EU Battery Regulation Requirements: Substances, Carbon Footprint, Recycled Content, Performance, Safety, Removability, Labels and State of Health

Chapter II is headed "Sustainability and safety requirements" (Articles 6 to 12), and Chapter III "Labelling, marking and information requirements" (Articles 13 and 14).

Removability (Article 11) sits in Chapter II but binds whoever places products incorporating batteries on the market. Both belong to the EU Battery Regulation, in force since 17 August 2023 and applicable since 18 February 2024.

As of 13 November 2026, five requirements apply in part or in full, while the carbon footprint declaration and the general labels still wait for Commission acts. The sections below give the requirements matrix, a category table, the dated status of each secondary act, the proof route and the duty holder.

Which Product Requirements Article 5 Sets for Placing a Battery on the Market

Under Article 5(1) of Regulation (EU) 2023/1542, a battery may only be placed on the market or put into service if it meets Articles 6 to 10, Article 12 and Chapter III, and Article 5(2) adds that, for any aspect those chapters do not cover, it must not present a risk to human health, the safety of persons, property or the environment.

Article 11, on removability, is missing from the Article 5(1) list because it addresses the products that incorporate batteries, not the battery itself. The same articles, 6 to 10, 12, 13 and 14, set the content of the EU declaration of conformity under Article 18(1) of the consolidated text on EUR-Lex.

For Chapter II only, a battery that falls into more than one category follows the category with the strictest requirements (Article 1(3), second subparagraph). How the Regulation sorts each battery into the five battery categories decides which rows below apply.

The Eight Requirement Guides: Article, Categories, Dates and Secondary Act Status

Eight guides cover the product requirements one by one, and each row below gives the article, the battery categories, the date from which the requirement applies and the status of the secondary act it depends on as of 13 November 2026.

Three kinds of date appear in the table: a fixed past date, a fixed future date, and a fixed date "or" a period after a secondary act enters into force, "whichever is the latest".

A requirement of the third kind does not apply while its act is not adopted, because the later of the two dates does not yet exist.

Table 1: Product requirements of Regulation (EU) 2023/1542, status as of 13 November 2026.

Need help meeting the battery product requirements? Where the product requirements sit among the other duties is set out under how to comply with the EU Battery Regulation.

Which Requirements Apply to Each Battery Category

Each of the five battery categories carries a different set of product requirements: substance restrictions and labelling cover every category, while carbon footprint, recycled content, performance documentation and state-of-health data apply only to the categories named in Articles 7, 8, 10 and 14.

Industrial batteries count for Articles 7, 8 and 10 only with a capacity greater than 2 kWh. Article 12 and the Article 14 duty for industrial batteries concern stationary battery energy storage systems, whatever their capacity. Removability covers portable batteries in products and LMT batteries only (Article 11(1) and (5)).

Table 2: Articles 6 to 14 by category; every category is also labelled under Article 13 (dates in Table 1).

Requirements in Force, Fixed Future Dates and Dates Waiting for Secondary Acts

As of 13 November 2026, five product requirements apply in part or in full, three have fixed future dates, and four depend in part on secondary acts that the Commission has not yet adopted. Labelling, performance and recycled content each combine dates of more than one kind.

Substance restrictions have applied since 18 February 2024, lead in portable batteries since 18 August 2024 and the vehicle lines added to Annex I by Regulation (EU) 2026/1738 since 13 August 2026. Each of these dates, in order, is on the EU Battery Regulation timeline.

The Article 10(1) performance document, the Article 14(1) state-of-health data and the Article 12(2) safety documentation have applied since 18 August 2024. The separate collection symbol has been required on every battery since 18 August 2025 (Article 13(4)), so labelling already applies in part.

Three requirements have fixed future dates. Removability applies from 18 February 2027 (Article 96(2), point (a)), the QR code is required on every battery from the same day (Article 13(6)), and the minimum recycled content shares apply from 18 August 2031 and 18 August 2036 (Article 8(2) and (3)).

Four requirements depend in part on a secondary act: the Article 7 declarations, the Article 8(1) documentation, the minimum values of Articles 9, 10(2) and 10(3), and the Article 13(1) to (3) labels. No carbon footprint stage applies and those labels are not yet mandatory, because their acts are not adopted.

Secondary Acts Adopted and Drafts Pending as of 13 November 2026

Three acts adopted under the Regulation are in force as of 13 November 2026: Delegated Regulation (EU) 2026/1770 on the Article 11(2) derogations, the only one that changes a product requirement, Delegated Regulation (EU) 2025/606 on recycling efficiency and Implementing Regulation (EU) 2025/2289 on reporting. Implementing Decision (EU) 2026/2048, which cites EN 18060:2025, rests on Regulation (EU) No 1025/2012.

Five drafts had not been adopted as of 13 November 2026: the carbon footprint methodology for electric vehicle batteries (Ares(2024)3131389), the declaration format (Ares(2024)3131449), the labelling implementing act (Ares(2025)11169592), the recycled content method (Ares(2026)7823470) and the industrial performance values (Ares(2026)9188325). Every act with its stage is listed under Battery Regulation delegated and implementing acts.

Four statutory deadlines have passed without adoption: 18 February 2024 (electric vehicle carbon footprint methodology), 18 August 2025 (labelling), 18 February 2026 (industrial performance values) and 18 August 2026 (recycled content method). The Article 9 act for portable batteries of general use is due by 18 August 2027 (Article 9(2)).

Pending Proposals That Would Change the Requirements

The Commission proposal COM(2025) 981 (procedure 2025/0397(COD)) would change two product requirements but is pending: as of 13 November 2026 the European Parliament's ENVI committee is at the stage "Awaiting committee decision", with an indicative plenary on 14 December 2026 (OEIL). The proposal does not amend Articles 7, 8 or 13.

It would make LMT batteries replaceable at module level under Article 11(5) and add substances of very high concern at 0.1 % weight by weight or more to the label (Annex VI, Part A, point 8). Until an amending act is published, both provisions apply as they stand; changes are compared under Battery Regulation amendments.

How Compliance with the Product Requirements Is Proven

Compliance with the product requirements is proven through the conformity assessment of Article 17 of Regulation (EU) 2023/1542, which has applied since 18 August 2024 and ends in an EU declaration of conformity and the CE marking. Which module applies depends on the requirement and on whether the battery is made in series.

For Articles 6, 9, 10, 12, 13 and 14, Article 17(1) allows Module A or Module D1 for series production and Module A or Module G otherwise.

For Articles 7 and 8, Article 17(2) requires Module D1 or Module G with a notified body, applying 12 months after the first publication of the notified-body list under Article 30(2).

Harmonised standards give a presumption of conformity for Articles 9, 10, 12, 13, 14 and 78, to the extent they cover them (Article 15).

EN 18060:2025 has given it for electric vehicle modules and batteries since 16 September 2026; no common specification exists under Article 16. Modules and the CE marking are explained under battery conformity assessment.

The technical documentation and the EU declaration of conformity are kept for 10 years (Article 38(4)). Five notified bodies under the Regulation were listed in the Commission's NANDO database when checked on 12 November 2026, four of them for Articles 7 and 8.

Who Carries the Duty for Each Requirement

The manufacturer carries the product requirements: it ensures that a battery is designed and manufactured in line with Articles 6 to 10, 12 and 14 and labelled under Article 13 (Article 38(1) Regulation (EU) 2023/1542). Importers and distributors check that work (Articles 41 and 42).

Removability is the exception: Article 11 binds any natural or legal person that places on the market products incorporating portable or LMT batteries. Portable batteries must be removable and replaceable by the end-user (Article 11(1)), and LMT batteries and their individual cells by an independent professional (Article 11(5)).

Operators that prepare for re-use or repurposing, repurpose or remanufacture a battery and place it on the market are manufacturers (Article 38(11)), yet Articles 7, 8 and 10 do not apply where the battery was placed on the market before that operation (Articles 7(5), 8(4) and 10(4)). The duties of manufacturers under the EU Battery Regulation add documentation and identification.

Product Requirements FAQ

Four questions about the product requirements come up again and again in compliance guides; each answer below gives the article that settles it, as of 13 November 2026.

Common Questions on the Product Requirements

These answers cover the carbon footprint stage, distributor stock, mixed categories and harmonised standards.

Does the carbon footprint declaration apply yet?

No: as of 13 November 2026 no stage of Article 7 applies, because the EV methodology delegated act and the declaration-format implementing act are not adopted, and each date runs "whichever is the latest". With 18 February 2025 passed, the electric vehicle declaration applies 12 months after both acts enter into force.

Do new requirements apply to batteries already in distributor stock?

No: batteries placed in stock in the Union by distributors before the date of application of a requirement do not need to meet that requirement (recital 11 of Regulation (EU) 2023/1542). The recital covers distributor stock only, not a manufacturer or importer placing batteries on the market after that date.

Does a battery in more than one category follow the strictest rules?

Yes, for Chapter II only: Article 1(3), second subparagraph, applies the requirements of the strictest category, but not to labelling, producer registration or collection targets. Those three sit in Chapters III and VIII, where each battery follows the rules of its own category.

Does a harmonised standard cover every product requirement?

No: EN 18060:2025 is the only harmonised standard cited under the Regulation as of 13 November 2026, and it gives a presumption of conformity only for the EV performance and durability aspects it covers (Article 15(3)). The standardisation work is described under harmonised standards for the Battery Regulation.