🇪🇺 EU · New Regulation Alert
EU New Battery Regulation (EU) 2023/1542
Replaces the 2006/66/EC battery directive. Fully enforced from 2026, covering labelling, QR codes, carbon footprint, supply-chain due diligence and recycled content declarations. All products with batteries exported to the EU are affected.
Regulation at a Glance
| Item | Details |
|---|---|
| Full name | Regulation (EU) 2023/1542 — concerning batteries and waste batteries |
| Entry into force | 17 August 2023 |
| Full enforcement | Phased-in mandatory requirements from 2026 |
| Replaces | 2006/66/EC Battery Directive |
| Scope | All batteries placed on the EU market (including those embedded in products), whether or not produced in the EU |
| Legal nature | Regulation — applies directly, no national transposition needed |
| Label format basis | European Commission implementing regulation on label format (Ref. Ares(2025)11169592) |
Enforcement Timeline
The New Battery Regulation takes effect in phases, with different deadlines for different requirements:
| Requirement | Enforcement date | Applicable battery types |
|---|---|---|
| Hazardous substance limits | 18 February 2024 | All batteries |
| CE marking + DoC | 18 August 2024 | All batteries |
| Labelling (basic information) | 18 August 2026 | All batteries |
| Labelling (QR code) | 18 February 2027 | All batteries |
| Carbon footprint declaration | 18 February 2028 | EV + industrial batteries |
| Recycled content declaration | 18 August 2031 | EV + industrial + SLI batteries |
Label Elements Checklist
Different battery types have different label requirements. The following are the basic requirements covering all battery types:
All batteries must state
| Element | Requirement | Description |
|---|---|---|
| Manufacturer information | Company name, registered trademark, contact address | Non-EU manufacturers must indicate an EU authorised representative |
| Battery type identifier | Model, batch number or serial number | Unique identifier to ensure traceability |
| Production date | Manufacturing date (year/month), or a date encoded in the batch number | Affixed on the product or packaging |
| Weight | Battery weight (g or kg) | Mandatory only for industrial and EV batteries |
| Chemical composition | Electrochemical system identifier (e.g., Li-ion/NiMH/Pb) | Uses a unified chemical nomenclature |
| Capacity | Nominal capacity (mAh or Wh) | Mandatory for portable and SLI batteries |
| Hazardous substance symbol | Cd/Pb mark (where applicable) | Marked when cadmium >0.002% or lead >0.004% |
| Separate collection symbol | Crossed-out wheeled bin mark | Mandatory for all batteries, size ≥0.5×0.5cm |
| CE mark | CE mark | Mandatory for all batteries since 18 August 2024 |
QR Code Requirements (from February 2027)
The New Battery Regulation introduces a QR code mechanism, allowing consumers to access key battery information by scanning:
Information the QR code must link to
- Basic battery information (manufacturer, model, chemical composition)
- Separate collection and recycling instructions
- Hazardous substance information
- Safe use instructions
- End-of-life treatment information
QR code technical requirements
| Location | On the battery body or packaging, clearly visible |
| Contrast | Sufficient contrast with the background |
| Format | URL linking to the manufacturer's web page |
| Durability | Readable throughout the battery's service life |
| Language | Official language of the member state where the consumer is located |
Other Key Requirements
| Requirement | Enforcement date | Description |
|---|---|---|
| Supply-chain due diligence | August 2025 | Battery manufacturers with annual revenue >EUR 40 million must establish a due-diligence system covering raw materials such as cobalt, natural graphite, lithium, nickel |
| Carbon footprint declaration | February 2028 | EV and industrial batteries must provide a carbon footprint declaration, with performance classes and maximum thresholds introduced in phases |
| Electrochemical performance and durability | August 2026 | General portable batteries must meet minimum durability requirements (charge/discharge cycles, capacity retention) |
| Removability and replaceability | February 2027 | Portable batteries must be removable and replaceable by the user or an independent professional (except for waterproof devices) |
| Battery passport | February 2027 | EV, industrial and LMT batteries require a digital battery passport |
| Recycled content declaration | August 2031 | EV and industrial batteries must declare the recycled content proportion of cobalt, lead, lithium, nickel |
Are Built-in Product Batteries Affected?
Yes. The regulation covers "all batteries placed on the EU market" — including non-removable batteries built into products.
This means Bluetooth earphones, smart watches, electric toothbrushes, wireless mice — any product containing a battery — must display compliance information on the battery body or in the accompanying product documentation.
Practical point: Many electronics manufacturers are not yet aware of the impact of the New Battery Regulation. If you are a brand owner/OEM, we recommend promptly reviewing all battery-containing products' labels and documents for compliance — especially the CE mark and the separate collection symbol.
FAQs
What is the relationship between the New Battery Regulation and UN38.3?
The two are completely independent. UN38.3 is a transport safety test (UN recommendations on the transport of dangerous goods), focusing on safety during transport. The New Battery Regulation is an EU market access requirement, focusing on environmental and sustainability aspects across the product's life cycle. They do not replace each other and both are required.
My product uses a standard 18650 battery. Do I still need to do anything separately?
Responsibility lies with the entity "placing on the market". If the battery you purchase already carries compliant labelling (the manufacturer has labelled it per the new regulation), the host product only needs to ensure the label information isn't obscured and include the battery compliance information in the accompanying documents. But if the battery supplier has not yet complied, you as the host manufacturer need to coordinate a resolution.
When does the carbon footprint declaration become mandatory?
The carbon footprint declaration is required for EV and industrial batteries from February 2028. Portable batteries (including consumer electronics batteries such as Bluetooth earphones and smart watches) currently have no clear mandatory carbon footprint timeline, but we recommend monitoring subsequent legislative developments.
What are the consequences of violating the New Battery Regulation?
Similar to CE violations: product delisting, customs refusal, fines (member states set specific amounts), and e-commerce platform delisting. Serious violations may trigger the EU rapid alert system (RAPEX), affecting the entire EU market.
Are your product labels compliant with the New Battery Regulation?
Provide your product information and battery specification and we'll assess your labelling compliance gap and a remediation plan
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