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Compliance timeline

The deadlines of the Batteries Regulation (EU) 2023/1542 and the Packaging Regulation (EU) 2025/40 that matter to producers, importers and distributors of batteries. Dates that depend on an act not yet adopted are marked.
  1. Batteries Regulation applies

    The Regulation replaces Directive 2006/66/EC. The substance restrictions (Art. 6, Annex I) apply; most other obligations start on the dates that follow.

    Legal basis
    Reg. 2023/1542 Art. 96
    For
    manufacturers, importers, and distributors
    Categories
    all categories
  2. Performance documentation, BMS data and conformity assessment

    Performance and durability documentation (Art. 10), safety of stationary storage (Art. 12), state of health data in the BMS (Art. 14), conformity assessment (Art. 17) with the EU declaration of conformity (Art. 18) and CE marking.

    Legal basis
    Reg. 2023/1542 Art. 10, 12, 14, 17–18, Chapter VI
    For
    manufacturers, importers, and distributors
    Categories
    all categories
  3. EU declaration of conformity

    A declaration per battery model, kept for 10 years and reachable from the QR code / the passport.

    Legal basis
    Reg. 2023/1542 Art. 18, Annex IX
    For
    manufacturers
    Categories
    all categories
  4. Carbon footprint declaration – EV batteries

    Carbon footprint declaration per battery model and manufacturing plant, verified by a notified body.

    Legal basis
    Reg. 2023/1542 Art. 7(1)
    For
    manufacturers
    Categories
    Electric vehicle (EV)
    Depends on an act not yet adopted

    Date of the delegated act on the calculation methodology; the platform uses 18 February 2025.

  5. Separate collection symbol

    The crossed-out wheeled bin on every battery (or on the packaging when the battery is too small).

    Legal basis
    Reg. 2023/1542 Art. 13(4), Annex VI Part B
    For
    manufacturers
    Categories
    all categories
  6. Carbon footprint declaration – industrial batteries > 2 kWh

    Carbon footprint declaration for rechargeable industrial batteries above 2 kWh (without external storage).

    Legal basis
    Reg. 2023/1542 Art. 7(1)
    For
    manufacturers
    Categories
    Stationary energy storage, Industrial (other), and Industrial without BMS
    Depends on an act not yet adopted

    Or 18 months after the delegated act on the calculation methodology and the implementing act on the format, whichever is later; the acts were not adopted by October 2026.

  7. Packaging Regulation applies

    Heavy metals limit, technical documentation and declaration of conformity of the packaging, registration of producers of packaging.

    Legal basis
    Reg. 2025/40 Art. 71; Art. 5, 11, 39, 44
    For
    manufacturers and importers
    Categories
    all categories
  8. Producer registration – packaging

    Registration in the producer register of every Member State where packaged batteries are made available.

    Legal basis
    Reg. 2025/40 Art. 44–45
    For
    manufacturers and importers
    Categories
    all categories
  9. General label and capacity label

    The label with the manufacturer, model, date, weight, capacity, chemistry, hazardous substances, extinguishing agent and critical raw materials; the capacity label for LMT.

    Legal basis
    Reg. 2023/1542 Art. 13(1)–(2), Annex VI Part A
    For
    manufacturers
    Categories
    all categories
    Depends on an act not yet adopted

    Or 18 months after the implementing act of Art. 13(10), whichever is later; the act was not adopted by October 2026.

  10. Today

  11. Battery passport and QR code

    Every LMT, industrial > 2 kWh and EV battery placed on the market or put into service needs a passport, reached through the QR code on the battery. Every other battery needs a QR code to its label information, EU declaration and waste information.

    Legal basis
    Reg. 2023/1542 Art. 77–78, Art. 13(6), Annex XIII
    For
    manufacturers and importers
    Categories
    all categories
  12. Removability and replaceability – LMT

    LMT batteries (and their cells) removable and replaceable by an independent professional.

    Legal basis
    Reg. 2023/1542 Art. 11
    For
    manufacturers
    Categories
    Light means of transport (LMT)
  13. Supply chain due diligence

    Policy, risk management, third-party verification and annual report for operators with a net turnover of 40 million EUR or more.

    Legal basis
    Reg. 2023/1542 Art. 48–52, Annex X (postponed by Reg. 2025/1561)
    For
    manufacturers and importers
    Categories
    all categories
  14. Packaging material label

    Harmonised label of the material composition on every packaging; reuse label where applicable.

    Legal basis
    Reg. 2025/40 Art. 12
    For
    manufacturers and importers
    Categories
    all categories
    Depends on an act not yet adopted

    24 months after the implementing act of Art. 12(6); the act was not adopted by October 2026.

  15. Recycled content documentation

    Documentation of the recycled cobalt, lead, lithium and nickel in the active materials (EV and industrial batteries > 2 kWh without exclusively external storage).

    Legal basis
    Reg. 2023/1542 Art. 8(1)
    For
    manufacturers
    Categories
    Electric vehicle (EV), Stationary energy storage, Industrial (other), and Industrial without BMS
    Depends on an act not yet adopted

    Or 24 months after the delegated act on the calculation methodology and the format, whichever is later.

  16. Carbon footprint declaration – LMT

    Carbon footprint declaration for LMT batteries.

    Legal basis
    Reg. 2023/1542 Art. 7(1)
    For
    manufacturers
    Categories
    Light means of transport (LMT)
    Depends on an act not yet adopted

    Or 18 months after the delegated act on the calculation methodology and the implementing act on the format, whichever is later; the acts were not adopted by October 2026.

  17. Packaging: recyclability, recycled plastic, minimisation, empty space

    Recyclability performance grades, minimum recycled content in plastic packaging, minimisation criteria and the 50 % empty space limit.

    Legal basis
    Reg. 2025/40 Art. 6, 7, 10, 24
    For
    manufacturers and importers
    Categories
    all categories
    Depends on an act not yet adopted

    Recyclability grades by delegated act.

  18. Minimum recycled content

    Minimum shares of recycled cobalt (16 %), lead (85 %), lithium (6 %) and nickel (6 %) – EV and industrial batteries; not LMT batteries.

    Legal basis
    Reg. 2023/1542 Art. 8(2)
    For
    manufacturers
    Categories
    Electric vehicle (EV), Stationary energy storage, Industrial (other), and Industrial without BMS
  19. Recycled content documentation – LMT

    Documentation of the recycled cobalt, lead, lithium and nickel in the active materials of LMT batteries.

    Legal basis
    Reg. 2023/1542 Art. 8(1), second subparagraph
    For
    manufacturers
    Categories
    Light means of transport (LMT)
  20. Higher minimum recycled content

    Cobalt 26 %, lead 85 %, lithium 12 %, nickel 15 %.

    Legal basis
    Reg. 2023/1542 Art. 8(3)
    For
    manufacturers
    Categories
    Electric vehicle (EV), Light means of transport (LMT), Stationary energy storage, Industrial (other), and Industrial without BMS

See where your own models stand

In the panel, the compliance calendar checks each of your battery models against these dates. It comes with the Business plan.