EU Battery Regulation: the dates that matter for storage and EV batteries

Labels in 2026, the battery passport in February 2027, due diligence in August 2027, recycled content after that. A dated checklist of Regulation (EU) 2023/1542 for industrial and EV battery makers.

Policy Updated 2 min read

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  • 01Regulation (EU) 2023/1542 has applied since 18 February 2024; obligations phase in over more than a decade.
  • 02From 18 February 2027, industrial batteries above 2 kWh, EV and LMT batteries need a digital battery passport.
  • 03Due diligence obligations were postponed to 18 August 2027 by Regulation (EU) 2025/1561.
  • 04The carbon footprint declaration starts only once the Commission’s acts are in force; the EV act had not been adopted by late September 2026.
  • 05Stationary storage systems have needed safety documentation since 18 August 2024.

One regulation, many deadlines

The EU Battery Regulation replaced the old Batteries Directive and has applied since 18 February 2024. Its obligations come into force in stages. These are the ones that matter most for rechargeable industrial batteries above 2 kWh, including stationary storage, and for EV batteries.

DateObligationArticle
18 Aug 2024Performance and durability documentation (industrial > 2 kWh, LMT, EV)10
18 Aug 2024Safety documentation for stationary battery energy storage systems12
18 Aug 2025Separate collection symbol on batteries13
18 Aug 2026General label and capacity information*13
18 Feb 2027QR code; battery passport for industrial > 2 kWh, LMT and EV batteries13, 77
18 Aug 2027Supply-chain due diligence48
18 Aug 2027Minimum performance and durability values for industrial batteries*10
18 Aug 2028Recycled content documentation*8
18 Aug 2031Minimum recycled content: 16% cobalt, 85% lead, 6% lithium, 6% nickel8
18 Aug 2036Higher minimums: 26% cobalt, 85% lead, 12% lithium, 15% nickel8

* Or later, if the Commission’s implementing or delegated act arrives late: the Regulation ties these dates to “whichever is later”.

The battery passport

From 18 February 2027, each LMT battery, each industrial battery with a capacity above 2 kWh and each EV battery placed on the EU market needs a battery passport: an electronic record reached through the QR code on the battery. It carries data on composition, performance, durability and, once those rules apply, carbon footprint and recycled content. For stationary storage, LMT and EV batteries, state-of-health data from the battery management system also has to be made accessible.

Due diligence: two more years

Regulation (EU) 2025/1561 moved the start of battery due diligence from 18 August 2025 to 18 August 2027, and the Commission’s guidelines from February 2025 to 26 July 2026. The obligation itself is unchanged: companies placing batteries on the market must manage social and environmental risks in their supply chains for raw materials such as cobalt, lithium and nickel.

Carbon footprint: not started yet

On paper, the carbon footprint declaration applied to EV batteries from 18 February 2025 and to industrial batteries above 2 kWh from 18 February 2026. In practice, it starts only once the Commission’s calculation rules are in force. As of 26 September 2026, the delegated act for EV batteries had not been adopted, according to compliance trackers.

Sources disagree on industrial batteries: at least one says the industrial declaration is already mandatory, while most say it is deferred in the same way. Check EUR-Lex for the current status before planning around either reading.

What storage and EV battery makers should do

  • Treat the passport as a data project. Composition, performance and BMS data must be collected per battery and kept accessible for years.
  • Keep the BESS safety file current. Article 12 documentation for stationary systems has been required since August 2024.
  • Prepare carbon footprint data now. When the rules land, the clock starts quickly.
  • Plan due diligence for 2027. The delay gives time, not an exemption.

Our partner laboratory network supports energy storage manufacturers with converter and system testing up to 2.5 MW, including safety, grid connection and EMC.

FAQ

When is the battery passport mandatory?

From 18 February 2027, for industrial batteries above 2 kWh, EV batteries and LMT batteries placed on the EU market.

Was due diligence postponed?

Yes. Regulation (EU) 2025/1561 moved the start from 18 August 2025 to 18 August 2027.

Do I need a carbon footprint declaration now?

Only once the Commission’s calculation rules are in force. For EV batteries, the delegated act had not been adopted as of 26 September 2026; check EUR-Lex for updates.

Sources

  1. Regulation (EU) 2023/1542 concerning batteries and waste batteries — EUR-Lex
  2. Regulation (EU) 2025/1561 (due diligence postponed to 18 August 2027) — EUR-Lex
  3. Traceable Digital: carbon footprint declaration status (26 September 2026)

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