Battery Regulation: battery passport from 18 February 2027, due diligence from 18 August 2027

What is the EU Battery Regulation?

The EU Battery Regulation (Regulation (EU) 2023/1542) has governed the entire lifecycle of batteries since 18 August 2024: manufacturing, labelling, take-back, recycling and due diligence in the raw material supply chain. It replaces the 2006 Battery Directive and, as a regulation, applies directly in all member states. Two building blocks particularly affect the supply chain: the digital battery passport from 18 February 2027 and the due diligence obligations for cobalt, graphite, lithium and nickel from 18 August 2027.

The battery passport is, in substance from Article 77, an electronic record per battery, accessible via QR code, containing information on manufacturing, materials, carbon footprint, recycled content, performance and durability. Due diligence requires, in substance from Articles 48 to 52, a management system based on OECD guidance that identifies, assesses and has third parties verify the origin of raw materials and the associated social and environmental risks.

Who is affected?

• Manufacturers and importers of batteries (portable, LMT batteries for e-bikes and scooters, starter, industrial, EV batteries): labelling, conformity, take-back, carbon footprint, recycled-content quotas, battery passport.
• Manufacturers of products with built-in batteries: removability and replaceability, labelling, information duties.
• Economic operators with due diligence obligations: anyone placing batteries on the market with a net turnover above €40 million must comply with due diligence for cobalt, natural graphite, lithium and nickel from 18 August 2027. The Commission proposes raising the threshold to €150 million (Omnibus IV); Council and Parliament reached political agreement on 9 June 2026, formal adoption is pending.
• Suppliers in the battery supply chain: not directly obliged, but recipients of data requests: cell manufacturers, cathode materials, housings, electronics, raw material traders.

Not affected: companies that neither manufacture, import nor place batteries or battery-powered products on the market and do not supply into the battery chain. Buying batteries for your own operations makes you an end user.

What applies from when?

The Commission’s implementing act on access rights and technical details of the battery passport was due by 18 August 2026 and has not yet been adopted; the Commission plans it for the fourth quarter of 2026. Anyone preparing the passport works with the requirements of Annex XIII and the CEN/CENELEC standards until then.

Which concrete obligations arise?

For battery manufacturers and importers:

1. Create the battery passport: a unique record per battery with the mandatory data from Annex XIII, accessible via QR code, kept current across the lifecycle.
2. Declare the carbon footprint: calculation according to the Commission’s methodology, performance class, maximum values from 2028.
3. Build a due diligence management system: company policy, supply chain traceability for cobalt, graphite, lithium, nickel, risk assessment based on OECD guidance, verification by a notified body, annual public report.
4. Document recycled content and meet the quotas from 2031.
5. Label and inform: capacity, hazardous substances, separate collection, QR code from 2027.
6. Organise take-back and recycling: through producer responsibility, in Germany under the Battery Law Implementation Act.

For suppliers this means: you receive structured requests on material origin, recycled content, carbon data and due diligence evidence, usually via questionnaire or supplier portal, often a year before the legal deadlines.

Common misconceptions

• “We are below €40 million turnover, so no due diligence.” Legally correct, practically meaningless: your customer above the threshold has to deliver the data and requests it from you. Contractually, the obligation lands with you.
• Waiting for the €150 million threshold. It is a proposal with political agreement, not law. Plan with €40 million until the Official Journal says otherwise.
• Dismissing the battery passport as an IT topic. The passport is largely a supply chain data topic: raw material origin, recycled content, carbon values per component. Without supplier data the passport stays empty.
• Only watching the four raw materials. Due diligence applies to cobalt, graphite, lithium and nickel. Customer data requests often go further, to copper or manganese, because OEMs apply their own standards.

How SCRM Guard helps

The Battery Regulation compliance module on the platform records per supplier and component which data is needed for the passport and due diligence, collects it via email requests and tracks what is documented. Material monitoring resolves your bills of materials down to raw-material level and shows where cobalt, graphite, lithium and nickel sit in your products, with sources. Raw-material monitoring watches these materials for supply, price and concentration risks.

In the full service we answer your customers’ data requests together with you, build the evidence documentation and keep you informed about the status of Omnibus IV and the battery passport acts, including the information on when you actually have to act.

Sources

• Regulation (EU) 2023/1542 concerning batteries and waste batteries, EUR-Lex (28 Jul 2023)
• Regulation (EU) 2025/1561 (postponement of due diligence obligations to 18 Aug 2027) (30 Jul 2025)
• European Commission: Batteries (Environment, waste and recycling) (01 Jul 2026)
• European Parliament, Legislative Train: Omnibus IV (small mid-caps) (01 Aug 2026)

This page is an editorial briefing for procurement and compliance teams in mid-sized companies, not legal advice. We check deadlines and thresholds against primary sources; the review date is shown at the top of the page.