The EU Battery Regulation is already in force. Since 18 February 2024 it applies with general effect, and since then, manufacturers and importers placing products with built-in or supplied batteries on the European market have specific obligations to review. The question is no longer whether Regulation (EU) 2023/1542 exists, but which of its requirements affect the specific product: technical documentation, labelling, QR code, removability, supplier evidence, extended producer responsibility (EPR) and, in some cases, digital battery passport or due diligence obligations. The exact requirements depend on the battery category, product design and the role of the economic operator.
Quick answer: does the EU Battery Regulation apply to products with batteries?
Yes, if the product incorporates a battery or is placed on the EU market together with one.
Regulation (EU) 2023/1542 covers batteries as a whole, including those that form part of a finished product. Whether the product is a portable speaker, a rechargeable toy, a cordless tool, a personal care device or any consumer electronic with a built-in battery does not exclude it from the scope of the Regulation.
What varies is which requirements apply and when. Not all obligations are universal or share the same date of entry into force. Some blocks are already applicable: those relating to conformity assessment and economic operator obligations from August 2024, and those relating to waste battery management and extended producer responsibility from August 2025. Others enter into force between August 2026 and February 2027, and their scope depends on factors such as battery category, capacity, product design or the operator's volume of activity. For a company that manufactures or imports products with batteries, the starting point is always the same: identify what type of battery the product contains and what role the company plays in the supply chain.
What is EU Battery Regulation 2023/1542?
Regulation (EU) 2023/1542 is the legal framework governing batteries and waste batteries in the European Union. It was published in the Official Journal of the EU on 28 July 2023 and entered into force on 17 August 2023.
Its scope is broad: it covers sustainability, safety, labelling, information requirements, conformity assessment, waste management, extended producer responsibility and due diligence in the raw material supply chain.
Unlike the previous Directive 2006/66/EC, which required national transposition, this text is a regulation. That means it is directly applicable in all Member States without the need for additional national implementing rules for its main provisions.
For companies placing products with batteries on the market, the relevance of the Regulation is not limited to product design. It also affects technical documentation, product and packaging labelling, the information that must accompany the product, the evidence that must be requested from battery suppliers, and registration and waste management obligations in each destination Member State.
Battery Directive vs EU Battery Regulation: what has changed?
Many companies are still looking for information about the "EU Battery Directive" or the "new Battery Directive". This is understandable: for years, Directive 2006/66/EC was the reference framework for placing batteries on the market in Europe.
However, that Directive has been repealed. It ceased to apply on 18 August 2025, replaced by Regulation (EU) 2023/1542, with transitional provisions for some products already on the market.
The change of legal instrument has practical consequences:
From directive to regulation. The directive required each Member State to transpose it into national legislation. The result was a patchwork of national rules with different nuances. The new regulation is directly applicable throughout the EU in a uniform manner.
Broader scope. The Regulation introduces requirements that the Directive did not have: digital battery passport, due diligence in the supply chain, durability and performance requirements by category, new labelling rules with QR code, and more demanding sustainability and recycled content criteria for certain categories.
Phased timelines. Not everything entered into force at once. The Regulation applies in phases depending on the nature of the requirement and the battery category affected.
If the company is working with documentation or advice based on the old Battery Directive, now is the time to update those references. Some obligations are already enforceable; others enter into force in the coming months.
Why products with built-in or supplied batteries are also affected
The Regulation does not distinguish between batteries sold as standalone products and batteries that form part of an item. If the product contains a battery, that battery is also subject to the Regulation, and the associated obligations transfer to those who place the finished product on the market.
This covers a wide variety of categories: rechargeable consumer electronics, battery-powered toys, cordless tools, personal care devices, small household appliances, LED products with rechargeable batteries, connected devices, electric scooters and other light means of transport.
The starting point for any product company is battery classification. The Regulation distinguishes several categories:
- Portable batteries: general-use, sealed batteries that the end user can carry by hand. This is the most common category in consumer electronics, toys, tools and personal devices.
- LMT batteries (Light Means of Transport): used in electric bicycles, scooters and similar light vehicles.
- Starting, lighting and ignition batteries (SLI): for traditional motor vehicles.
- Industrial batteries: industrial applications, storage systems and professional equipment.
- Electric vehicle batteries (EV): cars and heavy electric vehicles.
Each category has a specific set of requirements and different application dates. It is not possible to determine what applies to a product without first identifying the category of battery it incorporates.
Which companies have obligations under the EU Battery Regulation?
The Regulation distinguishes between different types of economic operators: manufacturers, importers, distributors and others. Obligations are not the same for all of them.
Manufacturer means the person who designs and manufactures the battery or product with battery, or who commissions its manufacture and places it on the market under their own brand. The manufacturer has the broadest obligations: design, technical documentation, conformity assessment, declaration of conformity and CE marking where applicable.
Importer means the natural or legal person established in the EU who introduces onto the European market batteries or products with batteries from third countries. The importer has the obligation to verify that the manufacturer has fulfilled their obligations before placing the product on the market: technical documentation, compliant labelling, instructions and information in the language of the destination Member State, and that the manufacturer can be contacted.
Distributor means a person who makes the product available on the market without being a manufacturer or importer. They have more limited verification obligations, but are not exempt.
One relevant point: if an importer or distributor modifies the product, or places it on the market under their own name or brand, they may take on obligations equivalent to those of the manufacturer.
For companies outside the EU selling directly on European marketplaces without a designated importer, the situation may require the appointment of an Authorised Representative in the EU under the Regulation, whose role is distinct from the Responsible Person under product safety legislation.
EU Battery Regulation requirements already applicable (as of publication)
As of the date of this article, several blocks of the Regulation are already enforceable:
| Date | Requirement | Why it matters for your product |
|---|---|---|
| 18 Feb. 2024 | General application of the Regulation | The Regulation is in force. It is the current legal framework. |
| 18 Aug. 2024 | Conformity assessment and economic operator obligations (Arts. 17 and Chapter VI, with exceptions) | Affects product technical documentation, declaration of conformity and importer checks. |
| 18 Aug. 2025 | Waste battery management and EPR obligations (Chapter VIII) | Registration, collection and end-of-life financing obligations in the Member States of commercialisation. |
| 18 Aug. 2025 | Separate collection symbol on all batteries | The symbol must be present on the battery, packaging or product documentation, depending on the case. |
| 18 Aug. 2025 | Repeal of Directive 2006/66/EC | The old Battery Directive no longer applies. Review any documentation that cites it. |
These requirements are not future or optional. If the product is already on the EU market and the company has not reviewed its technical documentation, importer checks or separate collection symbol compliance, action is needed now.
Phased-in requirements: labelling, QR code, removability and battery passport
In addition to the requirements already applicable, the Regulation establishes a series of obligations with staggered entry into force. Some of the most relevant for consumer products are the following.
Key milestones table (from publication date onwards)
| Date | Requirement | Categories affected |
|---|---|---|
| 18 Aug. 2026 or later* | General battery labelling information requirements | Depending on applicable implementing act |
| 18 Feb. 2027 | Portable batteries in products: removable and replaceable by end user | Portable batteries incorporated into products |
| 18 Feb. 2027 | LMT batteries: removable and replaceable by independent professional | Light means of transport batteries |
| 18 Feb. 2027 | QR code marking on all batteries | All categories |
| 18 Feb. 2027 | Digital battery passport | LMT, industrial >2 kWh and EV only |
| 18 Aug. 2027 | Supply chain due diligence obligations (after postponement under Reg. 2025/1561) | Subject to scope and applicable thresholds |
| 2028 onwards | Performance, durability and recycled content requirements for specific categories | LMT, industrial, EV, SLI depending on delegated acts |
*The exact application date of general labelling requirements depends on the publication of the relevant implementing act: 18 months after its entry into force or 18 August 2026, whichever is later.
The removable and replaceable battery requirement from 2027
This is one of the changes with the most direct impact on the design and documentation of consumer products.
From 18 February 2027, as a general rule, portable batteries incorporated into products must be readily removable and replaceable by the end user. For LMT batteries, the standard is different: they must be removable and replaceable by an independent professional.
What this means in practice:
Product design. The product must allow access to the battery without special tools or with widely available tools. The casing, screws, clips and internal structure of the product must be designed with this in mind.
Instructions and safety information. The product must be accompanied by clear instructions and safety information on the use, removal and replacement of the battery. This information must be permanently available online in an understandable format.
Spare parts availability. There are implications for spare parts management: it must be possible to obtain the replacement battery for a reasonable period.
After-sales process and supplier alignment. The company must align suppliers on design, documentation and the replacement process before the product is launched on the market.
Exceptions and derogations are provided for in the Regulation. Their application depends on the specific characteristics of the product, so a case-by-case assessment is necessary. It cannot be assumed that the current design of a product is automatically exempt.
If the product is currently in development or its design is about to be finalised, reviewing compliance with this requirement now is more efficient and less costly than doing so after production is locked.
Are you preparing a battery-powered product for the EU market?
Reviewing battery category, removability, labelling and supplier documentation before locking the design can prevent costly problems at customs, on marketplaces or post-launch. Conformity Point can help you identify which EU Battery Regulation requirements apply to your specific product.
QR code and battery passport: what is the difference?
These are two distinct requirements that are often confused.
QR code (all battery types, from 18 February 2027). From that date, all batteries placed on the EU market must be marked with a QR code. The information accessible through that QR code depends on the battery type. For consumer portable batteries, the QR code gives access to information such as battery category, chemistry, manufacturer, state of health and other relevant parameters as defined in the relevant implementing act.
Digital battery passport (LMT, industrial >2 kWh and EV only). The digital battery passport is an additional and far more demanding requirement. It only applies to specific categories: light means of transport (LMT) batteries, industrial batteries with a capacity above 2 kWh, and electric vehicle batteries. It does not apply to the small portable batteries found in the vast majority of consumer electronics products.
If the product contains a standard consumer portable battery (such as those in smartphones, headphones, portable vacuum cleaners, toys or small cordless tools), the digital battery passport is not a requirement that applies directly to the product.
What does apply, from February 2027, is the QR code requirement and the availability of the associated information. To prepare for this, the company must coordinate with the battery supplier to understand what information will be available, in what format and through what mechanism.
Labelling and information requirements for products with batteries
Battery labelling under the new Regulation covers several dimensions that go beyond the physical label on the battery.
Separate collection symbol. Since 18 August 2025, all batteries must carry the crossed-out wheelie bin symbol. This symbol may appear on the battery itself, on the packaging or in the product documentation, depending on the size and nature of the battery. Verifying that the product includes it correctly is already a current obligation.
Information on capacity, chemistry and other parameters. The Regulation sets out information requirements that must appear on the battery or be accessible via the QR code. The exact details for each category depend on the relevant implementing acts, whose application timeline is staggered.
Information in product instructions. The product must include information on correct use, safety precautions and the process for removing and replacing the battery. This information must be permanently available online.
Language and legibility. Information must be in the language or languages of the Member State where the product is marketed. For products sold in multiple EU countries, this requires adapting labelling and documentation.
A practical note: not all implementing acts developing the labelling requirements had been published at the time of writing this article. Before launching a product, it is necessary to verify the publication status of the relevant delegated and implementing acts for the specific battery category.
What documents should manufacturers and importers request from battery suppliers?
Supplier documentation is a frequent weak point in battery regulation compliance. Receiving a product datasheet is not sufficient.
List of documents to request from the battery supplier:
- Battery category identification under Regulation (EU) 2023/1542
- Battery model, reference and technical specification
- Battery manufacturer identification (name, address, contact details)
- Battery declaration of conformity, where applicable
- Technical documentation or conformity evidence
- CE marking evidence for the battery, where applicable
- Labelling information: separate collection symbol, capacity, chemistry and other required parameters
- QR code status and implementation plan for February 2027
- Relevance of the digital battery passport for the specific category
- Instructions for safe use, removal and replacement
- Information on availability of replacement batteries
- Design information for compliance with the removability requirement (applicable from 2027)
- Evidence of compliance with EPR obligations or producer registration where applicable
This documentation is necessary both for the technical file of the finished product and to enable the importer to fulfil their verification obligations before placing the product on the EU market.
Step by step: how to verify compliance of your battery-powered product
- 1Identify whether the product contains, incorporates or is supplied with a battery. This may seem obvious, but there are cases where the battery is optional, interchangeable or sold separately. Each configuration may have different implications.
- 2Classify the battery category. Is it a portable, LMT, SLI, industrial or EV battery? This classification determines which requirements apply and on what dates.
- 3Define the role of the economic operator. Is the company a manufacturer, importer or distributor? Does it sell under its own brand? Does it modify the product? The answers determine the level of obligations.
- 4Review the requirements already applicable. Assess compliance with the blocks currently in force: conformity assessment, technical documentation, importer obligations, separate collection symbol and EPR registration in the target markets.
- 5Map the phased-in requirements by application date. Identify which upcoming requirements (labelling, QR code, removability, digital battery passport) affect the product and when they enter into force.
- 6Review the product design for the removability requirement. Check whether the current design allows for battery removal and replacement in accordance with the Regulation. If not, plan the necessary modifications before finalising the production design.
- 7Review labelling, QR code and product information. Check that current labelling and product information comply with applicable requirements and plan the updates needed for those entering into force in 2027.
- 8Confirm whether the digital battery passport applies. Determine whether the battery category in the product falls within the scope of the digital battery passport.
- 9Review EPR and waste battery obligations in each destination Member State. Registration and end-of-life financing obligations vary by country. Some Member States already require formal registration.
- 10Update the technical file and supplier evidence record. Consolidate all documentation: declaration of conformity, technical specifications, supplier evidence, labelling, instructions and EPR records. The technical file must be available to market surveillance authorities.
Common mistakes when applying the EU Battery Regulation
1.Treating battery compliance as an issue that belongs solely to the supplier. The company placing the finished product on the market also has obligations. It is not sufficient for the supplier to certify the battery separately.
2.Basing compliance only on the battery datasheet. A datasheet is not a declaration of conformity and does not replace the documentation required by the Regulation.
3.Confusing the QR code with the digital battery passport. They are distinct requirements with different scope. The QR code applies to all batteries from 2027; the digital battery passport applies only to specific categories.
4.Ignoring the removability requirement until the production design is locked. Modifying a product's design after production is blocked costs far more than reviewing it during the development phase.
5.Using the old Battery Directive as the compliance baseline. Directive 2006/66/EC has been repealed since August 2025. Any documentation citing it as the current framework must be updated.
6.Forgetting importer verification obligations. The EU importer has the obligation to verify that the manufacturer has fulfilled their obligations before placing the product on the market. This verification must be documented.
7.Not reviewing EPR obligations by Member State. Extended producer responsibility and waste battery registration obligations vary by country. Complying in one market alone is not sufficient if the product is distributed across several.
8.Making generic compliance statements without identifying the battery category. Declarations of conformity must be linked to the specific category, model and specification of the battery.
FAQ: EU Battery Regulation and products with batteries
What you need to know before selling in Europe
The EU Battery Regulation is not just a rule about batteries as a component. It affects finished products, those who manufacture them, those who import them and those who distribute them in the EU.
The conformity assessment, technical documentation, importer obligations, separate collection symbol and extended producer responsibility blocks are already enforceable. Full labelling, QR code, removability requirements and, for certain categories, the digital battery passport, enter into force progressively from 2027.
What determines what applies to your product is not the Regulation in the abstract, but the specific battery category it incorporates, your company's role in the supply chain and the EU markets where the product is commercialised.
Knowing the Regulation is the first step. The second is carrying out the specific product assessment.
Selling products with batteries in the EU?
The EU Battery Regulation is already enforceable on key aspects, and the labelling, QR code and removability requirements arrive in 2027.
At Conformity Point we can help you:
- Identify which Regulation requirements apply to your specific product
- Review the technical documentation and your battery supplier's evidence
- Verify compliance with EU importer obligations
- Assess whether the product design meets the removability requirement
- Check EPR obligations by target market
- Prepare or update the conformity technical file
If you need a broader EU market access service, see our CE marking consulting and EU Authorised Representative services.
Official sources
About the author
Written by Juan Manuel Beltrán, Founder & Product Compliance Consultant at Conformity Point. Specialist in consumer product compliance for the European market, he helps manufacturers, importers and brands sell consumer products in Europe.
Reviewed for regulatory accuracy as of May 2026.
Last updated: May 2026.
This article provides general information about Regulation (EU) 2023/1542. The specific application of requirements depends on the individual product, battery category and the role of the economic operator. For a specific assessment, consult a compliance specialist.