What Applies Before 2027 Under the Battery Regulation?

Before 2027, Regulation (EU) 2023/1542 already applies in part, with duties on conformity, labelling, separate collection, safety documentation, performance and durability documentation and extended producer responsibility applying on their own dates from 2024 onwards. The period before 2027 is therefore a period of live duties and preparation, not a waiting period before the Regulation starts. An operator who treats the period before 2027 as a grace period will miss duties that already apply, and will arrive at the passport milestone without the classification, data and identifier work that the passport requires.

Preparation before 2027 should be organised as a programme with its own evidence, not as informal work in advance of a deadline. Classification notes, supplier data templates, identifier allocation, carrier printing tests, access tier design and hosting arrangements can all be built and tested before the passport duty applies, using the Regulation text and the guidance available. A programme that builds those elements before 2027, and tests them on sample batteries, will place batteries in 2027 on a tested system. A programme that starts building in 2027 will place batteries on an untested system.

What duties apply in 2024 and 2025?

Duties applying in 2024 and 2025 include the general application of the Regulation from 18 February 2024, conformity assessment and CE marking duties from 18 August 2024, safety and performance documentation duties for rechargeable industrial, LMT and electric vehicle batteries, and the separate collection symbol from 18 August 2025. Producer registration, collection financing and reporting duties also apply in this period, under the national arrangements that implement the Regulation. Each duty has its own application date and evidence, and the pre 2027 file should show each duty separately, with the date it was met.

A pre 2027 duty map should list each duty, its application date, its evidence and its status, with the map dated. A map that lists only the 2027 milestone will hide the earlier duties, and an authority check in 2025 or 2026 would find the earlier duties unmet. A map with rule specific dates allows the operator to show, at any point before 2027, which duties apply and which have been met. The map should be reviewed after each new duty date passes, with the review dated.

What labelling applies before 2027?

Labelling before 2027 includes the separate collection symbol from 18 August 2025 and general label information, including manufacturer, category, chemistry and capacity presentation, from 18 August 2026. The QR code duty applies from 18 February 2027, so a label prepared in 2026 will lack the QR code, and a label prepared for 2027 must add it. Labelling versions should therefore be tied to placing dates, with a 2025 version, a 2026 version and a 2027 version, each with its own artwork, check and evidence. A single label design assumed to cover the whole period will be incomplete for at least one placing date.

Worked check: a battery placed in September 2026 carries the 2026 label version, with symbol and general information, but no QR code. The same model placed in March 2027 carries the 2027 version, with the QR code added. The labelling file shows both versions, with the placing dates that each version served. A file with only the 2027 version, applied retrospectively to the 2026 placing, would misstate the label that the 2026 battery carried. Version and placing date must stay linked.

What preparation should be completed before 2027?

Preparation before 2027 should complete classification for every model, supplier data collection for passport fields, identifier and carrier design, access tier design, hosting and registry interaction design, and testing on sample batteries. Classification comes first, because data, carbon and performance duties follow the category. Supplier data follow, because supplier collection takes the longest time. Identifier, carrier and access design follow, because they depend on the data structure. Testing follows design, using sample batteries and independent scans. Each step should be evidenced, with a dated sign off, so that the preparation programme can be audited before the milestone.

Preparation evidence should be filed as a programme file, separate from the placing file, with step evidence, open items and review dates. A programme file that states only that preparation is under way, without step evidence, cannot be audited. A programme file with step evidence and open items allows a delay in one step, such as a delegated act, to be managed without claiming that the whole programme is complete. The programme file should be reviewed monthly in the run up to the milestone, with the review dated.

How are batteries placed before 2027 treated after the milestone?

Batteries placed before 2027 are treated under the duties that applied at their placing date, and they do not acquire a passport duty by the arrival of the milestone date alone. Later events, such as repair, preparation for reuse, repurposing, remanufacturing or a new placing after a life stage change, can create a new placing question, and the new placing must be assessed under the duties that apply at the new placing date. A battery placed before 2027 that is later repurposed and placed again in a passport category will need passport treatment for the new placing, with linkage to the original history where required.

Life stage tracking should therefore record the original placing date and the original category, together with any later life stage event and any new placing date. A tracking file that records only the current holder, without the placing history, cannot answer the milestone question for a battery that has changed life stage. A file with placing history and life stage events allows the milestone to be judged for each placing, not only for the first placing.

What guidance was available before 2027?

Guidance available before 2027 includes Commission guidance on removability and replaceability, Joint Research Centre methodology work on carbon footprint and on performance and durability, and Commission battery pages and summaries that explain the Regulation structure. Guidance should be logged with its date, subject and effect on the duty map, and the duty map should be reviewed after each guidance publication. A guidance log that lists titles without effects does not support planning, while a log that states the effect on each duty does. The log should be dated as checked on 28 October 2026 as the baseline for the run up to the milestone.

Guidance watching before 2027 should be assigned to a named role, with a review calendar tied to Commission publication cycles. A watching duty assigned to no one will miss a publication that affects a duty. The calendar should include the next expected guidance or delegated act publication, with a review date set for that publication. The calendar is part of the preparation file, not a separate administrative note.

What should not be assumed before 2027?

What should not be assumed before 2027 is that every passport detail is settled, that every delegated act will be adopted on the expected date, or that a battery placed before 2027 will never need a passport. Passport detail that depends on delegated or implementing acts remains open, delegated act dates are expected dates, and life stage changes can create new placing duties. As checked on 28 October 2026, preparation should proceed on settled fields, hold open work on fields that an act will define, and track life stage events for later placing questions. This guide gives general educational information only and is not individual legal advice. A reader with a specific battery or market decision should check the current Regulation text and any applicable delegated act, as checked on 28 October 2026, before acting.

This guide gives general educational information only and is not individual legal advice. A reader with a specific battery or market decision should check the current Regulation text and any applicable delegated act, as checked on 28 October 2026, before acting. The period before 2027 is a period of live duties and tested preparation, not a waiting period.