What is changing in the battery regulation this year?
The digital passport requirement for batteries comes into force on 18 February 2027, and that is usually what batpas.eu is about. But the battery regulation (Regulation (EU) 2023/1542) consists of more than just the passport, and part of the obligations it contains will come into force earlier than that date. For companies placing EV batteries or industrial batteries above 2 kWh on the market, things may already change this year, even though the best-known deadline is still ahead of you.
This involves, in particular, obligations that are not linked to the QR code and the passport, but to separate parts of the regulation: including reporting on the carbon footprint of certain batteries, and due diligence requirements for the sourcing of raw materials that already applied earlier to larger market participants. Those supplying only light transport vehicles, with LMT batteries in e-bikes or scooters, are generally not first affected by these specific obligations; that group will mainly have to deal with the passport requirement in 2027.
Why the regulation is being phased in
The battery regulation did not come into force all at once. The legislator chose a phased implementation, whereby obligations requiring more preparation, such as setting up a complete digital passport with QR data carrier, become mandatory later than obligations that can be combined with existing business processes, such as reporting or a due diligence policy. How we track for each subject which obligation comes into force at which moment, and where that information comes from, you can read on the page where we explain how we compile our information.
For your company, this means that the question of whether the regulation applies to you cannot be answered just once, but must be asked again for each obligation. For example, a company may not yet have to do anything about the passport, but may already fall under a reporting obligation, or vice versa.
What the carbon footprint declaration involves
For certain categories of batteries, in particular EV batteries and rechargeable industrial batteries above 2 kWh, the regulation provides for an obligation to calculate and declare the carbon footprint per battery model and manufacturing location, according to a method established by the European Commission. The exact moment when this obligation applies to your category, and the precise content of the calculation method, is set out in the official text of the regulation; we deliberately do not mention a year here, because the implementing rules are still being supplemented in parts.
For those who do not manufacture batteries themselves but do purchase or resell them, the practical consequence is mainly that suppliers may ask for this data, or that you must be able to pass it on to your own customers. This is a good time to discuss with your supplier who records and provides which data, and how it will later connect to the digital passport.
What this does not automatically mean for you
The fact that an obligation applies this year does not mean that every company in the chain will immediately have to deal with it. The regulation makes a distinction between roles: manufacturer, importer, distributor and so-called 'fulfillers' do not all have the same obligations at every moment. An office manager who uses batteries only internally in business assets is in a different position than an importer who places batteries on the EU market. Which role applies to your company, and which obligations belong to that role at which time, is something you can see in a few questions whether this applies to your situation.
How to keep track this year of what is changing
Because the regulation comes into effect in phases, the risk is not that you miss one large deadline, but that you overlook a smaller, earlier obligation because all attention goes to 2027. A fixed place to check per topic what applies and when helps with this more than reading the entire text once a year. In the knowledge base you will find that worked out per situation, always with the source in the official text included.
Other entrepreneurs asked us similar questions about the timing of the regulation; part of these are collected on the page with frequently asked questions. For the exact dates and the precise scope of a specific obligation for your business, the official text of the regulation, or a conversation with a lawyer or the competent supervisory authority, remains the appropriate route.
Would you first like to get an impression of where your business stands, without needing an account for that right away? Do the free quick-scan, or read through the topics at your leisure to see which changes might already be relevant for your situation this year.