EU Battery Regulation (EU) 2023/1542: Content, Implementation, Current Status

With the EU Battery Regulation (EU) 2023/1542, the European Union has introduced, for the first time, a directly applicable and fully harmonized legal framework covering the entire lifecycle of batteries – from raw material sourcing and design to placing on the market, use, take-back, recycling, and secondary raw materials.

The regulation entered into force on 17 August 2023 and largely applies from 18 February 2024. It fundamentally changes how battery-related data must be collected, structured, maintained, and shared across the value chain.

For companies, this is not just a compliance exercise. It is a structural shift toward digital, lifecycle-based product data management.

1. Scope: Which Batteries Are Covered?

The regulation applies broadly to almost all battery types, whether sold individually or integrated into products, including:

• Portable batteries
• SLI batteries (starting, lighting, ignition)
• LMT batteries (e.g. e-bikes, e-scooters)
• Electric vehicle (EV) batteries
• Industrial batteries, including stationary energy storage

Only limited exemptions apply, mainly for military and national security purposes.

In practice, most manufacturers, importers, distributors, and product owners dealing with batteries are affected.

2. Core Content: What Does the Regulation Require?

The EU Battery Regulation is intentionally designed as an end-to-end framework. Its requirements can be grouped into eight main areas.

A) Sustainability and Product Requirements

• Carbon footprint: Gradual introduction of declaration requirements, harmonized calculation methods, and later potential threshold values.
• Recycled content: Mandatory minimum shares of recycled raw materials for certain battery chemistries.
• Performance and durability: Defined technical and lifetime parameters depending on battery category.

Many of these requirements will be specified in detail via delegated and implementing acts, making the framework dynamic rather than static.

B) Safety, Conformity, and Market Surveillance

The regulation is integrated into the EU product safety and conformity system. Depending on battery type, manufacturers must provide conformity assessments, technical documentation, and evidence for market surveillance authorities.

C) Labeling and Information Obligations

Batteries must carry standardized information, including:

• Technical performance data
• Safety and substance-related information
• End-of-life and recycling instructions

These obligations increase transparency for users, recyclers, and regulators.

D) Removability and Replaceability

For certain embedded batteries, the regulation requires that batteries can be removed and replaced, supporting repairability and longer product lifecycles, subject to defined exceptions.

E) Collection, Take-Back, Recycling, and Recovery

• Higher collection targets
• Stricter recycling efficiency and material recovery requirements
• Additional rules for calculation and verification, further clarified in 2024–2025

F) Extended Producer Responsibility (EPR)

Manufacturers (and equivalent “producers”) must:

• Register in national EPR systems
• Finance and organize take-back and recycling schemes
• Provide standardized information and reporting

A key milestone is 18 August 2025, when the old Battery Directive is fully repealed and the new regulation becomes the sole legal basis.

G) Supply Chain Due Diligence

For critical raw materials such as cobalt, lithium, nickel, and natural graphite, the regulation introduces mandatory due diligence obligations.

Important update: In 2025, the EU postponed the application of these obligations by two years.

New start date: 18 August 2027.

H) Digital Battery Passport and QR Code Access

One of the most transformative elements is the digital Battery Passport.

From 18 February 2027, certain batteries (notably EV batteries and selected industrial batteries above defined capacity thresholds) must be accompanied by a digital battery passport, typically accessed via a QR code.

The passport is not a PDF, but a structured, digital data object with defined access rights and update requirements.

3. Implementation Timeline: Key Dates at a Glance

• 17 August 2023 – Regulation enters into force
• 18 February 2024 – General application of core provisions
• 18 August 2025 – Repeal of the old Battery Directive; EPR obligations fully active
• 18 February 2027 – Digital Battery Passport becomes mandatory
• 18 August 2027 – Supply chain due diligence obligations apply

Many technical details depend on secondary legislation, guidance documents, and standards that are still being finalized.

4. Current Status (End of 2025)

As of late 2025, the situation can be summarized as follows:

1. The regulation is fully in force and operational.
2. The old Battery Directive has been replaced.
3. Due diligence obligations have been postponed to allow industry preparation.
4. Work on data models, methodologies, and governance for the Battery Passport is ongoing.
5. Authorities and standardization bodies continue to refine guidance, confirming that compliance is a continuous process, not a one-time project.

5. Why This Is Highly Relevant for AIRdBASE

At its core, the EU Battery Regulation is a data regulation.

Compliance depends on the ability to:

• Manage structured battery data
• Maintain documentation and evidence over many years
• Control access rights for different stakeholders
• Ensure traceability across the full lifecycle

This is exactly where AIRdBASE fits in.

6. AIRdBASE as a Battery Compliance Backbone

Using AIRdBASE, each battery or battery-powered product can be managed as a digital object, linked to:

• Structured master and technical data
• Compliance documents and certificates
• Supplier declarations and audit evidence
• Version history and change logs
• Defined user roles and access permissions
• Notifications and workflows for missing or outdated data

This creates a single source of truth for battery compliance.

7. Smart IDs and QR Codes: The Foundation of the Battery Passport

The Battery Passport relies on QR-based access. AIRdBASE is built around this exact concept:

• A Smart ID (QR code) uniquely identifies each battery or product
• Scanning the code provides controlled access to relevant data
• Public, partner-specific, and authority-specific views can be separated
• Data remains structured, auditable, and up to date

Instead of distributing static documents, companies operate a living digital product record.

8. Practical Use Cases

• Manufacturers / OEMs: Central compliance and evidence management per battery platform or series
• Importers & distributors: Structured collection of supplier data and regulatory proof
• Service & second-life operators: Linking usage, maintenance, and condition data to the battery object
• Recyclers & EPR partners: Secure, role-based access to relevant end-of-life information

Conclusion

The EU Battery Regulation (EU) 2023/1542 introduces a new operational model for batteries: digital, transparent, lifecycle-based, and verifiable.

By 2027, the Battery Passport will be the central interface between manufacturers, users, authorities, and recyclers. Companies that treat this early as a data and process challenge, rather than a last-minute compliance task, will gain a clear advantage.

AIRdBASE provides the structural foundation for this approach:

object-based data management, Smart IDs (QR codes), controlled access, and audit-ready documentation – exactly what the Battery Regulation requires.