On August 18, 2026, the labelling requirements of the EU Battery Regulation (Regulation (EU) 2023/1542) take effect. Every battery placed on the EU market will need to carry defined information covering category, chemistry, capacity, and hazardous substances, along with a QR code. For directors of product compliance, engineering leads, and sustainability teams at EV, industrial, energy storage, and light means of transport (LMT) manufacturers, 2026 is the technical preparation year that determines whether the February 2027 battery passport is a configuration exercise or a scramble.

This guide explains exactly what applies on the date, what remains conditional on pending EU secondary legislation, and how to structure battery data now so the passport is an extension of existing infrastructure rather than a separate project.

📌 Book a compliance risk assessment to map your battery labelling and passport readiness before the August 2026 date.

Key Takeaways

📌 EU Battery Regulation labelling requirements apply from August 18, 2026, or 18 months after the labelling-format implementing act enters into force, whichever is later.

📄 Labels must show battery category, chemistry, capacity, hazardous substances, and a separate-collection symbol under Annex VI Part A, plus a QR code under Article 13.

⏳ The Digital Battery Passport applies from February 18, 2027 for LMT, industrial batteries above 2 kWh, and EV batteries under Article 77.

⚠️ The carbon footprint declaration is phased and deferred. Its application slides with the methodology delegated act and format implementing act, which have not entered into force.

🔗 Supply chain due diligence was postponed to August 18, 2027 by Regulation (EU) 2025/1561, currently applying to operators above €40M net turnover.

🤖 Battery passport data infrastructure takes 12 to 18 months to build. Spreadsheet-based tracking does not survive audit at scale.

What Changes on August 18, 2026

The core change is labelling and marking. From this date, batteries placed on the EU market must carry the information set out in Annex VI Part A, and a QR code as required under Article 13. This is a content and format obligation, distinct from the carbon footprint performance class label, which follows its own deferred timeline.

One caveat matters for legal accuracy. Under Article 13(10), the labelling requirements apply from August 18, 2026, or 18 months after the entry into force of the implementing act defining harmonised label formats, whichever is later. The European Commission opened a consultation on harmonised labelling specifications in early 2026. Confirm the current status of that implementing act with the European Commission before finalising label artwork, because the format specification can move the applicable date.

For most manufacturers, the practical response is the same either way. The underlying data needed for the label must be assembled now, and that data sits across material and environmental compliance records, supplier declarations, and bill of materials structures.

The Five Battery Categories in Scope

Regulation (EU) 2023/1542 applies across five battery categories, each with different downstream obligations.

• Portable batteries used in consumer electronics and appliances

• LMT batteries for e-bikes, e-scooters, and similar vehicles

• Automotive (SLI) batteries for starting, lighting, and ignition

• Industrial batteries, including energy storage above 2 kWh

• Electric vehicle (EV) batteries for traction

The labelling requirements apply broadly across categories, while the battery passport, carbon footprint, and due diligence obligations concentrate on LMT, industrial batteries above 2 kWh, and EV batteries. Manufacturers in the energy and infrastructure and automotive sectors carry the heaviest cumulative load because their products fall into the higher-obligation categories.

Label Content Requirements Under Annex VI

Annex VI Part A defines what a compliant label must communicate. The information includes manufacturer identification, battery category, chemistry, capacity, hazardous substances present beyond mercury, cadmium, and lead, and the separate-collection symbol. Where thresholds are met, the label must also indicate cadmium and lead content.

This is not a cosmetic change. Capacity and chemistry values must be accurate and traceable to the underlying cell and pack specifications, and hazardous substance information depends on complete material disclosure from suppliers. Managing this at the part level is a BOM substance and threshold management problem, and it connects directly to obligations you already track under REACH and RoHS. A manufacturer that already maintains substance-level data for those frameworks has a head start on the battery label.

EU Battery Regulation label content requirements for chemistry capacity and hazardous substances

Click on image to view full

The QR Code and the On-Ramp to the 2027 Passport

From August 18, 2026, batteries must carry a QR code under Article 13. For LMT, industrial batteries above 2 kWh, and EV batteries, that QR code becomes the access point to the Digital Battery Passport from February 18, 2027 under Article 77.

The sequence matters for planning. The QR code arrives first, and the passport data it points to arrives later. Manufacturers that treat these as two projects will build the QR code in 2026 and then rebuild the data layer in 2027. A better approach is to treat the 2026 labelling and QR work as the first configuration of the same digital passport and traceability system that the 2027 passport will formalise. Our analysis of why the Digital Product Passport is becoming the backbone of compliance explains this convergence in more detail.

Carbon Footprint: Phased and Conditional

The carbon footprint declaration is where most public summaries are inaccurate, and where compliance teams should be careful. Article 7 sets nominal dates, February 18, 2025 for EV batteries and February 18, 2026 for industrial batteries above 2 kWh, but each applies "whichever is later" of that date or 12 to 18 months after the methodology delegated act and the declaration-format implementing act enter into force.

Those secondary acts have not entered into force. The EV methodology was published as a draft for consultation in 2024 and has not been finalised into an applicable obligation. Based on currently available regulatory guidance, the practical effect is that the carbon footprint declaration obligation is deferred beyond its nominal date, and the applicable date will move with the acts. Do not assume the declaration is live. Monitor EUR-Lex and the Commission's batteries pages, and build the data capability now so that whenever the methodology finalises, the declaration is a reporting step rather than a data-gathering project. This is where carbon and sustainability compliance data needs to connect to the same BOM used for labelling.

Supply Chain Due Diligence: Postponed to 2027

Battery supply chain due diligence was postponed by two years, from August 18, 2025 to August 18, 2027, through Regulation (EU) 2025/1561 under the Omnibus IV simplification package. The obligations cover responsible sourcing of cobalt, natural graphite, lithium, and nickel, and apply to operators above €40M net turnover, though a separate proposal to raise that floor to €150M for small mid-caps remains under discussion and is not adopted.

The postponement is preparation time, not relief. Third-party verification by a notified body must be operational before August 2027, and Commission guidelines are expected by July 26, 2026. Because the same four minerals sit at the centre of both this regime and broader supply chain due diligence under the CSDDD and conflict minerals programs, manufacturers benefit from consolidating supplier data collection and risk scoring into one workflow rather than running parallel campaigns. Our conflict minerals compliance guide covers the mineral-level due diligence mechanics that apply here.

Penalties and Market Exclusion Risk

Under Article 93, member states set penalties that must be effective, proportionate, and dissuasive. In practice, the more consequential exposure is commercial: non-compliant batteries can be restricted, withdrawn, or recalled by market surveillance authorities, and a battery without a valid label, QR code, or, from 2027, passport can be blocked from the EU market.

For a manufacturer with a battery embedded in a finished product, market exclusion of the battery means exclusion of the product. This is why labelling accuracy is a market-access question, not a documentation formality, and why audit-ready documentation across the product line reduces both surprise findings and response time. No system makes a portfolio audit-proof. The objective is to be audit-ready, so that when a customer, notified body, or market surveillance authority asks, the evidence is retrievable at the point in time it was declared.

Affected Industries and Operational Impact

🏭 Automotive and EV: EV traction packs carry the full stack of labelling, QR, passport, carbon footprint, and due diligence obligations.

🏭 Energy storage: Industrial batteries above 2 kWh face passport and, once finalised, carbon footprint requirements.

🏭 Electronics and appliances: Portable batteries embedded in products trigger labelling obligations that flow to electronics manufacturers and their retail customers.

🏭 LMT: E-bike and e-scooter batteries face labelling now and passport obligations from 2027.

The common operational thread is data. Capacity, chemistry, hazardous substances, mineral origin, and carbon data all trace back to suppliers and the BOM. Manufacturers that lack multi-tier supply chain visibility will struggle to populate a compliant label, let alone a passport.

Why 2026 Is the Technical Preparation Year

Battery passport data infrastructure takes 12 to 18 months to build because it requires structured, verifiable data from suppliers who often sit three or four tiers deep. Spreadsheet-based tracking fails at this scale, both because it cannot maintain point-in-time evidence and because it cannot feed a machine-readable passport.

The strategic move is to build the centralized compliance data backbone in 2026, using the labelling requirement as the forcing function, so that the 2027 passport is a data export rather than a new build. This reframes compliance from reactive filing to continuous compliance monitoring and audit readiness.

Battery compliance data workflow linking 2026 labelling to the 2027 EU battery passport

Click on image to view full

Compliance Preparation Checklist

✅ Confirm which of the five categories your products fall into and map obligations to each.
✅ Assemble Annex VI Part A label data: category, chemistry, capacity, hazardous substances, collection symbol.
✅ Verify the current status of the harmonised labelling-format implementing act before finalising artwork.
✅ Implement the Article 13 QR code and design it as the access point for the 2027 passport.
✅ Build the passport data layer now, linking supplier data to the BOM.
✅ Start due diligence supplier engagement for cobalt, graphite, lithium, and nickel ahead of August 2027.
✅ Establish point-in-time evidence retrieval for customer and regulatory audits.
✅ Track carbon footprint methodology developments and stage the data capability.

How AI Supports Battery Compliance

Manual battery compliance does not scale across five categories, multiple deadlines, and multi-tier suppliers. AI-native compliance automation addresses the structural problem.

Certivo functions as the system of record for battery compliance. CORA-powered regulatory intelligence monitors the moving delegated and implementing acts and maps changes to affected products, so a shift in the carbon footprint or labelling-format act reaches the compliance team as an alert rather than a surprise. CORA-driven document parsing extracts and validates data from supplier declarations and certificates, and links it to the BOM so that a label or passport reflects verified, product-level data.

The result is continuous audit-ready documentation with time-stamped declarations, a clear evidence chain of who submitted what and when, and point-in-time retrieval for internal, customer, and market surveillance audits. For battery makers, this is the difference between a 2027 passport that configures in weeks and one that consumes a year.

Before publishing labels or building your passport, request a compliance review to confirm your battery data is structured, verifiable, and ready for the August 2026 and February 2027 deadlines.