The EU Battery Regulation, Regulation (EU) 2023/1542, replaced the old Batteries Directive and has applied since 18 February 2024, with most duties phased in over the following years. It covers every battery placed on the EU market, whether sold loose or built into a product, in five categories: portable, light means of transport (LMT), starting, lighting and ignition (SLI), industrial and electric vehicle batteries. For sellers the dates that matter are 18 August 2024 (conformity assessment, CE marking and the duties of manufacturers, importers and distributors), 18 August 2025 (the crossed-out bin symbol and the waste and producer responsibility rules), 18 February 2027 (a QR code on every battery, the battery passport and user-replaceable portable batteries) and 18 August 2027 (supply chain due diligence for large companies).
Online shops and marketplace sellers are in scope too. If you sell a battery, or a product with one inside, you are at least a distributor with checks to run before you list it. If you sell directly to consumers in another EU country, you count as the producer there, with a registration and take-back duty in that country, and marketplaces must collect your producer registration number before they let you sell. Every date below was checked against the consolidated text on EUR-Lex on 26 October 2026. This article explains the rules; it is not legal advice.
The five battery categories and how to classify yours
The category decides which rules apply, so classify every battery product first. The definitions are in Article 3 and turn mainly on weight, sealing and what the battery powers.
Battery categories under Regulation (EU) 2023/1542
| Portable | Sealed, 5 kg or less, not designed for industrial use, not LMT, EV or SLI | AA cells, button cells, phone and laptop batteries, power banks | No (QR code only) |
|---|---|---|---|
| LMT | Sealed, 25 kg or less, powers the traction of light electric vehicles | E-bike and e-scooter batteries | Yes |
| SLI | Supplies power for starting, lighting or ignition in vehicles or machinery | Car starter batteries | No (QR code with recovered metal content) |
| Industrial | Designed for industrial use, or above 5 kg and not LMT, EV or SLI | Home energy storage, forklift batteries | Yes, above 2 kWh |
| Electric vehicle | Powers traction in hybrid or electric cars, vans and trucks, or L-category vehicles above 25 kg | Car traction batteries | Yes |
Two edge cases trip up catalog teams. Cells or modules sold for end use without further assembly count as batteries, and when they could fit two categories the stricter one applies (Article 1(4)). And a heavy battery that is not for traction or starting, such as a 6 kg portable power station pack, is an industrial battery by definition, even when a consumer buys it.
Battery Regulation deadlines from 2024 to 2027
EU Battery Regulation dates for sellers (checked 26 October 2026)
18 Feb 2024
The regulation applies
The rules on hazardous substances such as mercury and cadmium apply. The old Batteries Directive 2006/66/EC stays in force alongside it until its repeal on 18 August 2025.
18 Aug 2024
Conformity assessment and operator duties
Batteries need a conformity assessment, EU declaration of conformity and CE marking. Manufacturers, importers, distributors and fulfillment service providers carry their Chapter VI duties.
18 Aug 2025
Separate collection symbol and waste rules
All batteries carry the crossed-out wheeled bin. Producer registration, extended producer responsibility and take-back (Chapter VIII) apply, and the Batteries Directive is repealed, apart from a few transitional provisions (Article 95).
- 4
18 Aug 2026 or later
Label with capacity and chemistry
Applies from 18 August 2026 or 18 months after the Commission's implementing act on label specifications enters into force, whichever is later. No such act had been adopted when we checked EUR-Lex on 26 October 2026, so the label duty cannot start before 2028.
- 5
18 Feb 2027
QR code, battery passport, replaceable batteries
Every battery gets a QR code. LMT, EV and industrial batteries above 2 kWh need a battery passport. Portable batteries in products must be removable and replaceable by the end user.
- 6
18 Aug 2027
Battery due diligence
Postponed from 18 August 2025 by Regulation (EU) 2025/1561. Applies to operators with a net turnover of EUR 40 million or more.
The labelling date is the one most summaries get wrong. Article 13 does not say "from 18 August 2026" on its own: the label with the general information from Annex VI, the capacity label and the "non-rechargeable" label apply from that date or 18 months after the implementing act on harmonised label specifications enters into force, whichever is later. The Commission published a draft for feedback in December 2025, but we found no adopted act on EUR-Lex on 26 October 2026. Any act that enters into force after that date pushes the label duty to at least 18 months later, so it cannot apply before 2028. The separate collection symbol is different: it has been mandatory on all batteries since 18 August 2025.
Two changes are worth tracking. Regulation (EU) 2025/1561 moved the due diligence start to 18 August 2027. A further Commission proposal, COM(2025) 981 of 10 December 2025, would among other things exclude LMT battery packs from the removability rule and amend the producer definition for distance sales; when we checked on 26 October 2026, the Council had agreed its negotiating mandate and Parliament's environment committee had not yet voted, according to the European Parliament's legislative train. Until an amendment is adopted and published, the current text applies. The compliance calendar lists the battery dates next to other EU product rules.
What the regulation asks of online shops and marketplace sellers
Checks a distributor runs before listing a battery
Anyone in the supply chain other than the manufacturer or importer who makes a battery available is a distributor. Under Article 42(2), before you sell it you must verify that:
- the producer is registered in the register of producers of that Member State (Article 55);
- the battery bears the CE marking and is marked and labelled according to Article 13;
- it comes with the required documents, instructions and safety information in a language end users in that country understand;
- the manufacturer and importer have put their identification and contact details on the battery, its packaging or its documents.
In practice you request this per product from your supplier when you source the product and keep it, because a national authority can ask you for the documentation that shows conformity (Article 42(6)). The general rules on CE marking are in our CE marking guide.
When selling across a border makes you the producer
The definition of producer in Article 3(47) includes anyone who sells batteries, including batteries built into appliances or vehicles, by distance contract directly to end users in a Member State while being established in another Member State or outside the EU. A Dutch webshop that ships e-bike batteries or cordless tools to consumers in Germany is therefore the producer in Germany. It has to register in each Member State where it first makes batteries available (Article 55), carry extended producer responsibility there (Article 56), usually through a producer responsibility organisation, and appoint an authorised representative for extended producer responsibility in each of those countries (Article 56(3)). The Commission proposed in December 2025 to suspend that last duty (COM(2025) 982), but the proposal had not been adopted when we checked on 26 October 2026.
Take-back duties for shops that deliver
Distributors must take back waste batteries free of charge, without requiring a purchase, limited to the battery categories they sell (Article 62). For distance sellers this applies too: you need enough collection points across the Member State, and with home delivery you must offer free take-back at the point of delivery or at a local collection point, and tell the buyer about the arrangement when they order. Under Article 74, the information on collection, safe handling and the meaning of the labels also has to be shown when you sell through online platforms, and the producer responsibility costs must be shown separately to the end user at the point of sale of a new battery.
Products with a built-in battery
From 18 February 2027, anyone placing on the market a product with a portable battery must make sure the end user can remove and replace it with commercially available tools, unless an exemption applies, such as appliances designed to work in water or certain medical devices (Article 11). Instructions and safety information on removal must be permanently available online, and the battery must stay available as a spare part for five years after the last unit of the model is sold. For LMT batteries, removal and replacement by an independent professional is enough. Delegated Regulation (EU) 2026/1770, published on 22 October 2026 and in force from 11 November 2026, widens the list of products that may keep a battery only an independent professional replaces, where user safety requires it: certain wearables, rechargeable electric toys until 31 July 2030, food thermometer probes, equipment for explosive atmospheres, on-body drug delivery systems and roof-mounted telematics devices for farm and construction machinery.
What marketplaces must collect from battery producers
Article 62(6) ties the Battery Regulation to the Digital Services Act. Online marketplaces that let consumers buy from producers must, as part of their trader checks under DSA Article 30, obtain from every producer offering batteries to EU consumers:
- the details of the register of producers and the producer's registration number or numbers in it;
- a self-certification that the producer only offers batteries for which its extended producer responsibility obligations are met.
So a seller who lists cordless drills on several marketplaces needs a registration number for each country those marketplaces sell into, stored where every listing can pick it up. Member States must give marketplaces free access to the register if it is not public (Article 55(13)), which means a marketplace can check the number you enter. The marketplace strategy guide covers the other data each new channel asks for.
Battery fields to store for every SKU
Most of these obligations come down to data you need per product, either to show buyers, to pass the distributor checks or to fill a marketplace's compliance fields. The table maps each field to the article that asks for it. Values are illustrative, for a cordless drill sold with a 2 Ah lithium-ion pack.
Battery data fields per product
| Battery category | Portable | Decides which rules apply (Art. 3); also asked at producer registration (Art. 55(3)) |
|---|---|---|
| Included or built in | Included, removable | Products with built-in portable batteries fall under the removability rule (Art. 11) |
| Chemistry | Lithium-ion | Label content (Annex VI Part A) and producer registration |
| Rechargeable | Yes | Non-rechargeable portable batteries carry a different label (Art. 13(3)) |
| Capacity | 2 Ah, 36 Wh | Capacity label for rechargeable portable, LMT and SLI batteries (Art. 13(2)) |
| Weight | 0.35 kg | Label content and the category thresholds of 5 kg and 25 kg |
| Model and batch or serial number | BP-18-20, batch 2026-41 | Identification on the battery or packaging (Art. 38(6)) |
| Manufacturer name and address | Name, postal address, web and email | Required on the battery or its documents (Art. 38(7)); checked by distributors |
| CE marking and declaration of conformity | Yes, DoC reference DOC-BP18-2024 | Distributor check (Art. 42(2)(b)) and proof on request |
| Cd or Pb marking | None | Batteries above 0.002% cadmium or 0.004% lead show the symbol (Art. 13(5)) |
| Producer registration number per country | One number per Member State sold into | Marketplace trader checks (Art. 62(6)) and distributor checks |
| Removal instructions URL | Link to the instructions page | Must be permanently available online (Art. 11(1)) |
| QR code target or passport identifier | URL or unique identifier | From 18 February 2027 (Art. 13(6), Art. 77) |
Store these as structured attributes, not as a sentence in the description. A select field for chemistry and category, a number with a unit for capacity and weight, and one field per country for registration numbers let you filter the catalog ("every lithium-ion product sold in France without a French registration number"), map the values to each marketplace's compliance fields and print them on product pages.
Four battery data errors to catch before a marketplace or authority does
- Classifying by product, not by battery. A portable power station feels like consumer electronics, but a pack above 5 kg that is not for traction or starting is an industrial battery, and above 2 kWh it needs a passport from February 2027. Classify the battery itself, with its weight and capacity, not the product it sits in.
- "Battery included" as free text. A sentence in the description cannot be filtered, mapped or checked. If chemistry, capacity and category only exist in prose, you cannot answer a simple question such as which products need a French registration number.
- One registration number for every country. Producer registration is per Member State. A seller shipping to consumers in Germany, France and Belgium needs a number in each, and each marketplace storefront asks for the one that matches its country.
- Hard-coding 18 August 2026 as the label date. Copy, compliance checklists and supplier requests that treat it as fixed will be wrong if the implementing act moves the date. Store the requirement, and keep the date in one place you can update.
All four come from treating battery information as a description detail rather than as product data with its own fields, owners and checks.
Battery passport: scope, access levels and data
From 18 February 2027, each LMT battery, each industrial battery above 2 kWh and each electric vehicle battery placed on the market needs a battery passport, an electronic record reached through the QR code on the battery (Article 77). The economic operator placing the battery on the market keeps it accurate, complete and up to date. Retailers who resell such batteries do not create the passport, but they should store the identifier or QR target per product so it can be shown and checked.
The passport has three access levels. Some information is public, such as general battery data, composition, carbon footprint, due diligence report and recycled content (Annex XIII point 1). Detailed composition, dismantling and safety information is limited to persons with a legitimate interest and to authorities. Data about the individual battery, such as its state of health, is open to persons with a legitimate interest. The digital product passport guide explains how the battery passport relates to the wider passport plans under the Ecodesign for Sustainable Products Regulation.
WISEPIM has no battery-specific module: it does not issue or host battery passports, generate QR codes or look up producer registers. What it does is hold the data a compliance team needs per product. You create the battery fields as product attributes and mark them as required in the battery product families, AI enrichment can fill attributes from supplier data, and Quality Guard rules block the export of a battery product to a channel while its chemistry, capacity or registration number is missing.
