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 applies, save as set out in Art. 96(2), second subparagraph, and in other provisions. It entered into force earlier, on the twentieth day following its publication in the Official Journal | All | Art. 96(1), 96(2) |
| 18 Aug 2027 | Supply chain due diligence policy obligations apply (subject to Article 47, first paragraph, under which Chapter VII does not apply to economic operators that had a net turnover of less than EUR 40 million in the financial year preceding the last financial year and that are not part of a group which, on a consolidated basis, exceeds the limit of EUR 40 million), as amended by Regulation (EU) 2025/1561 | All | 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, 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 | 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 and implementing acts set methodology, thresholds and formats; where a date is followed by "or ... whichever is the latest", their entry into force can make the obligation apply later; the Commission may amend the recycled-content targets by delegated act (Art. 8(5)) | 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 the QR code referred to in Article 13(6), which all batteries must bear from 18 February 2027 as described in Annex VI Part C. The QR code must be printed or engraved visibly, legibly and indelibly on the battery; only where this is not possible or not warranted on account of the nature and size of the battery is it affixed to the packaging and to the documents accompanying the battery (Article 13(7)). The Regulation mandates the QR code; alternative types of smart labels can be provided for only by Commission delegated act (Article 13(8)).
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 the latest — 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), second subparagraph, point (a) | 18 February 2025 or 12 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest. 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; that is guidance and does not change the date Art. 7(1) sets. Traceable's publish gate does not block on empty EV carbon-footprint fields on any date, because those fields are optional on the EV template. The platform records 18 February 2028 as the date from which its carbon-footprint value checks (stage shares and declaration expiry) change from a warning to a block; this is a platform setting, not a date in the Regulation |
| 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), second subparagraph, point (b) | 18 February 2026 or 18 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest. The Commission was to adopt the delegated act and the implementing act referred to in Art. 7(1), fourth subparagraph, points (a) and (b), by 18 February 2025 for these batteries; the date on which the declaration binds depends on when those acts enter into force |
| Carbon-footprint declaration (value) | Rechargeable industrial >2 kWh with external storage; Art. 7(1), second subparagraph, point (d) | 18 August 2030 or 18 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest |
| Carbon-footprint declaration (value) | LMT, Art. 7(1), second subparagraph, point (c) | 18 August 2028 or 18 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest |
| Carbon-footprint performance class | EV (18 August 2026), rechargeable industrial >2 kWh except those with exclusively external storage (18 August 2027), LMT (18 February 2030), rechargeable industrial >2 kWh with external storage (18 February 2032); Art. 7(2), third subparagraph, points (a) to (d) | Each date applies "or 18 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest"; the same guidance marks the label not to be filled or displayed pending the implementing act, and guidance does not change these dates |
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; the Commission's guidance marks the datapoint "not to be filled/displayed as of February 2027", and guidance does not change the Regulation. The carbon-footprint fields are optional on every battery template, so an empty field does not block publication on any date. On the date the platform records for each category (EV, industrial and stationary 18 February 2028; LMT 18 August 2028) its carbon-footprint value checks start to block instead of warn, and the compliance score starts to count the carbon-footprint attributes as mandatory. These are platform settings, not statements about the Regulation. Until September 2026 the platform treated EV carbon footprint as in force from 18 February 2025; the platform changed that setting in September 2026 to follow the guidance.
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 or 24 months after the date of entry into force of the delegated act referred to in the third subparagraph, whichever is the latest |
| 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 minimum shares are set in Article 8(2) and (3) (see the master table above); the Commission may amend them by delegated act under Article 8(5).
- The recycled-content declaration is a data obligation 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 (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 per-metal recycled-content declarations for any battery category today. The four recycled-content fields are optional on every battery template and do not block publication. The compliance score starts to count them as mandatory from the date the platform records for the category (EV, industrial and stationary 18 August 2028; LMT 18 August 2033). Declared values below the Article 8 minimum shares block publication from 18 August 2031 (EV, SLI, industrial above 2 kWh) and 18 August 2036 (adds LMT).
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 Article 47, first paragraph, under which Chapter VII does not apply to economic operators that had a net turnover of less than EUR 40 million in the financial year preceding the last financial year and that are not part of a group which, on a consolidated basis, exceeds the limit of EUR 40 million.
Due diligence is a policy-and-reporting obligation on the operator; it is distinct from the battery-passport obligation, which applies from 18 February 2027 (Article 77(1)).
Producer registration
Producers (as defined in Article 3(1), point (47), which can be a manufacturer, importer or distributor) 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. Annex XIII does not list producer registration numbers or extended-producer-responsibility references among the battery passport information.
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. For the requirements laid down in Articles 7 and 8, conformity assessment is carried out under Module D1 or Module G of Annex VIII, which involve a notified body (Article 17(2)); Article 17(2) applies from 12 months after the date of the first publication of the list referred to in Article 30(2) (Article 96(2), point (b)). 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, where a date is tied to their entry into force, determine when an obligation applies. 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 QR code placement per Article 13(7) and Annex VI Part C: printed or engraved visibly, legibly and indelibly on the battery, or, only where this is not possible or not warranted on account of the nature and size of the battery, affixed to the packaging and to the documents accompanying the battery.
- 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 recycled-content declaration date (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 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.