The New EU Battery Regulation -Labelling Requirements and Timetable

In July 2023, the European Union issued the new Battery Regulation (EU) 2023/1542, replacing the outdated 2006/66/EC directive. It establishes unified safety, sustainability and transparency standards for all batteries sold in the EU, with standardized labelling rules as a key mandatory provision. The new labelling framework eliminates inconsistent regional marking practices, boosts environmental awareness among consumers, and enables full lifecycle traceability of batteries. It adopts a dual regulatory model covering universal labelling standards for all batteries and differentiated special requirements for high-capacity, high-risk battery products, driving the standardized and green development of the EU battery industry.

General Unified Labelling Requirements for All Batteries

All batteries marketed in the EU must comply with unified labelling specifications fully effective from February 18, 2027. To ensure consistent information transparency and environmental compliance, all labels on battery surfaces or packaging must be permanent, legible and non-erasable, regardless of battery type, capacity and application.

First, complete basic identification information is mandatory. Labels must clearly display the manufacturer’s name, address and unique product batch or serial number. For imported batteries, importer information is also required to clarify regulatory accountability. Core product parameters including battery type, rated capacity and weight must be marked for quick product identification.

Second, unified environmental and hazardous substance marking is enforced. All batteries must bear the standard separate collection symbol, indicating prohibited domestic waste disposal and mandatory separate recycling. All batteries containing more than 0,002 % cadmium or more than 0,004 % lead, shall be marked with the chemical symbol for the metal concerned: Cd or Pb. The relevant chemical symbol indicating the heavy metal content shall be printed beneath the separate collection symbol and shall cover an area of at least one-quarter the size of that symbol.

The separate collection symbol shall cover at least 3 % of the area of the largest side of the battery up to a maximum size of 5 × 5 cm.

In the case of cylindrical battery cells, the separate collection symbol shall cover at least 1,5 % of the surface area of the battery and shall have a maximum size of 5 × 5 cm

Where the size of the battery is such that the separate collection symbol would be smaller than 0,47 × 0,47 cm, the battery does not need to be marked with that symbol. Instead, a separate collection symbol measuring at least 1 × 1 cm shall be printed on the packaging

Third, universal digital traceability is required. From February 18, 2027, all batteries must be printed with a unified QR code linked to the official EU electronic system. The system integrates product compliance documents, safety guidelines, waste management instructions and lifecycle data, realizing unified digital traceability for all battery products across the EU market.

Special Labelling Requirements for Specific Battery Categories

Based on the universal standards, the regulation stipulates exclusive labelling rules for high-impact batteries, including electric vehicle (EV) batteries, light means of transport (LMT) batteries and industrial batteries above 2 kWh. Targeting their complex applications and prominent environmental footprints, these special requirements focus on carbon footprint disclosure, durability parameter marking and in-depth digital lifecycle management.

The core special rule is mandatory carbon footprint grading labelling for eligible high-capacity batteries. Manufacturers must mark official carbon footprint levels calculated based on full-production greenhouse gas emissions. The EU will dynamically adjust grading thresholds to tighten low-carbon standards, enabling downstream users and consumers to intuitively assess battery environmental performance and driving industrial low-carbon upgrading.

Additionally, specific batteries require detailed performance and durability labelling. EV, LMT and stationary energy storage batteries must be marked with service life and cycle performance data to reflect actual durability. A clear “non-rechargeable” warning is mandatory for primary batteries to avoid misuse and potential safety hazards.

A key special provision is the digital battery passport, officially implemented in May 2026 for all batteries above 2 kWh. Serving as a unique digital identity, the passport records full-lifecycle data including raw material sources, supply chain ESG performance, production and operation status, and recyclable component ratios. Unlike the basic universal QR code, it supports in-depth supply chain traceability and facilitates battery recycling and secondary utilization.

Portable household batteries also have supplementary special rules. They must be labelled with clear disassembly prompts to support consumer self-removal and replacement, reducing electronic waste caused by discarding entire devices due to battery failure.

Significance and Implementation Impact of the New Labelling Rules

The dual labelling system of universal standards and category-specific special rules builds a complete battery information disclosure mechanism for the EU. Unified rules standardize market labelling, eliminate market confusion and cut cross-border corporate compliance costs. Targeted special requirements for high-capacity batteries effectively regulate industrial carbon emissions and improve supply chain sustainability.

For EU-exporting battery manufacturers, the new rules raise refined compliance thresholds, requiring optimized labelling design, improved carbon accounting capacity and timely battery passport registration. For consumers and regulators, transparent and standardized labelling enables effective market supervision, standardized battery recycling, and solidly supports the EU’s circular economy and carbon neutrality goals.

Timetable for Labelling under EU Battery Regulation (EU 2023/1542)

1. Separate Collection Symbol (Waste Bin Marking)

• Effective Date: 18 August 2025
• Requirements: All batteries must be marked with the separate collection symbol. Additional markings Cd or Pb are mandatory if cadmium content exceeds 0.002% or lead content exceeds 0.004%.

Symbol for separate collection of batteries

2. Harmonized Labelling (10 core information items)

• Effective Date: 18 August 2026 (or 18 months after the entry into force of implementing acts, whichever is later)
• Mandatory label information: manufacturer details, battery type, chemical composition, hazardous substances, critical raw materials, capacity, production date, batch number, CE marking and recycling symbol.
• Synchronized capacity marking rules:
  • Rechargeable portable batteries, light means of transport (LMT) batteries and starting, lighting and ignition (SLI) batteries: shall be marked with capacity.
  • Non-rechargeable portable batteries: shall be marked with minimum average discharge duration and the statement "non-rechargeable".

3. QR Code & Digital Battery Passport

• Effective Date: 18 February 2027
• Requirements: All batteries shall be affixed with a QR code linking to compliance information, digital battery passport (applicable to EV batteries, LMT batteries and industrial batteries above 2 kWh) and recycling guidelines.
• The QR code shall be in high contrast to the background colour and of a size that is easily readable by a commonly available QR reader, such as those integrated in hand-held communication devices.