EU battery passport timeline: every deadline and every pending act

The battery passport becomes mandatory on 18 February 2027: for every LMT battery, every EV battery and every industrial battery above 2 kWh that is placed on the EU market or put into service (Art. 77(1)). The QR code becomes mandatory on all batteries on the same day. Some obligations already apply, such as the performance and durability documentation, the data in the battery management system and the separate collection symbol. Others have no firm date yet, because they depend on acts the Commission has not adopted.

This page lists every date in Regulation (EU) 2023/1542 that affects the battery passport and its data, each with its status, legal basis and source. We last checked them on 25 October 2026.

What do the four statuses mean?

Every line of the timeline carries one of four statuses. It tells you whether a date is settled or still depends on the Commission.

‘In force’ does not mean that obligations already bite. The Regulation entered into force on 17 August 2023, but most of its obligations start later.

Which dates apply?

The full timeline in date order. Each line links to its legal basis.

1. 17 August 2023

   Battery Regulation enters into force

   in force Regulation (EU) 2023/1542 concerning batteries and waste batteries enters into force on the twentieth day after its publication in the Official Journal. Its obligations apply only from the dates it sets. (Art. 96(1))

2. 18 February 2024

   Regulation applies

   applies The Regulation applies wherever a provision does not set its own date. The battery passport, the label and most of the passport data follow later. (Art. 96(2))

3. 18 August 2024

   Performance and durability documentation

   applies Rechargeable industrial batteries above 2 kWh, LMT batteries and EV batteries are accompanied by a document with the values of the parameters in Annex IV Part A. (Art. 10(1))

4. 18 August 2024

   Data in the battery management system

   applies The BMS of stationary battery energy storage systems, LMT batteries and EV batteries holds up-to-date data on state of health and expected lifetime as set out in Annex VII. The legal purchaser gets read-only access. (Art. 14(1), (2))

5. 18 August 2024

   Conformity assessment and obligations of economic operators

   applies Article 17 on conformity assessment procedures and Chapter VI on the obligations of economic operators (Articles 38 to 46) apply. Article 17(2) is the exception: it applies twelve months after the list referred to in Article 30(2) is first published. (Art. 96(2)(b))

6. 18 February 2025

   Carbon footprint declaration for EV batteries

   pending act The declaration applies from this date or 12 months after the delegated act on the calculation method and the implementing act on the format enter into force, whichever is later. When we checked, neither had been adopted, so the obligation does not apply yet. (Art. 7(1)(a))

7. 18 August 2025

   Separate collection symbol

   applies All batteries bear the separate collection symbol shown in Annex VI Part B. (Art. 13(4))

8. 18 August 2025

   Deadline: implementing act on labelling

   delayed By this date the Commission was to adopt harmonised specifications for the labels under Article 13(1) to (3). A draft was open for feedback from December 2025 to January 2026; when we checked, the act had not been adopted. (Art. 13(10))

9. 18 August 2025

   Member State penalties

   applies By this date the Member States lay down the penalties for infringements of the Regulation. Germany did so with the Battery Law Implementation Act (BattDG). (Art. 93)

10. 7 October 2025

    BattDG enters into force

    in force Germany’s Battery Law Implementation Act applies. Failing to ensure that the information in the battery passport is accurate, complete and up to date is an administrative offence with a fine of up to EUR 10,000. (BattDG § 60(2) No. 29, (3))

11. 18 February 2026

    Carbon footprint declaration for rechargeable industrial batteries

    pending act For rechargeable industrial batteries above 2 kWh, except those with exclusively external storage, the declaration applies from this date or 18 months after the acts on method and format enter into force, whichever is later. When we checked, the method for industrial batteries was only planned, so the obligation does not apply yet. (Art. 7(1)(b))

12. 18 February 2026

    Deadline: minimum values for industrial batteries

    delayed By this date the Commission was to set, by delegated act, minimum values for the performance and durability of rechargeable industrial batteries above 2 kWh. When we checked, a draft was open for feedback until 27 October 2026; the act had not been adopted. (Art. 10(5))

13. 15 July 2026

    Six harmonised standards for digital product passports

    in force Implementing Decision (EU) 2026/1736 publishes the references of EN 18216, 18219, 18220, 18221, 18222 and 18223 (data exchange, identifiers, data carriers, storage, APIs, interoperability). They give a presumption of conformity with Articles 10 and 11 of the Ecodesign Regulation, not with the Battery Regulation. (ESPR Art. 41(2); (EU) 2026/1736)

14. 20 July 2026

    EU digital product passport registry launched

    applies The Commission has launched the registry, with a testing environment and a helpdesk. Economic operators upload the unique identifier of each battery there; the passport itself stays with them. (ESPR Art. 13; Art. 77(10))

15. 26 July 2026

    Deadline: due diligence guidelines

    delayed By this date the Commission was to publish guidelines on applying the due diligence requirements of Articles 49 and 50. We did not find them in the Official Journal when we checked. (Art. 48(5))

16. 6 August 2026

    Registry implementing regulation enters into force

    in force Implementing Regulation (EU) 2026/1778 governs the registry: economic operators verify their identity, for example with a qualified electronic seal, register passports through the user interface or an API and receive a proof of registration. ((EU) 2026/1778, Art. 4, 8, 9)

17. 18 August 2026

    Deadline: access rights for a legitimate interest

    delayed By this date the Commission was to specify who counts as a person with a legitimate interest and to what extent they may download, share, publish and re-use which parts of the passport. When we checked, a draft was open for feedback from 19 October to 16 November 2026; the act had not been adopted. (Art. 77(9))

18. 18 August 2026

    Label under Annex VI Part A

    pending act Batteries bear a label with the general information in Annex VI Part A and, depending on the type, capacity information, from this date or 18 months after the implementing act under Article 13(10) enters into force, whichever is later. When we checked, the act was missing, so the label obligation does not apply yet. (Art. 13(1), (2), (3))

19. 18 August 2026

    Deadline: recycled content methodology

    delayed By this date the Commission was to set out, by delegated act, how the recycled share of cobalt, lithium, nickel and lead is calculated, verified and documented. A draft was open for feedback for four weeks from 12 August; when we checked, the act had not been adopted. (Art. 8(1))

20. 16 September 2026

    First harmonised standard under the Battery Regulation

    in force Implementing Decision (EU) 2026/2048 publishes the reference of EN 18060:2025 on the performance and durability of EV batteries. When we checked, there was no harmonised standard yet for stationary or other industrial batteries. (Art. 15(3); (EU) 2026/2048)

21. 18 February 2027

    Battery passport and QR code

    applies Every LMT battery, every industrial battery above 2 kWh and every EV battery placed on the market or put into service needs a battery passport. All batteries bear a QR code; the removability and replaceability rules of Article 11 start on the same day. (Art. 77(1), Art. 13(6))

22. 18 August 2027

    Supply chain due diligence

    applies Economic operators placing batteries on the market meet the due diligence obligations for cobalt, natural graphite, lithium and nickel and have them verified by a notified body. Companies below EUR 40 million net turnover are exempt unless they belong to a group above that threshold. (Art. 47, Art. 48(1))

23. 18 August 2027

    Minimum values for rechargeable industrial batteries

    pending act Rechargeable industrial batteries above 2 kWh, except those with exclusively external storage, must meet the minimum performance and durability values from this date or 18 months after the delegated act enters into force, whichever is later. When we checked, the act was still a draft. (Art. 10(2))

24. 18 August 2028

    Carbon footprint declaration for LMT batteries

    pending act For LMT batteries the declaration applies from this date or 18 months after the acts on method and format enter into force, whichever is later. When we checked, neither had been adopted. (Art. 7(1)(c))

25. 18 August 2028

    Recycled content documentation

    pending act Industrial batteries above 2 kWh (except exclusively external storage), EV batteries and SLI batteries with cobalt, lead, lithium or nickel in active materials are accompanied by recycled content documentation, from this date or 24 months after the delegated act enters into force, whichever is later. When we checked, the act was missing. (Art. 8(1))

26. 18 February 2029

    Deadline: carbon method for industrial batteries with external storage

    pending act By this date the Commission adopts the method and format for industrial batteries with external storage. Their declaration applies from 2030 at the earliest or 18 months after those acts enter into force, whichever is later. (Art. 7(1))

27. 18 August 2031

    First minimum recycled content

    applies Industrial batteries above 2 kWh (except exclusively external storage), EV batteries and SLI batteries contain, per model, year and plant, at least 16 % recovered cobalt, 6 % lithium and 6 % nickel in active materials and 85 % lead, shown in the technical documentation. (Art. 8(2))

28. 18 August 2033

    Recycled content documentation for LMT batteries

    applies The recycled content documentation now also applies to LMT batteries with cobalt, lead, lithium or nickel in active materials. (Art. 8(1))

29. 18 August 2036

    Second stage of recycled content

    applies The minimum shares rise to 26 % cobalt, 12 % lithium and 15 % nickel; lead stays at 85 %. They now also apply to LMT batteries. (Art. 8(3))

How does ‘a fixed date or N months after the act’ work?

Many obligations need the Commission to settle the details first, for instance how the carbon footprint is calculated. For these, the Regulation gives two dates: a fixed date, and a period after the delegated or implementing act enters into force. Whichever comes later applies. Where an obligation depends on two acts, as the carbon footprint declaration depends on both the method and the format, the period runs from the later of the two.

As long as the act is missing, the obligation does not apply, even once the fixed date has passed. That is why nobody asks for a carbon footprint declaration for EV batteries today, although their fixed date was 18 February 2025.

A worked example

Take the minimum performance and durability values for rechargeable industrial batteries. The fixed date is 18 August 2027; the alternative is 18 months after the delegated act under Article 10(5) enters into force.

1. Suppose the act enters into force in June 2027. The date is invented, purely for the arithmetic.
2. Eighteen months later is December 2028.
3. December 2028 is after the fixed date, so the minimum values apply from December 2028.

The fixed date would only have applied if the act had entered into force by 18 February 2026. By this date the Commission should have adopted the act; deadline and fixed date are exactly 18 months apart. Even then it would only have entered into force after the objection period of Parliament and Council (Art. 89(6)); every further month of delay now pushes the obligation further back. Recycled content documentation follows the same pattern. Its fixed date is 24 months after the deadline for the method, 18 August 2026, and that deadline has passed too.

A draft on ‘Have your say’ is only the beginning. Once the Commission adopts a delegated act, the European Parliament and the Council have three months to object, which can be extended by two. The act enters into force only when that period ends without objection or both say earlier that they will not object (Art. 89(6)). Implementing acts are adopted under the examination procedure, after an opinion of a committee of the Member States (Art. 90(3)).

What has no foreseeable date yet?

Some obligations do have fixed dates in the Regulation but build on acts that are missing or exist only as drafts:

• Carbon footprint performance classes (Art. 7(2)): batteries are to show on their label which class their carbon footprint falls into. A separate delegated act defines the classes. For EV batteries its deadline passed in 2025; on ‘Have your say’ it is listed only as a planned initiative.
• Maximum carbon footprint thresholds (Art. 7(3)): another delegated act is to set life-cycle ceilings. The deadline for EV batteries has passed, and we found no such initiative among the battery initiatives on ‘Have your say’.
• Industrial batteries with external storage: their carbon footprint declaration applies from 2030 at the earliest. The Commission has until 18 February 2029 to adopt the method and the format.
• Legitimate interest: who may access the restricted parts of the passport is settled only by the act under Article 77(9). The information itself still belongs in the passport from the start.

The Commission’s FAQ for batteries states that carbon footprint, recycled content and due diligence information will not yet be required at the February 2027 start. BatteryPass therefore marks such fields as ‘later required’ rather than missing in testing.

What does the timeline look like as a table?

The same dates as a table, with the legal basis and source in their own columns, ready to copy into a project plan.

Where is the current status of each act?

Whether a draft exists, when feedback closes and what comes next is tracked on the implementation status page. The glossary explains what a delegated act and an implementing act are. The battery passport guide covers which batteries need a passport and what goes into it, and the data fields page shows which fields are required today.