Regulation (EU) 2023/1542 enters into force, replacing Battery Directive 2006/66/EC.
Free guide · osapiens x TÜV SÜD
EU Batteries Regulation: What you need to prepare by 18 February 2027
The free guide by osapiens and TÜV SÜD shows who is responsible for the Digital Battery Passport and which data must be in place before the deadline.
Intro to list: What you will learn in the guide:
- Which batteries require a Digital Battery Passport as a market access requirement from 18 February 2027
- Who carries responsibility along your value chain
- What level of data readiness is required before the deadline, and why transparent product data is a competitive advantage
TÜV SÜD
Guide created together with TÜV SÜD
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enterprise customers worldwide trust the osapiens HUB
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suppliers registered on the osapiens supplier portal
What the EU Batteries Regulation requires
The EU Batteries Regulation entered into force on 17 August 2023 and has applied directly in all 27 EU Member States since 18 February 2024. It covers the entire battery life cycle, from sourcing raw materials through manufacturing and use to collection, recycling and disposal at end of life.
The Regulation applies to all manufacturers, importers and distributors placing batteries on the EU market, regardless of where they were produced. Its scope covers portable batteries, industrial batteries with a capacity above 2 kWh, light means of transport (LMT) batteries, electric vehicle batteries and stationary battery energy storage systems (SBESS) with a capacity above 2 kWh.
Key obligations include carbon footprint declarations per battery model and manufacturing plant based on the Product Environmental Footprint (PEF) methodology, supply chain due diligence for cobalt, natural graphite, lithium and nickel, and the Digital Battery Passport for EV, LMT and industrial batteries above 2 kWh. The Regulation also sets binding minimum targets for material recovery and recycled content, and extends producer responsibility for the collection and recycling of waste batteries.
Three obligations. One data foundation.
The data for the carbon footprint declaration, the battery passport and due diligence all comes from the same supply chain. Capture it properly once, and you can use it for every proof of compliance.
Carbon footprint declaration per battery model and plant
The challenge:
Calculated using the PEF methodology for every battery model and every manufacturing plant, and verified by a notified body. Portfolio or average values are not enough.
With the osapiens HUB:
Audit-ready carbon footprints per unit, calculated automatically from product master data and bills of materials, including variants and scenarios.
Interoperable data for the Digital Battery Passport
The challenge:
Every battery needs a unique digital identity via QR code, fed by structured supply chain data and accessible to authorities, recyclers and repairers.
With the osapiens HUB:
Material composition, carbon footprint, recycled content and due diligence data are held in the HUB in a structured way: the data foundation for your battery passport.
Due diligence for cobalt, lithium, nickel and natural graphite
The challenge:
Identify and assess risks in the supply chain and document mitigation measures, verified by a notified body from 18 August 2027.
With the osapiens HUB:
Questionnaires, process steps and measures are documented automatically in the supplier profile. Risk signals are detected and tracked until resolved.
Regulation timeline
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.