The EU Battery Regulation (Regulation (EU) 2023/1542), in force since 17 August 2023, is the world's first product-level sustainability regulation covering a battery's full life cycle. Per the compliance calendar maintained by sorena.io (updated 15 October 2026) and the explainer by myproductpassport.eu (updated 28 October 2026), 2026–2027 is the dense implementation window: general labelling applies from August 2026, the battery passport and QR code become mandatory in February 2027, and due diligence starts in August 2027. The text has been amended twice: Regulation (EU) 2025/1561 moved the due-diligence start to 18 August 2027, and Regulation (EU) 2026/1738 rewrote the Annex I substance restrictions (consolidated text rechecked by FactoryFollow on 24 October 2026).
At industry level, Ma Dejun, chairman of China's battery association, said at the INES2026 conference (29–30 October) that the full implementation of the EU Battery Regulation has made carbon-footprint accounting, supply-chain due diligence and the digital battery passport rigid institutional conditions for cross-border storage trade (Shanghai Securities News, 31 October 2026). For Europe-bound storage systems, compliance is no longer a bonus — it is market access.
Compiled from sorena.io's compliance calendar (15 October 2026) and myproductpassport.eu (28 October 2026). Note the "whichever-is-later" mechanism: for carbon footprint, recycled content and labelling, the listed date or a waiting period (12, 18 or 24 months) after the relevant delegated/implementing act enters into force applies, whichever is later — track the acts themselves.
Date | Obligation | Scope | Article |
18 August 2026 | General labelling applies (or 18 months after the labelling implementing act, whichever later) | All batteries | Art 13(1)–(3) |
20 July 2026 | EU Digital Product Passport Registry opens testing environment | Passport registration | — |
18 February 2027 | QR code on all batteries | All batteries | Art 13(6) |
18 February 2027 | Battery passport mandatory | LMT batteries, industrial batteries above 2kWh, EV batteries | Art 77 |
18 August 2027 | Supply-chain due diligence starts (moved by Regulation (EU) 2025/1561) | Cobalt, natural graphite, lithium, nickel and compounds | Chapter VII / Art 48 |
18 August 2027 | Carbon footprint performance class label (or 18 months after the class act, whichever later) | Rechargeable industrial batteries above 2kWh | Art 7(2) |
18 August 2028 | Recycled-content documentation (or 24 months after the methodology act, whichever later) | Industrial batteries above 2kWh, EV, SLI | Art 8(1) |
18 February 2029 | Maximum lifecycle carbon-footprint threshold (or 18 months after the threshold act; above it, no market placement) | Rechargeable industrial batteries above 2kWh | Art 7(3) |
18 August 2031 | Minimum recycled content: cobalt 16%, lead 85%, lithium 6%, nickel 6% | As above | Art 8(2) |
18 August 2036 | Minimum recycled content rises: cobalt 26%, lead 85%, lithium 12%, nickel 15% | As above | Art 8(3) |
Carbon-footprint obligations under Article 7 run in three phases, each starting on the listed date or after the relevant delegated act enters into force, whichever is later. Per myproductpassport.eu (28 October 2026), the regulation's nominal declaration dates are 18 February 2025 for EV batteries and 18 February 2026 for rechargeable industrial batteries above 2kWh (except exclusively external-storage batteries) — but the obligations only start counting after the Commission adopts the calculation-methodology act, which was still outstanding in September 2026, so actual start dates need tracking. The methodology itself is set out in Commission Delegated Regulation (EU) 2024/1773.
The three phases: declaration (Phase 1, a declared value in kg CO₂e per kWh delivered), performance classes (Phase 2, A–E rating visible in procurement), and maximum thresholds (Phase 3, above which batteries cannot be placed on the market — carbon intensity becomes a market-access condition). Under Annex II, the carbon footprint must be recalculated whenever the bill of materials or the production energy mix changes — this is ongoing data management, not a one-off calculation.
Per myproductpassport.eu (28 October 2026), core passport data includes: battery identity (manufacturer, date and place of manufacture, category, model, weight, unique identifier); technical performance (rated capacity, voltage, expected lifetime in cycles and years, round-trip efficiency, temperature operating range, internal resistance); chemistry (cathode, anode and electrolyte active materials at recycling-grade detail); carbon footprint (lifecycle, calculated and verified per the regulation's methodology); recycled content (actual percentages of cobalt, lithium, nickel and lead, verified by a conformity assessment body); supply-chain due diligence (policies, risk assessment findings and mitigation measures, per OECD guidance, continuously updated); and end-of-life information (collection, reuse and recycling instructions, including safety information).
The passport is accessed through the Article 13(6) QR code and linked to a unique identifier; the economic operator must keep the information accurate, complete and up to date (Art 77(4)). The EU DPP Registry has offered a testing environment since 20 July 2026 — manufacturers can rehearse registration now.
Per myproductpassport.eu (28 October 2026): collection rates must reach 63% for portable batteries by 2027 and 73% by 2030, and 100% for EV and industrial batteries; recycling efficiency must reach 65% of lithium-based battery weight by end-2025 and 70% by end-2030, with 80% of the lithium itself recovered by end-2031 (methodology in Delegated Regulation (EU) 2025/606). For manufacturers, the minimum recycled-content shares from August 2031 (cobalt 16%, lead 85%, lithium 6%, nickel 6%) mean building auditable closed-loop supply chains with recyclers well in advance.
1. Map products to obligations first. Confirm which models fall under the passport scope (essentially all C&I and home storage above 2kWh) and open a compliance file per model.
2. Build carbon-footprint data capability. Collect BOM, energy and process data per model and plant; pre-calculate under Delegated Regulation (EU) 2024/1773 and track the delegated act for the real start date.
3. Collect due-diligence documentation upstream. Require cell and material suppliers to provide traceability and audit documents for cobalt, lithium, nickel and natural graphite, with an update mechanism.
4. Rehearse passport registration. Use the EU DPP Registry testing environment; design the split between model-level and individual-battery data early.
5. Price compliance explicitly. Passport data, verification and third-party audits cost real money — make them visible in export quotations and delivery schedules.
DEMUDA's C&I products for European projects (120kW/215kWh cabinets, 143–215kWh HV rack batteries; product pages: /home/product/detail/id/97.html, /home/product/detail/id/53.html) can be delivered with compliance data prepared along this framework together with customers; see our OEM/ODM selection guide for how compliance duties are divided in OEM/ODM cooperation.
Q1: Which batteries does the EU Battery Regulation cover?
Regulation (EU) 2023/1542 covers nearly all batteries placed on the EU market (portable, SLI, light means of transport, industrial and EV). The battery passport obligation applies to LMT batteries, industrial batteries above 2kWh and EV batteries.
Q2: When does the battery passport become mandatory?
18 February 2027 (Art 77). On the same date all batteries must carry a QR code under Art 13(6), through which the passport is accessed and linked to a unique identifier.
Q3: When does the carbon footprint declaration start for industrial storage batteries?
The nominal date for rechargeable industrial batteries above 2kWh (except exclusively external-storage ones) is 18 February 2026, but the "whichever-is-later" rule applies — the obligation starts 18 months after the relevant delegated act enters into force if that is later. Per myproductpassport.eu (28 October 2026), the act was still outstanding in September 2026; track the act rather than counting down to the nominal date.
Q4: What are the minimum recycled-content shares?
From 18 August 2031: cobalt 16%, lead 85%, lithium 6%, nickel 6%; from 18 August 2036: cobalt 26%, lead 85%, lithium 12%, nickel 15% (Art 8).
Q5: What should Europe-bound storage manufacturers do first?
Open model-level compliance files, pre-calculate carbon footprints under the regulation's methodology, collect supply-chain due-diligence documents, rehearse registration in the EU DPP Registry testing environment, and fold compliance costs into quotations.
