Specialist Timeline for Battery Passport Duties

The specialist timeline is the timeline of Regulation (EU) 2023/1542, read with the specialist scope checks that need to happen at each stage, rather than a separate timeline for specialist batteries. The Regulation applies from 18 February 2024, with individual provisions phased in on their own dates, and the battery passport duty in Article 77 applies from 18 February 2027 for electric vehicle batteries, light means of transport batteries and industrial batteries over 2 kWh placed on the market or put into service from that date. A specialist operator who works only from the 2027 date will miss the earlier duties, and an operator who works only from the earlier duties will miss the passport preparation that the 2027 date requires.

The scope is the phased application of the Regulation, as summarised on EUR-Lex, for specialist batteries inside the Regulation. Dates for other provisions are labelled as expected where the Regulation summaries describe them as phased or dependent on further acts, and the fixed passport date is stated as fixed. The position is stated as checked on 28 October 2026.

When did the Regulation start to apply?

The Regulation entered into force in August 2023 and has applied since 18 February 2024, with the exception of certain specified provisions that apply on later dates, as the EUR-Lex summary records. The general application date matters for specialist operators because labelling, information, conformity and producer responsibility duties phase in around it, and a specialist battery placed on the market after that date carries duties that a battery placed before it may not carry in the same form. A specialist operator should record the placing date for each battery, because the placing date decides which phased duties apply, and a file without placing dates cannot answer a timeline question. The application date is a fact about the Regulation, not a deadline that an operator can choose.

What is the fixed passport date?

The fixed passport date is 18 February 2027, from which each light means of transport battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market or put into service must have a battery passport under Article 77. The date is fixed in the Regulation text, and the duty turns on placing on the market or putting into service from that date, not on manufacture date alone. A specialist battery placed on the market before that date falls outside the fixed duty, while a specialist battery placed from that date falls inside it, subject to category and scope. The date should be treated as a placing test, with the placing date recorded for each battery.

What other dates affect specialist batteries?

Other dates that affect specialist batteries include the labelling dates in Article 13, the carbon footprint and recycled content dates in Articles 7 and 8, and the due diligence dates in the due diligence chapter, each of which phases in on its own timetable and may depend on delegated or implementing acts. The due diligence chapter, for example, was originally set for an earlier date and was later delayed, as the European Parliament amendment text records, which shows why a timeline should be checked against the current Regulation text rather than against an old summary. This guide does not state a complete list of phased dates, because the list needs the current consolidated text, and a reader should build the list from that text for the categories relevant to the specialist batteries in question.

What does a specialist timeline table look like?

A timeline table separates the fixed date from the phased dates, so that a fixed duty is not treated as expected and an expected date is not treated as fixed. The table below uses the dates that the Regulation summaries state with confidence, and labels the rest as phased.

When should specialist scope checks happen?

Specialist scope checks should happen at design, at first placing, at any change of equipment or application, and at any second life move, because scope status can change when the equipment or the application changes, even though the battery itself is unchanged. A battery that was inside scope for its first application may raise a scope question in a new application, and a battery that was outside scope for one equipment type may fall inside scope for another. The scope check is therefore a recurring check, not a one off check at first placing, and each check should be recorded with the date, the wording read and the facts relied on. A scope file that contains only the first check is incomplete for a battery with a long and varied life.

How should a specialist operator prepare for 18 February 2027?

Preparation for 18 February 2027 should cover scope and category decisions, identifier and data carrier arrangements, Annex XIII data collection, access tier arrangements, record system testing and operator role mapping, in that order, with each element tested on a pilot record before the duty date. The preparation is described in detail in the implementation cluster, and the specialist version adds the scope checks and the placement checks for specialist batteries. An operator who leaves preparation until the duty date will face a record system, a data collection and a scope question at the same time, while an operator who prepares in sequence will face each question once, with time to resolve it. The sequence is the preparation method, and the pilot record is the test that the sequence worked.

What limits apply to timeline readings?

The limits are that phased dates depend on the current consolidated text and on further acts, and this guide does not state them as fixed. This guide gives general educational information only and is not individual legal advice. An operator with a specific battery should check the Regulation text as checked on 28 October 2026 before acting.