Regulation (EU) 2023/1542 enters into force, replacing Battery Directive 2006/66/EC.
EU Battery Regulation (EUBR)
The EU Battery Regulation applies to any manufacturer, importer, or distributor placing batteries on the EU market, regardless of production origin. Core obligations cover a Digital Battery Passport for EV, LMT, and industrial batteries above 2 kWh, supply chain due diligence for cobalt, natural graphite, lithium, and nickel, and carbon footprint declarations per battery model and production site.
Next deadline:
February 18, 2027: Digital Battery Passport becomes mandatory for all EV, LMT, and industrial batteries above 2 kWh placed on the EU market.
A harmonised battery label expanding labeling requirements covering capacity, lifespan and disposal information is expected pending the final implementation of the regulation. The separate-collection symbol already applies to all batteries as of August 18, 2025.
Battery Passport compliance requires unique digital identifiers per battery unit, interoperable data architecture, supplier-verified material and carbon data, and technical capacity to serve QR-linked records to regulators, recyclers, and service providers on demand.
The data collection and system integration this standard requires involve supplier engagement and design decisions that precede the February 2027 deadline.
osapiens x TÜV SÜD
The Battery Passport: Turning Product Data into Market Access
This guide brings together osapiens' product data and software perspective with TÜV SÜD's expertise in testing, inspection, and certification. It covers what Battery Passport readiness means in practice, from assigning responsibility and structuring product data to building the assurance that a passport can hold up to scrutiny.
Regulation timeline
What the EU Battery regulation requires
The EU Battery Regulation entered into force on August 17, 2023 and has applied directly across all 27 EU member states since February 18, 2024. It covers the full battery lifecycle, including raw material sourcing, production, collection, recycling, and end-of-life management.
The regulation applies to any company placing batteries on the EU market, regardless of production origin. Scope covers portable batteries, industrial batteries above 2 kWh - including stationary energy storage systems (SES) - EV batteries, and LMT batteries including e-bikes and electric scooters.
Core obligations include a Digital Battery Passport for EV, LMT, and industrial batteries above 2 kWh from February 18, 2027, which must be registered in the EU's central Digital Product Passport Registry before the battery is placed on the market, supply chain due diligence for cobalt, natural graphite, lithium, and nickel from August 18, 2027, and extended producer responsibility for battery collection. Carbon footprint declarations, a harmonised battery label, and recycled-content disclosure and thresholds will apply as the Commission finalizes the underlying methodologies - these are not yet in force.
Common EU Battery Regulation implementation challenges
Battery Passport data must meet a structured, verified technical standard
The Digital Battery Passport must be accessible via a QR code indelibly affixed to the battery and requires a unique digital identifier per battery unit, technical integration with an interoperable data system, and role-based access for regulators, recyclers, and repair professionals. Supplier-level data must be assembled at the granularity the passport specification requires.
Passport registration in the EU DPP Registry - the Commission's central database for customs and market surveillance access - adds a further coordination point alongside the QR code and access-tier requirements.
Carbon footprint declarations require model-level and facility-level granularity
Article 7 sets out carbon footprint declarations using the PEF methodology, covering emissions through the production gate and requiring verification by a third-party notified body. Portfolio-level calculations and sector averages will not satisfy this standard once it applies.
Due diligence obligations for critical raw materials require independent verification
Articles 48 to 56 require companies above the applicable turnover threshold (€40 million) to implement an OECD-aligned due diligence policy covering cobalt, natural graphite, lithium, and nickel. Programs must identify and assess supply chain risks, document mitigation actions, and submit to third-party verification by a notified body before August 18, 2027.
EUBR obligations apply on different dates across battery types and capacity thresholds
Carbon footprint declarations are planned to apply first to EV batteries, then extend to industrial batteries above 2 kWh and later to LMT batteries. Recycled-content disclosure and thresholds, performance standards, and collection obligations each carry separate phased timelines.
Battery disclosures, carbon footprint data, and Digital Battery Passport readiness for EUBR
The osapiens HUB for General Product Compliance manages carbon footprint data collection, supplier due diligence documentation, and battery disclosure workflows across the EUBR implementation schedule.
Assign battery models to compliance templates and collect supplier data through the osapiens Supplier Portal
CB codes or product categories map each battery model to the correct compliance standard within the osapiens HUB. Then, structured data requests go to suppliers via the osapiens Supplier Portal, which has over 100,000 registered suppliers and connects directly to the osapiens HUB. Each supplier response is evaluated as conformant, non-conformant, or not applicable and attestation levels 'self-declared', 'certificate-backed' and 'third-party verified' can be set. This closes the supplier data gap so that EUBR readiness efforts don't get stalled.
Map bill-of-materials (BOM) compliance across supplier tiers and connect to ERP, PLM, or PIM systems
The osapiens HUB for General Product Compliance provides bill-of-materials-level visibility across supplier tiers, with all supporting documents, declarations, and regulatory records held in one central repository. A two-way integration layer connects to ERP, PLM, and PIM systems so compliance data flows directly into the existing product master without manual transfers.
Build the data foundation for Battery Passport compliance through existing product disclosure workflows
Material composition, carbon footprint, recycled content, and due diligence data collected through the osapiens HUB for General Product Compliance forms the structured data layer the Digital Battery Passport will require. The osapiens HUB for Digital Product Passport is updated and maintained by legal experts as EUBR delegated acts further define the requirements.
Generate identifiers and QR codes at scale
Battery Passport compliance requires a unique identifier per battery unit and a QR code that resolves reliably across regulators, recyclers, and service providers. As a long-term GS1 partner, the osapiens HUB automatically generates and manages these identifiers and QR codes - so passport data is interoperable with controlled access for different audiences
Frequently asked questions
The EU Battery Regulation applies to any manufacturer, importer, or distributor placing batteries on the EU market, regardless of where those batteries were produced. Scope covers all battery categories: portable batteries, industrial batteries above 2 kWh, EV batteries, LMT batteries including e-bikes and electric scooters, and stationary energy storage systems above 2 kWh.
There is no blanket exemption by company size, though due diligence obligations currently apply only to companies with annual turnover above €40 million. A European Commission proposal (not yet adopted as of June 2026) would raise this threshold to €150 million annual turnover.
The Digital Battery Passport is an electronic record, accessible via a QR code or other data carrier on the physical battery, containing model-level and unit-level data including chemical composition, carbon footprint, recycled content percentages, performance and durability parameters, and supply chain due diligence results.
The Digital Battery Passport becomes mandatory on February 18, 2027 for EV batteries, LMT batteries, and industrial batteries above 2 kWh. From the same date, all batteries must carry a data carrier providing access to basic information including capacity, chemistry, and disposal guidance.
The manufacturer or importer placing the battery on the EU market is responsible for the accuracy and completeness of the passport data.
Article 7 requires manufacturers to calculate and declare the carbon footprint for each battery model at each production facility, expressed in kilograms of CO2 equivalent per kilowatt-hour of total energy delivered over the battery's service life. Calculations must use the Product Environmental Footprint (PEF) methodology, be verified by a third-party notified body, and carbon offsets cannot reduce the declared figure.
The obligation has applied to EV batteries since February 18, 2025, extended to rechargeable industrial batteries above 2 kWh from February 18, 2026, with LMT batteries following in August 2028.
Until February 18, 2027, declarations must accompany the battery physically; after that date, they are accessible via the Digital Battery Passport QR code.
Articles 48 to 56 of the EU Battery Regulation require companies with annual turnover above €40 million to implement an OECD-aligned due diligence policy covering the responsible sourcing of cobalt, natural graphite, lithium, and nickel. Programs must identify and assess supply chain risks related to human rights violations, environmental damage, and corruption in extraction regions, document mitigation actions, and submit to independent verification by a third-party notified body. The application date was postponed from August 2025 to August 18, 2027 via Regulation (EU) 2025/1561. A Commission proposal currently under review (not yet adopted as of June 2026) would raise the exemption threshold from €40 million to €150 million annual turnover.
Member states set penalties under national law, with the regulation requiring them to be effective, proportionate, and dissuasive. Non-compliant batteries cannot legally be placed on the EU market. Batteries without a valid Digital Battery Passport from February 18, 2027 are blocked from market entry at that point. Member states were required to establish their penalty frameworks by 2025.
Mandatory minimum recycled content levels for industrial batteries above 2 kWh and EV batteries take effect on August 18, 2031: cobalt 16%, lead 85%, lithium 6%, nickel 6%.
A second set of stricter targets applies from August 18, 2036: cobalt 26%, lithium 12%, nickel 15%.
From August 18, 2028, companies must declare the share of recycled cobalt, lithium, nickel, and lead in these battery categories, verified against actual supplier data. Supplier declarations without underlying verifiable documentation do not satisfy the evidence standard.
The Digital Battery Passport is the first product category implementation of the broader Digital Product Passport framework established under the Ecodesign for Sustainable Products Regulation (ESPR).
Data collected for EUBR compliance, including material composition, carbon footprint, recycled content, and due diligence evidence, forms part of the data layer that feeds DPP records as ESPR designates additional product categories by delegated act.
The osapiens HUB for General Product Compliance runs EUBR and PPWR supplier engagement through a shared workflow without parallel data collection.
