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The Batteries and Batteries Waste Regulation (EU) 2023/1542 is applicable from 18 February 2024. That said, many requirements under the Regulation will only apply at a later date.
This guide serves as a timeline for EU Batteries Regulation requirements and their respective dates.
Methodology
Step 1: I mapped out all the articles mentioning a date*
Step 2: I determined if the requirement is relevant to either:
- Manufacturers, importers, distributors, and other economic operators, or
- EU Commission or Member States
Step 3: The respective Batteries Regulation requirements tied to a particular date were added to one of the two tables below
*Note that the table contains the dates identified during this stage. I cannot guarantee that I identified every single article or requirement tied to a specific date.
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EU Batteries Regulation Requirements
This section lists requirements for producers (e.g. manufacturers, importers, distributors), and other economic operators for which I found that a specific application date is set in the regulation.
This includes labelling, collection, performance, battery passport, and other requirements. Note that I listed the requirements in chronological order.
| Article | Date/s | Summary |
| Article 59 – Collection of waste portable batteries | 31 December 2023 | Producers of portable batteries or their appointed producer responsibility organisations should achieve a collection target of 45% |
| Article 10 – Performance and durability requirements for rechargeable industrial batteries, LMT batteries and electric vehicle batteries | 18 August 2024 | A document containing values for the electrochemical performance and durability parameters should accompany rechargeable industrial batteries with a capacity greater than 2 kWh, LMT batteries and electric vehicle batteries |
| Article 12 – Safety of stationary battery energy storage systems | 18 August 2024 | The technical documentation should comply with the requirements set in Article 12(2) |
| Article 14 – Information on the state of health and expected lifetime of batteries | 18 August 2024 | The battery management system of stationary battery energy storage systems, LMT batteries and electric vehicle batteries should contain up-to-date data for the parameters for determining the state of health and expected lifetime of batteries |
| Article 17 – Conformity assessment procedures | 18 August 2024 | Conformity assessment procedures requirements should apply from this date, except for Article 17(2), which applies from 12 months after publication of the list of bodies notified mentioned in Article 30(2). |
| CHAPTER VI – Obligations of economic operators other than the obligations in Chapters VII and VIII | 18 August 2024 | The obligations listed in Chapter VI should apply from this date:
Article 38 – Obligations of manufacturers Article 39 – Obligations of suppliers of battery cells and battery modules Article 40 – Obligations of authorised representatives Article 41 – Obligations of importers Article 42 – Obligations of distributors Article 43 – Obligations of fulfilment service providers Article 44 – Case in which obligations of manufacturers apply to importers and distributors Article 45 – Obligations of economic operators placing on the market or putting into service batteries that have been subject to preparation for re-use, preparation for repurposing, repurposing or remanufacturing Article 46 – Identification of economic operators |
| ANNEX I – RESTRICTION ON SUBSTANCES | 18 August 2024 | Portable batteries should not contain more than 0,01% of lead (whether or not incorporated into appliances). Portable zinc-air button cells are excluded until 18 August 2028. |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 18 February 2025 or 12 months after the date of entry into force of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, whichever is the latest | The carbon footprint declaration is necessary for electric vehicle batteries |
| Article 13 – Labelling and marking of batteries | 18 August 2025 | All batteries should be marked with the symbol for separate collection of batteries |
| CHAPTER VIII – Management of waste batteries | 18 August 2025 | Requirements concerning management of waste batteries (e.g. Producer Responsibility Organisation, collection, and more) |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 18 February 2026 or 18 months after the date of entry into force of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, whichever is the latest | The carbon footprint declaration is necessary for rechargeable industrial batteries except those with exclusively external storage |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 18 August 2026 or 18 months after the date of entry into force of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, whichever is the latest | The carbon footprint performance class requirements in the first subparagraph should apply for electric vehicle batteries |
| Article 13 – Labelling and marking of batteries | 18 August 2026 or 18 months after the date of entry into force of the implementing act referred to in paragraph 10, whichever is the latest | Batteries should include a label containing the general information on batteries set out in Part A of Annex VI |
| Article 13 – Labelling and marking of batteries | 18 August 2026 or 18 months after the date of entry into force of the implementing act referred to in paragraph 10, whichever is the latest | Rechargeable portable batteries, LMT batteries and SLI batteries should bear a label containing information on their capacity |
| Article 13 – Labelling and marking of batteries | 18 August 2026 or 18 months after the date of entry into force of the implementing act referred to in paragraph 10, whichever is the latest | Non-rechargeable portable batteries should bear a label containing information on their minimum average duration |
| Article 13 – Labelling and marking of batteries | 18 February 2027 | All batteries should be marked with a QR code as described in Part C of Annex VI. |
| Article 11 – Removability and replaceability of portable batteries and LMT batteries | 18 February 2027 | Requirements concerning removability and replaceability of portable batteries and LMT batteries |
| Article 77 – Battery passport | 18 February 2027 | A battery passport should be provided for each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 18 August 2027 or 18 months after the date of entry into force of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, whichever is the latest | The carbon footprint performance class requirements in the first subparagraph should apply for rechargeable industrial batteries except those with exclusively external storage |
| Article 10 – Performance and durability requirements for rechargeable industrial batteries, LMT batteries and electric vehicle batteries | 18 August 2027 or 18 months after the date of entry into force of the delegated act referred to in the first subparagraph of paragraph 5, whichever is the latest | Rechargeable industrial batteries with a capacity greater than 2 kWh, except those with exclusively external storage, should meet the minimum values laid down in the delegated act adopted pursuant to the first subparagraph of paragraph 5 |
| Article 48 – Battery due diligence policies | 18 August 2027 | Economic operators should comply with the due diligence obligations laid down in paragraphs 2 and 3 of this Article, and in Articles 49, 50 and 52, and implement battery due diligence policies |
| Article 59 – Collection of waste portable batteries | 31 December 2027 | Producers of portable batteries or their appointed producer responsibility organisations should achieve a collection target of 63% |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 18 February 2028 or 18 months after the date of entry into force of the delegated act referred to in the third subparagraph, whichever is the latest | The requirement for a maximum life cycle carbon footprint threshold start to apply for electric vehicle batteries |
| ANNEX I – RESTRICTION ON SUBSTANCES | 18 August 2028 | Portable zinc-air button cells should not contain more than 0,01% of lead (whether or not incorporated into appliances) |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 18 August 2028 or 18 months after the date of entry into force of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, whichever is the latest | The carbon footprint declaration is necessary for
LMT batteries |
| Article 8 – Recycled content in industrial batteries, electric vehicle batteries, LMT batteries and SLI batteries | 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 | Documentation concerning the percentage share of cobalt, lithium, nickel and lead should accompany industrial batteries with a capacity greater than 2 kWh, except those with exclusively external storage, electric vehicle batteries and SLI batteries that contain cobalt, lead, lithium or nickel in active materials |
| Article 9 – Performance and durability requirements for portable batteries of general use | 18 August 2028 or 24 months after the date of entry into force of the delegated act referred to in paragraph 2 | Portable batteries of general use, excluding button cells, should comply with the minimum values for the electrochemical performance and durability parameters |
| Article 10 – Performance and durability requirements for rechargeable industrial batteries, LMT batteries and electric vehicle batteries | 18 August 2028 or 18 months after the date of entry into force of the delegated act referred to in the second subparagraph of paragraph 5, whichever is the latest | LMT batteries should meet the minimum values laid down in the delegated act adopted pursuant to the second subparagraph of paragraph 5 |
| Article 60 – Collection of waste LMT batteries | 31 December 2028 | Producers of LMT batteries or their appointed producer responsibility organisations should achieve a collection target of 51% |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 18 February 2029 or 18 months after the date of entry into force of the delegated act referred to in the third subparagraph, whichever is the latest | The requirement for a maximum life cycle carbon footprint threshold start to apply for electric vehicle batteries for rechargeable industrial batteries except those with exclusively external storage |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 18 August 2030 or 18 months after the date of entry into force of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, whichever is the latest | The carbon footprint declaration is necessary for rechargeable industrial batteries with external storage |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 18 February 2030 or 18 months after the date of entry into force of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, whichever is the latest | The carbon footprint performance class requirements in the first subparagraph should apply for LMT batteries |
| Article 59 – Collection of waste portable batteries | 31 December 2030 | Producers of portable batteries or their appointed producer responsibility organisations should achieve a collection target of 73% |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 18 August 2031 or 18 months after the date of entry into force of the delegated act referred to in the third subparagraph, whichever is the latest | The requirement for a maximum life cycle carbon footprint threshold start to apply for electric vehicle batteries LMT batteries |
| Article 8 – Recycled content in industrial batteries, electric vehicle batteries, LMT batteries and SLI batteries | 18 August 2031 | The technical documentation should demonstrate that industrial batteries with a capacity greater than 2 kWh, except those with exclusively external storage, electric vehicle batteries and SLI batteries contain, in active materials, the minimum percentage share listed in Article 8(2) |
| Article 60 – Collection of waste LMT batteries | 31 December 2031 | Producers of LMT batteries or their appointed producer responsibility organisations should achieve a collection target of 61% |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 18 February 2032 or 18 months after the date of entry into force of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, whichever is the latest | The carbon footprint performance class requirements in the first subparagraph should apply for rechargeable industrial batteries with external storage |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 18 August 2033 or 18 months after the date of entry into force of the delegated act referred to in the third subparagraph, whichever is the latest | The requirement for a maximum life cycle carbon footprint threshold start to apply for electric vehicle batteries for rechargeable industrial batteries with external storage |
| Article 8 – Recycled content in industrial batteries, electric vehicle batteries, LMT batteries and SLI batteries | 18 August 2033 | Documentation concerning the percentage share of cobalt, lithium, nickel and lead should accompany LMT batteries that contain cobalt, lead, lithium or nickel in active materials |
| Article 8 – Recycled content in industrial batteries, electric vehicle batteries, LMT batteries and SLI batteries | 18 August 2036 | The technical documentation should demonstrate that industrial batteries with a capacity greater than 2 kWh, except those with exclusively external storage, electric vehicle batteries, LMT batteries and SLI batteries contain, in active materials, the minimum percentage share listed in Article 8(3) |
Commission / Member State Deadlines
This section lists requirements for the European Commission and EU member states for which I found that a specific deadline is set in the regulation. Also in this case, I listed the requirements that I found in chronological order.
For the European Commission, the deadlines include the adoption of delegated or implementing acts, among other requirements. For EU member states, this includes collection, penalties, and more.
| Article | Date/s | Summary |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 18 February 2024 | The Commission should adopt a delegated act and an implementing act concerning the format for the carbon footprint declaration for electric vehicle batteries |
| Article 94 – Review | 1 January 2025 | The Commission should assess how to introduce harmonised standards for a common charger for different types of batteries |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 18 February 2025 | The Commission should adopt a delegated act and an implementing act concerning the format for the carbon footprint declaration for rechargeable industrial batteries |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 18 February 2025 | The Commission should adopt a delegated act establishing the carbon footprint performance classes and an implementing act establishing the formats for the labelling and the declaration on the carbon footprint performance class for electric vehicle batteries |
| Article 71 – Targets for recycling efficiency and recovery of materials | 18 February 2025 | The Commission should adopt a delegated act establishing the methodology for calculation and verification of rates for recycling efficiency and recovery of materials |
| Article 13 – Labelling and marking of batteries | 18 August 2025 | The Commission should adopt implementing acts to set harmonised specifications for the labelling requirements referred to in paragraphs 1, 2 and 3 |
| CHAPTER VIII – Management of waste batteries | 18 August 2025 | Requirements concerning management of waste batteries for both the Commission and Member States |
| Article 76 – Reporting to the Commission | 18 August 2025 | The Commission should adopt implementing acts laying down the format for the data and information to be reported to the Commission |
| Article 93 – Penalties | 18 August 2025 | Member States should lay down the rules on penalties applicable to infringements and take the measures necessary to ensure that they are implemented |
| Article 54 – Competent authority | 8 November 2025 | Member States should notify the Commission of the names and addresses of the competent authorities |
| ANNEX XII – STORAGE AND TREATMENT, INCLUDING RECYCLING, REQUIREMENTS | 31 December 2025 | Recycling should achieve the targets set in Annex XII Part B(1) |
| Article 69 – Obligations for Member States regarding collection targets for waste portable batteries and waste LMT batteries | 1 January 2026 (and every five years thereafter) | Member States should carry out a compositional survey of collected mixed municipal waste and waste electrical and electronic equipment |
| Article 10 – Performance and durability requirements for rechargeable industrial batteries, LMT batteries and electric vehicle batteries | 18 February 2026 | The Commission should adopt a delegated act establishing minimum values for the electrochemical performance and durability parameters for rechargeable industrial batteries with a capacity greater than 2 kWh, except those with exclusively external storage |
| Article 48 – Battery due diligence policies | 26 July 2026 | The Commission should publish guidelines concerning due diligence requirements |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 18 August 2026 | The Commission should adopt a delegated act establishing the carbon footprint performance classes and an implementing act establishing the formats for the labelling and the declaration on the carbon footprint performance class for rechargeable industrial batteries except those with exclusively external storage |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 18 August 2026 | The Commission should adopt a delegated act to determine the maximum life cycle carbon footprint threshold for electric vehicle batteries, |
| Article 8 – Recycled content in industrial batteries, electric vehicle batteries, LMT batteries and SLI batteries | 18 August 2026 | The Commission should adopt a delegated act
establishing the methodology for the calculation and verification of the percentage share of cobalt, lithium or nickel that is present in active materials |
| Article 77 – Battery passport | 18 August 2026 | The Commission shouldl adopt implementing acts specifying which persons are to be considered persons with a legitimate interest |
| Article 71 – Targets for recycling efficiency and recovery of materials | 18 August 2026 (and at least every five years thereafter) | The Commission should assess if, due to market developments, it is appropriate to revise the targets for recycling efficiency and recovery of materials |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 18 February 2027 | The Commission should adopt a delegated act and an implementing act concerning the format for the carbon footprint declaration for LMT batteries |
| Article 10 – Performance and durability requirements for rechargeable industrial batteries, LMT batteries and electric vehicle batteries | 18 February 2027 | The Commission should adopt a delegated act establishing minimum values for the electrochemical performance and durability parameters for LMT batteries shall attain. |
| Article 9 – Performance and durability requirements for portable batteries of general use | 18 August 2027 | The Commission should adopt a delegated act establishing mandatory minimum values for the electrochemical performance and durability parameters set out in Annex III |
| Article 11 – Removability and replaceability of portable batteries and LMT batteries | 18 February 2027 | Requirements concerning removability and replaceability of portable batteries and LMT batteries (e.g. guidelines, delegated acts) |
| Article 59 – Collection of waste portable batteries | 18 August 2027 | The Commission is empowered to adopt delegated acts to amend the methodology to calculate the collection rate of portable batteries |
| Article 60 – Collection of waste LMT batteries | 18 August 2027 | The Commission is empowered to adopt delegated acts concerning the collection rate of waste LMT batteries |
| Article 89 – Exercise of the delegation | 17 November 2027 (No later than nine months before the end of five years, starting from 17 August 2023) | The Commission should draw up a report in respect of the delegation of power |
| Article 6 – Restrictions on substances | 31 December 2027 | The Commission should prepare a report on substances of concern present in batteries or used in their manufacture. |
| ANNEX XII – STORAGE AND TREATMENT, INCLUDING RECYCLING, REQUIREMENTS | 31 December 2027 | Recovery of materials should achieve the targets set in Annex XII Part C(1) |
| Article 63 – Deposit return systems for batteries | 31 December 2027 | The Commission should assess the feasibility of establishing deposit return systems for batteries |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 18 February 2028 | The Commission should adopt a delegated act to determine the maximum life cycle carbon footprint threshold for rechargeable industrial batteries, except those with external storage |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 18 August 2028 | The Commission should adopt a delegated act establishing the carbon footprint performance classes and an implementing act establishing the formats for the labelling and the declaration on the carbon footprint performance class for LMT batteries |
| Article 8 – Recycled content in industrial batteries, electric vehicle batteries, LMT batteries and SLI batteries | After the date of entry into force of the delegated act adopted under paragraph 1 for Article 8, and no later than 31 December 2028 | The Commission should assess whether it is appropriate to revise the targets laid down in paragraphs 2 and 3 of Article 8 |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 18 February 2029 | The Commission should adopt a delegated act and an implementing act concerning the format for the carbon footprint declaration for industrial batteries with external storage |
| Article 8 – Recycled content in industrial batteries, electric vehicle batteries, LMT batteries and SLI batteries | 18 August 2029 | The Commission should adopt a delegated act to amend the targets laid down in paragraphs 2 and 3, if justified |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 18 February 2030 | The Commission should adopt a delegated act to determine the maximum life cycle carbon footprint threshold for LMT batteries |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 18 August 2030 | The Commission should adopt a delegated act establishing the carbon footprint performance classes and an implementing act establishing the formats for the labelling and the declaration on the carbon footprint performance class for rechargeable industrial batteries with external storage |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 31 December 2030 | The Commission should assess if it is feasible to extend the requirements of Article 7 to portable batteries, and the requirement laid down in paragraph 3 to rechargeable industrial batteries with a capacity of 2 kWh or less. |
| Article 9 – Performance and durability requirements for portable batteries of general use | 31 December 2030 | The Commission should assess the feasibility of measures to phase out non-rechargeable portable batteries of general use |
| ANNEX XII – STORAGE AND TREATMENT, INCLUDING RECYCLING, REQUIREMENTS | 31 December 2030 | Recycling should achieve the targets set in Annex XII Part B(2) |
| Article 94 – Review | 30 June 2031 | The Commission should draw up a report on the application the Regulation and its impact |
| Article 94 – Review | 12 months after the date of entry into force of any of the legislative acts referred to in the first subparagraph, or by 30 June 2031, whichever is the earliest | The Commission should assess whether any amendment to Chapter VII is necessary and publish a report |
| Article 94 – Review | 30 June 2031 | The Commission should create a report that assesses the feasibility of extending the scope of the definition of ‘LMT battery’ to include batteries powering non-wheeled vehicles |
| ANNEX XII – STORAGE AND TREATMENT, INCLUDING RECYCLING, REQUIREMENTS | 31 December 2031 | Recovery of materials should achieve the targets set in Annex XII Part C(2) |
| Article 7 – Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries | 18 February 2032 | The Commission should adopt a delegated act to determine the maximum life cycle carbon footprint threshold for industrial batteries with external storage |
| ANNEX II – CARBON FOOTPRINT | 2050 | The Commission should set maximum life cycle carbon footprint thresholds for the battery categories listed in Article 7(1).
It should take into account several factors, including the Union’s objectives on sustainable mobility and climate neutrality by 2050. |
FAQ
When does the EU Batteries Regulation apply?
According to Article 96, the Batteries Regulation applies from 18 February 2024. However, the article also mentions the following exceptions:
a. Article 11 will apply from 18 February 2027.
b. Article 17 and Chapter VI apply from 18 August 2024, except for Article 17(2), which will apply from 12 months after publication of the list of bodies notified mentioned in Article 30(2).
c. Chapter VIII applies from 18 August 2025.
When is the EU Batteries Directive repealed?
The Batteries Directive is repealed from 18 August 2025. However, according to Article 95, the following provisions will keep applying until a later date:
a. Article 11 will apply until 18 February 2027.
b. Article 12(4) and (5) applied till 31 December 2025, except for the provision concerning transmission of data to the Commission, which will apply until 30 June 2027.
c. Article 21(2) will apply until 18 August 2026.
What regulations and directives are amended by the EU Batteries Regulation?
The Batteries Regulation amends the following regulations and directives:
a. Market Surveillance Regulation (EU) 2019/1020
b. Waste Framework Directive 2008/98/EC
