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The EU Battery Regulation timeline, date by date

The regulation phases in over more than a decade, and several dates depend on acts the Commission hasn't adopted yet. Here is what applies when, and which dates are firm.

Updated · 4 min read

The Battery Regulation, Regulation (EU) 2023/1542, took effect in August 2023 and phases in its duties over the following thirteen years. The most important thing to know about its timeline is that not every date is firm. Several are written as "this date, or a set time after the Commission adopts the detailed rules, whichever is later", and as of October 2026 some of those rules still haven't been adopted.

So it helps to sort the dates into two groups: the ones that apply on the day, and the ones waiting on the Commission.

Dates that apply on the day

Date What applies
18 February 2024 The regulation applies (Art. 96)
18 August 2024 Conformity assessment (Art. 17), CE marking, and state-of-health data in the battery management system of EV, LMT and stationary batteries (Art. 14)
18 August 2025 Separate-collection symbol on every battery (Art. 13(4)); cadmium and lead symbols above the thresholds (Art. 13(5))
31 December 2025 Recycling efficiency targets for recyclers (Annex XII Part B)
18 February 2027 Battery passport for EV, LMT and industrial batteries above 2 kWh (Art. 77); QR code on every battery (Art. 13(6)); removability and replaceability (Art. 11)
18 August 2027 Supply-chain due diligence (Arts. 48 to 52), moved from 2025 by Regulation (EU) 2025/1561
31 December 2027 Material recovery targets for recyclers: 50% lithium, 90% cobalt, copper, lead and nickel
18 August 2031 First minimum recycled-content shares: 16% cobalt, 85% lead, 6% lithium, 6% nickel (Art. 8)
31 December 2031 Higher recovery targets: 80% lithium, 95% for the others
18 August 2036 Second recycled-content shares: 26% cobalt, 85% lead, 12% lithium, 15% nickel

The passport deadline has not moved, and nothing published so far suggests it will.

Dates waiting on the Commission

These are written with fixed dates, but they only apply once the delegated or implementing act behind them is adopted and a set period has passed. As of October 2026, none of them has been triggered:

  • Carbon footprint declaration (Art. 7(1)): due from 18 February 2025 for EV batteries and 18 February 2026 for industrial batteries above 2 kWh, but only 12 or 18 months after the methodology and format acts. For LMT batteries the earliest date is 18 August 2028. Commission guidance in 2026 said the declaration is not to be shown in passports from February 2027.
  • Carbon performance classes (Art. 7(2)) and maximum carbon thresholds (Art. 7(3)), from 2026 and 2028 at the earliest for EV batteries.
  • General labelling (Art. 13(1) to (3)): due from 18 August 2026, or 18 months after the implementing act on the label format, whichever is later. That act hasn't been adopted.
  • Recycled-content documentation (Art. 8(1)): from 18 August 2028, or 24 months after its delegated act, whichever is later.
  • Who has a "legitimate interest" in restricted passport data (Art. 77(9)): the act was due by 18 August 2026 and is still outstanding.

The practical reading: prepare as if the later dates will arrive, because the evidence takes longer to gather than the acts take to publish. Leave space on labels and fields in your data model for what isn't required yet.

The wider Digital Product Passport

The battery passport is the first of many. Under the ESPR, other product groups get their own passports through delegated acts, each applying at least 18 months after it takes effect. The Commission's working plan for 2025 to 2030 points to iron and steel first, then textiles, tyres and aluminium around 2027, furniture in 2028 and mattresses in 2029. Separate laws bring passports for toys and detergents, and construction products get a system of their own. Treat all of these dates as estimates; delegated acts have often slipped by six to twelve months.

FAQ

When does the EU battery passport become mandatory?

On 18 February 2027, for EV batteries, LMT batteries and industrial batteries above 2 kWh first placed on the EU market from that date.

Has the battery passport deadline been postponed?

No. Supply-chain due diligence was moved from 2025 to 18 August 2027, but the passport deadline of 18 February 2027 is unchanged.

When do recycled-content minimums start?

The first minimum shares apply from 18 August 2031 (16% cobalt, 85% lead, 6% lithium, 6% nickel) and rise from 18 August 2036. Documenting recycled content starts earlier.

Sources

General information, not legal advice. Checked against the sources above on 31 October 2026; the Commission is still adopting the acts that fill in the detail, so check before relying on a date.