EU Batteries Regulation for sellers: registration, labels and the 2027 deadlines
The Batteries Regulation, Regulation (EU) 2023/1542, replaced the old Batteries Directive with one set of rules that applies directly in every EU country. Its obligations start in stages between 2024 and the 2030s. For most sellers, three things matter now, and two more arrive in 2027.
Who is the producer
You are the producer of a battery in a country if you are the first to make it available there — including batteries inside appliances, light means of transport and other products. Sellers based in another country who sell directly to end users by distance contract count as producers in each country they sell to.
1. Register in each country (since 18 August 2025)
Producers must register in the producer register of each EU country where they first make batteries available, before selling. Sellers established in another country who sell by distance must appoint an authorised representative for extended producer responsibility in each of those countries, by written mandate. In Germany the register is run by stiftung ear.
Registration comes with take-back and financing duties, usually met by joining a producer responsibility organisation, and with regular reporting of quantities. Marketplaces ask for the registration numbers.
2. Mark batteries with the collection symbol (since 18 August 2025)
All batteries must carry the crossed-out wheelie bin symbol for separate collection. If a battery contains more than the threshold amounts of cadmium or lead, add the chemical symbol Cd or Pb under the bin. Small batteries can carry the symbol on the packaging instead.
3. CE marking and technical documentation
Batteries covered by the regulation need a conformity assessment, an EU declaration of conformity and the CE mark. Keep the technical documentation available for the authorities.
Coming in 2027
- QR codes (18 February 2027): every battery must carry a QR code that links to information about it.
- Removable portable batteries (18 February 2027): products with portable batteries must be designed so that end users can remove and replace them, with limited exceptions.
- Battery passport (18 February 2027): a digital record for light means of transport batteries, electric vehicle batteries and industrial batteries over 2 kWh.
- Due diligence (18 August 2027): larger companies must check the supply chain for the raw materials in their batteries. The date was postponed from 2025 by Regulation (EU) 2025/1561.
The detailed label requirements (capacity, chemistry and other information) apply from 18 August 2026 or 18 months after the Commission adopts the label specifications, whichever is later. Check the current status before you print new packaging.
Checklist
- List the countries you sell to, and every product that contains a battery.
- Register as a battery producer in each country; appoint an authorised representative where you sell from abroad.
- Join a take-back scheme and report quantities.
- Mark batteries with the crossed-out bin (and Cd / Pb where relevant).
- Plan for QR codes and user-replaceable batteries before February 2027.
Run the free compliance check to see the other rules for your product, or find a provider for registrations in several countries.
Frequently asked questions
Does it apply if the battery is built into my product?
Yes. Batteries incorporated in appliances, vehicles and other products are covered. If you sell a device with a battery, you are usually the producer of that battery too.
Do I need a battery passport for a phone power bank?
No. The battery passport applies to light means of transport batteries (e-bikes, e-scooters), electric vehicle batteries and industrial batteries over 2 kWh. Portable batteries need the QR code and labels instead.
Sources
- Regulation (EU) 2023/1542 concerning batteries and waste batteries
- Regulation (EU) 2025/1561 postponing battery due diligence obligations
- stiftung ear (Germany)
ohdock provides software tools and general information, not legal advice. Check the official texts, or ask a qualified adviser, for your situation.