Regulation · Lifecycle

EU Battery Regulation 2023/1542 — more than the passport.

The EU Battery Regulation, Regulation (EU) 2023/1542, is the rulebook for batteries in the EU: sustainability, safety, labelling and circularity. The battery passport is the data layer inside it, not the whole law.

By Nils Flagmeier · 11 years battery testing · updated 22 Sep 2026

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Not legal advice. Sources: Regulation (EU) 2023/1542, 2025/1561, DE BattDG.

2023/1542 · roadmap5 stations
  • 18 Feb 2024Regulation applies
  • 18 Aug 2025EPR · registration (DE: BattDG)
  • 18 Feb 2027Battery passport mandatory · EV, LMT, industrial
  • 18 Aug 2028Recycled-content quotas · evidence
  • Your packGap · passport fields without a source
Excerpt · demo data

Context

More than the battery passport

Regulation (EU) 2023/1542 covers product requirements, digital transparency and circularity including EPR. Battery passport requirements are the data layer inside it, not the whole rulebook. Peak 2027, day-to-day 2025/26: registration and evidence that validation teams already see in the spec.

For the test plan that means passport fields, carbon-footprint declarations and recycled-content quotas need measurable sources. Without spec-to-test mapping, fields stay empty even if UN 38.3 is green.

What must land in the spec in 2026 — and what only in 2027

A calendar date in the regulation is not the same as a requirement in the OEM spec. Validation often sees 2027 duties in 2026 as vague sentences.

Date In the regulation What validation sees in the spec
2025/26 EPR, national registration (DE: BattDG) Rarely tests — compliance, not the lab
18 Feb 2027 Battery passport + QR for EV, LMT, industrial > 2 kWh Passport fields as requirements without a source — see battery passport requirements 2027
18 Aug 2027 Due diligence (2025/1561) Supplier audits, not a homologation test
2031 / 2036 Recycled-content minima Specs often ask for evidence already

Sources: Regulation (EU) 2023/1542; 2025/1561; BattDG. Not legal advice.

Regulation

What the EU Battery Regulation 2023/1542 is

Regulation (EU) 2023/1542 has applied directly in the EU since 18 February 2024 and replaces the 2006 Batteries Directive. It covers portable, electric-vehicle, industrial and starting batteries, with different duties by category.

Conformity means the duties of your role can be evidenced. That is product requirements, the digital record (battery passport and QR from 18 February 2027 for EV, LMT and industrial batteries above 2 kWh), registration for extended producer responsibility and, from 18 August 2027, supply-chain due diligence. A passed UN 38.3 transport test on its own is not conformity.

Chemical requirements, and what the lab actually proves

The regulation restricts substances and asks for composition data. It does not define its own test series the way UN 38.3 defines transport tests T.1–T.8.

Article 6 and Annex I restrict mercury, cadmium and, for portable batteries, lead. Thresholds and exceptions live in the regulation text, not in a spec sentence that says “meet the chemical requirements”. For the test plan the split matters: a substance limit is a conformity statement with an analysis or a supplier declaration. Capacity, in-use safety and transport stay with IEC 62619 and UN 38.3. Carbon footprint and recycled content are a method and a mass balance, not abuse tests. Due diligence on cobalt, lithium, nickel and graphite is a supply-chain audit.

Sources: Regulation (EU) 2023/1542 Art. 6, Art. 77, Annex I and Annex XIII; Regulation (EU) 2025/1561. Not legal advice. Cite: cevelar.com/en/standards/eu-battery-regulation#chemische-anforderungen

Architecture

Five pillars. One lifecycle.

01

Product

Substances, safety, performance, removability, conformity.

02

Pass & QR

Digital record and QR, not just a marketing label.

03

EPR

Collection, recycling, national registers (DE: ear / OfH).

04

Due diligence

Raw materials Co, Li, Ni, graphite, start 18 Aug 2027.

05

CO₂ & recycled

3-step carbon footprint; minima 2031/2036. Track secondary law.

Calendar

What matters now

A date in the regulation is not always practice. Many CO₂ and labelling deadlines depend on delegated/implementing acts.

  1. 25/26 Base active

    EPR & national registration

    In DE: BattDG, ear, OfH per category. Without registration, no legal sales.
  2. 2026 Prep

    Label → QR → passport pilot

    Labelling, passport access, due-diligence guidelines (26 Jul 2026). Lock data models and supplier contracts now.
  3. 2027 Peak year

    QR, battery passport, removability, due diligence

    18 Feb 2027: QR for all batteries, passport for LMT / industrial > 2 kWh / EV. 18 Aug 2027: due diligence (moved by 2025/1561).
  4. 31/36 Supply chain

    Recycled-content minima

    From 18 Aug 2031 e.g. 16% Co, 6% Li, 6% Ni; higher from 2036. Industrial sourcing needs lead time.

Clarification

Three myths. One reality.

  • Myth

    “Due diligence has applied since August 2025.”

    Reality

    Moved to 18 Aug 2027 (Reg. 2025/1561). Still prepare now.

  • Myth

    “CO₂ declarations are already mandatory everywhere.”

    Reality

    Depends on delegated/implementing acts. Calendar ≠ practice; track secondary law.

  • Myth

    “Only manufacturers are in scope.”

    Reality

    Importers, distributors, authorised representatives, second life, fulfilment: check roles.

Actor view

Who must do what?

Manufacturer

Conformity, passport data, due diligence, EPR. Second life needs a new, linked passport.

Importer

Market-access duties, registers, supply-chain evidence. Often the operational bottleneck.

Distributor / AR

In DE: ear and authorised representative per category. Without proof, no legal sales.

Action plan

90 days. Five steps.

For validation and compliance teams: spec mapping and passport pilots run in parallel with register work.

  1. Clarify roles Manufacturer, importer, authorised representative, second life, fulfilment.
  2. Registers & EPR Check ear / OfH (or national equivalent) per battery category.
  3. Data model Lock passport fields, owners and verification methods.
  4. Supply chain Start due-diligence lead time and spec evidence.
  5. Passport pilot Aggregation → register → scan before 2027 hard-starts.

2023/1542

Conformity evidence, the February 2027 mandate, and passport software

Conformity with Regulation (EU) 2023/1542 is product rules, EPR and due diligence evidenced for your role. The battery passport becomes mandatory on 18 February 2027 for EV, LMT and industrial batteries above 2 kWh. Software that writes fields and QR codes does not create that conformity.

What has to exist before the field is filled: a source in the OEM spec, a test report or a declaration, and an owner. UN 38.3 and IEC 62619 cover transport and in-use safety. Carbon footprint and recycled content come from the supply chain. Due diligence from 18 August 2027 is an audit, not a lab test.

The German guide maps those fields: Batteriepass-Anforderungen 2027. English: battery passport requirements 2027.

FAQ

Conformity, briefly

The questions validation teams in Europe are searching right now.

What is the EU Battery Regulation 2023/1542?

Regulation (EU) 2023/1542 replaces the 2006 Batteries Directive and governs sustainability, safety, EPR and the digital battery passport across the full lifecycle.

What does conformity with the Battery Regulation mean?

Product rules, digital transparency (battery passport/QR), EPR registers and due diligence are evidenced for your role. Without mapping OEM specs onto UN 38.3, IEC 62619 and passport fields, gaps stay until the audit.

When does the digital battery passport become mandatory?

For LMT, EV and industrial batteries above 2 kWh from 18 February 2027. Guide: Battery passport requirements.

Has due diligence applied since August 2025?

No. Regulation (EU) 2025/1561 moved the start to 18 August 2027. Preparation should still start now.

What must land in the spec in 2026 versus 2027?

2026: EPR/register and passport fields with a source. 18 February 2027: passport and QR. 18 August 2027: due diligence (audit, not a lab test). Recycled-content quotas for 2031/36 already appear in specs now.

Which chemical requirements does the lab prove?

Article 6 and Annex I restrict mercury, cadmium and lead in portable batteries. That is a substance statement with an analysis or a supplier declaration, not a transport series. UN 38.3 and IEC 62619 prove transport and in-use safety. Carbon footprint and recycled content come from a method and the supply chain.

Contact

Map specs to regulation and standards.

Cevelar structures OEM requirements with traceability to UN 38.3, IEC 62619 and passport fields, EU-hosted. Full guides: Batteriepass-Anforderungen 2027 and battery passport requirements 2027.

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