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Obligation check · EU Battery Regulation

Which obligations apply to your battery?

Answer up to eight questions and get your personal checklist: from the battery passport to CE marking and QR code to registration and due diligence – with deadlines and articles. No sign-up, everything stays in your browser.

Question 1

What type of battery is it?

Choose the category in which you place the battery on the market.

Question 2

What is the capacity of the industrial battery?

For industrial batteries, the threshold is 2 kWh.

Question 3

Is it a stationary battery energy storage system?

That is, a permanently installed system that stores and releases energy – from home storage to containers.

Question 4

What is your role?

The regulation assigns obligations according to your role in the supply chain.

Question 5

Do you sell under your own name or brand?

Anyone who offers batteries under their own name or modifies them substantially is generally considered a manufacturer.

Question 6

Where is your company based?

Manufacturers outside the EU need a representative in the EU for some obligations.

Question 7

Is your annual turnover €40 million or more?

The due diligence obligations for raw materials depend on this. Net turnover is decisive; for groups, the consolidated turnover.

Last question

When do you place the batteries on the EU market?

This means the first making available on the EU market or putting into service.

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Meet obligations with Batterypass

Rules as of November 2026. This check provides initial guidance and does not replace legal advice. The text of Regulation (EU) 2023/1542 and the associated legal acts in their currently applicable version is authoritative.

The rule in brief

Who needs a passport from 2027?

Battery categoryExamplesBattery passport from 18 Feb 2027
LMT batteryE-bike, e-scooter, e-mopedYes – every unit
Industrial battery > 2 kWhHome and commercial storage, forklifts, backup powerYes – every unit
Electric vehicle batteryTraction battery for EV or hybridYes – every unit
Industrial battery ≤ 2 kWhsmaller industrial applicationsNo
Starter battery (SLI)Starter battery in a carNo
Portable batterySmartphone, tools, laptopNo

Even without the passport obligation, other requirements of the regulation apply to all batteries, such as labelling, registration and extended producer responsibility.

What the check covers

22 obligations from the EU Battery Regulation.

The check maps every obligation to your battery category and role and shows whether it already applies, when it is coming or whether the date is still open.

Product

Substance restrictions, performance and durability, safety of stationary storage, data in the battery management system, removability and replaceability.

Conformity & labelling

Conformity assessment, EU declaration of conformity, CE marking, label, collection symbol and QR code.

Data & evidence

Digital battery passport, carbon footprint, recycled content and due diligence in the raw material supply chain.

Market & take-back

Producer registration, extended producer responsibility, information for end users and the obligations of importers, distributors and authorised representatives.

FAQ

Questions about the EU Battery Regulation.

Does the EU Battery Regulation also apply to distributors?

Yes. Before selling, distributors must check that the battery bears the CE marking, the required documents are enclosed and the manufacturer is registered. Anyone selling batteries under their own name or brand generally takes on the obligations of a manufacturer.

From when does every battery need a QR code?

From 18 February 2027, all batteries must carry a QR code. For LMT, industrial (above 2 kWh) and electric vehicle batteries it leads to the digital battery passport, for all others to the required product information.

Where do I register as a producer in Germany?

In Germany, Stiftung EAR has been responsible for registration under the Battery Law Implementation Act (BattDG) since 18 August 2025. Registration is a prerequisite for offering batteries in Germany.

Who must comply with the due diligence obligations for raw materials?

Companies that place batteries on the market and have a net turnover of at least €40 million – alone or as part of a group. Following the postponement by Regulation (EU) 2025/1561, the obligations apply from 18 August 2027.

Do batteries already in stock need a passport?

What counts is when each individual unit is placed on the market. If a unit is first made available on the EU market before 18 February 2027, it does not need a passport. Units placed on the market from that day need one.