art. 7(1)–(3) |
| Ongoing | Delegated / implementing acts may set methodology, thresholds, formats, and adjust dates | All | Multiple articles |
SLI batteries and portable batteries have no battery-passport obligation under Article 77 at any date. Dates that some sources attribute to a "SLI/portable DPP" do not exist in the Regulation. SLI batteries are, however, in scope for the recycled-content obligation (Art. 8).
Detailed Breakdown by Obligation
Battery passport (Digital Product Passport)
Article 77(1) sets a single start date for the battery passport:
From 18 February 2027, each LMT battery, each industrial battery with a capacity greater than 2 kWh, and each electric-vehicle battery placed on the market or put into service must have a battery passport.
| Battery Category | Battery passport required | Basis |
|---|---|---|
| EV batteries | From 18 February 2027 | Art. 77(1) |
| Industrial batteries > 2 kWh | From 18 February 2027 | Art. 77(1) |
| LMT batteries | From 18 February 2027 | Art. 77(1) |
| SLI batteries | No Art. 77 passport obligation | — |
| Portable batteries | No Art. 77 passport obligation | — |
The information the passport must contain is set out in Annex XIII (via Article 77) and is organised across three access tiers: information accessible to the public; information accessible to persons with a legitimate interest and to the Commission; and information accessible to notified bodies, market-surveillance authorities and the Commission. The passport must be accessible via a data carrier (see below).
Implication for Traceable users: the battery passport is a future obligation that becomes mandatory on 18 February 2027 for LMT, industrial (>2 kWh) and EV batteries. It is not "already in force". Operators in scope should prepare their product data now, but no battery passport is legally required before that date. SLI and portable batteries are outside the passport obligation entirely.
Data carrier (QR code)
The battery passport must be accessible through a data carrier (such as a QR code) on the battery or its documentation, per Article 13(6) and Annex VI Part C. The QR code is the common data-carrier form; the Regulation specifies the carrier requirements rather than mandating a single technology.
Carbon footprint declarations
Carbon footprint obligations under Article 7(1)–(3) apply to EV batteries, rechargeable industrial batteries with a capacity greater than 2 kWh, and LMT batteries. Each obligation applies from the date below or a later date tied to the entry into force of the relevant Commission delegated/implementing act, whichever is applicable — several of these acts are not yet adopted, so the effective dates may move.
| Obligation | Battery Category | Applies from |
|---|---|---|
| Carbon-footprint declaration (value) | EV, Art. 7(1)(a) | Art. 7(1)(a)'s stated date was 18 February 2025, but the Commission's "Digital Batteries Passport — data points by category" guidance (28 July 2026, points 17-18) marks the declaration "not to be filled/displayed as of February 2027, format still to be specified in the upcoming implementing act" for all categories including EV. Pending that implementing act, the earliest realistic bind date mirrors industrial: 18 February 2028 |
| Carbon-footprint declaration (value) | Industrial >2 kWh and stationary (Art. 3 classifies stationary battery energy storage as industrial), except exclusively external storage; Art. 7(1)(b) | 18 February 2026, or 18 months after the industrial carbon-footprint delegated act enters into force, whichever is later. That delegated act is not yet adopted (the Commission's own adoption deadline is 18 August 2026), so the earliest realistic bind date is 18 February 2028 |
| Carbon-footprint declaration (value) | Industrial >2 kWh, exclusively external storage; Art. 7(1)(d) | 18 August 2030 |
| Carbon-footprint declaration (value) | LMT, Art. 7(1)(c) | 18 August 2028, or 18 months after the LMT carbon-footprint delegated act enters into force, whichever is later. That delegated act is not yet adopted, so 18 August 2028 is the earliest realistic bind date |
| Carbon-footprint performance class | EV (18 Aug 2026), industrial >2 kWh except external storage (18 Aug 2027), LMT (18 Feb 2030), industrial with exclusively external storage (18 Feb 2032) | Phased; each "or 18 months after entry into force of the delegated act, whichever latest"; the same guidance suspension applies to the label pending the implementing act |
The dates above are when each carbon-footprint declaration starts to bind, not a suggestion that the obligation is optional or has been relaxed. The obligation exists in the Regulation now for every listed category, including EV; what the Commission's guidance suspended pending the implementing act is the filling and display of the datapoint, not the obligation itself. Traceable's publish gate reflects this by treating the fields as informational until each date, not as removed or downgraded, and enforcement resumes automatically on each date. Until September 2026 the platform treated EV carbon footprint as in force from 18 February 2025; the Commission's guidance superseded that position.
Calculation methodology: the carbon footprint must be calculated in accordance with the methodology established in the Commission's delegated act under Article 7(1), based on the Product Environmental Footprint (PEF) approach for batteries. Technical documentation supporting the declaration must be retained for 10 years after the battery is placed on the market (Article 38 and Annex VIII).
Recycled content
Minimum recycled-content requirements under Article 8 apply to cobalt, lithium, nickel and lead. The obligation applies to industrial batteries (>2 kWh), EV batteries, LMT batteries and SLI batteries.
| Milestone | Applies from |
|---|---|
| Recycled-content declaration (industrial >2 kWh except exclusively external storage, EV, SLI) | 18 August 2028 |
| Recycled-content declaration (LMT) | 18 August 2033 |
| Recycled-content minimum shares — first thresholds (industrial, EV, SLI; LMT excluded) | 18 August 2031 |
| Recycled-content minimum shares — second (higher) thresholds (industrial, EV, LMT, SLI) | 18 August 2036 |
Notes:
- The specific percentage thresholds are set by the Regulation and its implementing acts; consult the current Official Journal text for the figures applicable to each material and date.
- The recycled-content declaration is a data obligation from 18 August 2028 (from 18 August 2033 for LMT, under Article 8(1) second subparagraph); the enforceable minimum shares begin on 18 August 2031 (LMT excluded from the first tier), rising on 18 August 2036 (all four categories, including LMT).
- Third-party verification of recycled-content data will be required — operators should engage suppliers early to obtain verifiable data.
- Platform behaviour today: the Commission's guidance update of 15 August 2026 (v2.0, rows 20-23) marks the four recycled-content percentages "not to be filled/displayed as of February 2027" pending Article 8 and its delegated act, so Traceable does not block publication on empty recycled-content declarations for any battery category today. The fields stay visible and marked with the date they start to bind, and enforcement resumes automatically.
Supply chain due diligence
Battery due-diligence obligations under Article 48 (Chapter VII, Articles 47–53) require economic operators placing batteries on the market to operate a due-diligence policy covering the sourcing of cobalt, natural graphite, lithium and nickel. These obligations apply from 18 August 2027 (as amended by Regulation (EU) 2025/1561), subject to the small- and medium-sized-enterprise exemption in Article 47, first paragraph.
Due diligence is a policy-and-reporting obligation on the operator; it is distinct from, and predates, the battery-passport obligation.
Producer registration
Producers (manufacturers and importers) must register in the national producer register of each Member State in which they place batteries on the market, under Article 55. This is a Member-State-level register, not a single EU database. Producer registration numbers and extended-producer-responsibility references are among the data recorded in the battery passport once that obligation applies.
Separately, Article 76 requires Member States to report aggregated calendar-year data on portable, LMT, SLI, industrial and EV batteries placed on the market to the Commission. Article 76 itself does not establish a Commission-operated battery-passport repository — the battery-passport system and its essential requirements are set out in Articles 77 and 78. It is also distinct from the national producer registers under Article 55.
A Commission-operated central registry for digital product passports is now live, however, under Article 13 of ESPR (Regulation (EU) 2024/1781), not under the Battery Regulation: the Commission launched it on 20 July 2026. Its operating rules were adopted by Commission Implementing Regulation (EU) 2026/1778 on 16 July 2026, entering into force 6 August 2026, and it explicitly covers battery passports issued under Article 77, though battery registration specifically is not yet part of its live scope (the Commission's own first stated implementation deadline for batteries is 18 February 2027). See EU Digital Product Passport Registry for the identity-verification and registration process this establishes.
Conformity assessment and CE marking
CE marking and Declaration-of-Conformity obligations apply to batteries in scope. Where third-party conformity assessment is required, a notified body is involved from the relevant obligation dates. Traceable stores the supporting documents and declarations an operator produces; it does not itself issue conformity assessments or act as a notified body.
Delegated acts and future changes
The Battery Regulation delegates significant powers to the European Commission to issue supplementary legislation (delegated and implementing acts). These may set the carbon-footprint calculation methodology and performance-class thresholds, the battery-passport data format, and may adjust timelines. Several acts relevant to the dates above are not yet adopted, so the effective dates may change.
Operators should monitor the European Commission's work programme and the Official Journal for acts that affect their obligations. Traceable tracks regulatory developments and updates the platform's data models as new acts come into force, but this tracking is provided as support and is not a substitute for the operator's own legal monitoring.
Practical preparation guidance for Traceable users
Preparing for the battery passport (LMT, industrial > 2 kWh, EV — from 18 February 2027)
- Complete your product-data inventory now: battery identifiers, specifications, chemistry data, and supplier information.
- Build draft passports on Traceable and identify data gaps well ahead of the 18 February 2027 date.
- Plan the data carrier (QR code) placement on the battery or its documentation per Article 13(6) / Annex VI Part C.
- Populate all Annex XIII information for your category before you place a battery on the market on or after the start date.
SLI and portable batteries
These categories have no battery-passport obligation under Article 77. SLI batteries remain in scope for the recycled-content obligation (Article 8) from the dates above.
Recycled content and carbon footprint
Engage material suppliers early to obtain verifiable recycled-content data ahead of the 18 August 2028 declaration date, and track the Article 7 delegated acts that fix the carbon-footprint methodology and dates for your category.
None of the above makes a product compliant on its own. Traceable helps you capture, structure and publish the required data; responsibility for meeting the Regulation rests with the operator.