EU Batteries Regulation 2023/1542 for exporters: key dates 2025–2028

Timeline of obligations

• 18 August 2023: the Regulation entered into force; it has applied since 18 February 2024, including CE marking against the new requirements.
• 18 August 2025: the producer responsibility rules took effect and the Regulation replaced the Batteries Directive 2006/66/EC.
• 18 August 2026: harmonised labelling requirements expand, or 18 months after the implementing acts enter into force if that is later.
• 18 February 2027: all batteries must bear a QR code giving access to information and declarations; EV, LMT and industrial batteries over 2 kWh need a digital battery passport; portable batteries in products must be user-removable using commonly available tools.
• 18 August 2027: due diligence obligations on the battery supply chain start, after a two-year postponement.
• 18 August 2028: declarations of recycled content begin for specified categories; minimum recycled content applies from 18 August 2031 and 18 August 2036 depending on the category.

Producer registration and the authorised representative

The producer responsibility rules mean that whoever first makes batteries available in an EU country, alone or inside products, must register there and finance collection and recycling. In Germany, for example, stiftung ear registers battery producers since 18 August 2025, every producer joins an organisation for producer responsibility (OfH) or sets up its own, and producers without an establishment in Germany must register through an authorised representative based there. Exporters who sell to EU consumers directly, or who are named as producer, need to check these rules in each country.

Due diligence after the postponement

Regulation (EU) 2025/1561, adopted on 18 July 2025 as part of the Omnibus IV package and in force since 31 July 2025, postponed the battery supply chain due diligence obligations by two years, from 18 August 2025 to 18 August 2027. Under the Batteries Regulation they apply to economic operators whose net turnover, or that of their group, was at least EUR 40 million in the financial year before the last one. A separate Commission proposal in the Omnibus IV package would raise this threshold to EUR 150 million; it was still under negotiation in late 2025, so check its status before relying on it. The Commission was due to publish guidelines on these obligations by July 2026.