What Is the Portable Battery Timeline, and What Is Not Yet Required?

The portable passport timeline is a timeline of duties that apply without a passport, and the key point is to avoid treating 18 February 2027 as a portable passport date. Portable batteries carry labelling, QR code, removability, collection and performance duties on their own dates, and none of those duties creates a passport for a portable battery. The timeline in this guide therefore lists the portable duties in date order, marks the passport date as not applicable to portable batteries, and shows what is not yet required in the portable category.

Timeline discipline for portable batteries prevents two planning errors. The first error is late preparation for a labelling or removability duty, because the team waited for the passport date. The second error is wasted preparation for a portable passport, because the team assumed that every battery would need one. Both errors follow from reading the Regulation timetable as a single date, rather than as a set of duty specific dates. The portable timeline should be drawn duty by duty, with the passport line marked not applicable.

What is not required for portable batteries on 18 February 2027?

A battery passport is not required for portable batteries on 18 February 2027, or on any later date set in the Regulation as it stands as checked on 28 October 2026. The passport duty in Article 77 applies to LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries placed on the market or put into service from that date. A portable battery placed on the market on or after that date needs the QR code and the label set that apply on that date, but it does not need a passport, and a passport claim for a portable battery should not be made.

A planning document that lists a passport milestone for portable batteries should be corrected to list the QR code and labelling milestones for the same date, with the passport line marked not applicable and the category test cited. A document that retains the passport milestone will generate work, cost and record confusion, and it will mislead a later reader about the category. The correction should be dated and filed, so that the earlier error does not reappear in a later plan.

What portable duties apply before 2027?

Before 2027, portable duties on separate collection, labelling, safety documentation and conformity assessment already apply on their own dates. The separate collection symbol applies from 18 August 2025, and general label information applies from 18 August 2026. Performance and durability documentation, technical documentation and conformity assessment duties apply on the timetables set in the Regulation from 2024 onwards. A portable programme that starts in 2027 will therefore miss duties that already applied, and the programme should be backdated in its evidence file to show when each duty was met.

Worked check: a portable model placed on the market in late 2026 is checked against the symbol and label duties that apply on that date, not against the 2027 QR duty. The same model placed on the market in March 2027 is checked against the QR duty as well. The placing date decides which duties in the sequence apply, and the file should show the placing date and the duty set for that date. A file that applies the 2027 set to a 2026 placing, or the 2026 set to a 2027 placing, misstates the duty set.

What applies on 18 February 2027 for portable batteries?

On 18 February 2027, portable batteries within scope must be marked with a QR code, portable batteries incorporated in appliances must be removable and replaceable by the end user under Article 11, subject to derogations, and the label set applicable on that date must be complete. The QR code provides access to the Article 13 information for the battery, not to a passport. The removability duty is a design duty for incorporated batteries, and it must be evidenced by design and test records, not by a passport record.

A 2027 readiness check for portable batteries should list the QR carrier, the label set, the removability evidence and the collection arrangements as separate lines, each with a status. A readiness statement that covers only the QR code, without removability evidence, is incomplete for incorporated batteries. A readiness statement that covers only removability, without the QR check, is incomplete for standalone batteries. The combined check is the readiness evidence for the date.

What portable duties apply after 2027?

After 2027, portable duties continue on performance and durability values, collection objectives and recycling targets, together with the Commission review on phasing out non-rechargeable general purpose batteries by 31 December 2030. General purpose portable batteries, excluding button cells, must meet performance and durability values from 18 August 2028. Collection objectives rise to 73 percent by the end of 2030. Recycling efficiency and material recovery targets rise in steps to the end of 2031. Each later duty has its own date and its own evidence, and the timeline should be extended duty by duty rather than closed at 2027.

Later duty planning should be labelled expected where the duty depends on a delegated act, and fixed where the Regulation sets the date and the value. Performance values depend in part on delegated acts for methods and values, while collection objectives and recycling targets are set in the Regulation text. A plan that treats every later date as fixed overstates certainty for the delegated act duties, and a plan that treats every later date as expected understates the fixed targets. The label for each date should state the basis.

What guidance should be watched for portable batteries?

Guidance to watch for portable batteries includes Commission guidance on removability and replaceability, guidance on labelling and QR presentation, Joint Research Centre work on performance and durability, and Commission reporting and recycling guidance. Each guidance publication should be logged with its date, subject and effect on the portable duty map, and the duty map should be reviewed after each publication. A guidance log that lists titles without effects does not support planning, while a log that states the effect on each duty does.

Guidance watching should be assigned to a named role, with a review calendar tied to Commission publication cycles. A watching duty assigned to no one, or to a general inbox, will miss a publication that affects a duty. The review calendar should include a check as checked on 28 October 2026 as the baseline, with the next review date set for the next expected guidance or delegated act publication. The calendar is part of the timeline file, not a separate administrative note.

How should a portable timeline be presented to avoid misconceptions?

A portable timeline should be presented as a duty table, with the passport line marked not applicable, the QR line marked applicable, and each duty line carrying its date, its basis and its evidence reference. The presentation should avoid a single timeline graphic that implies a single deadline, and it should avoid language that suggests a portable passport is expected. As checked on 28 October 2026, no portable passport duty is set in the Regulation, and a timeline that suggests otherwise should be corrected. 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 portable timeline is a duty table, not a single deadline, and the passport line should stay marked not applicable.