Battery Labelling
Since Tuesday, 18 August 2026, batteries placed on the EU market were widely expected to carry extensive new labelling information intended to support informed purchasing decisions and assist waste-management operators at end of life. These requirements are set out in Annex VI, Part A of the EU Batteries Regulation (EU) 2023/1542. That is the general principle.
At the same time, the Regulation authorises the European Commission to adopt implementing acts harmonising the technical specifications for those labels across the EU. The implementing act defining the detailed format and content of the label has now been overdue for approximately one year and, at present, exists only in draft form.
The Batteries Regulation provides that, where such implementing measures are outstanding, the later applicable date prevails. As a result, 18 August 2026 is not, in practice, the operative compliance date for the expanded labelling obligations. Instead, the requirements will apply 18 months after the Commission’s specifications enter into force. The earliest possible date would have been 18 March 2027, but in the absence of a final implementing act, implementation is expected to be delayed further.
What continues to apply in the meantime
The existing labelling framework remains applicable. In practice, this includes:
- capacity marking requirements for rechargeable portable batteries and automotive batteries;
- the crossed-out wheeled-bin symbol;
- cadmium or lead markings where the relevant threshold values are exceeded.
In addition, CE-marking obligations continue to apply where required under the relevant EU product legislation.
What the current draft specification provides for
The Commission’s draft implementing act proposes a broad set of information requirements, including details concerning the manufacturer, battery category and identification, place and date of manufacture, weight, capacity, electrochemical composition, hazardous and restricted substances, suitable extinguishing agents or fire classes, and certain critical raw materials.
For smaller batteries, some information may, subject to specific conditions, be moved to the packaging or accompanying documentation.
From a compliance perspective, the forthcoming regime is less a conventional printing exercise and more a structured data-management project. However, the final specifications are still not settled.
Practical implications for manufacturers and importers
Economic operators currently face the challenge of complying with the existing framework while simultaneously preparing for a future labelling system that has not yet been formally adopted.
One date that is already fixed, however, is 18 February 2027. On that date, the requirements relating to QR codes and the digital battery passport are scheduled to apply. The digital battery passport is also intended to contain labelling-related information and does not depend on the adoption of the outstanding implementing act.
Industry associations across the EU have criticised the draft rules on the basis that the proposed implementation period is too short. At the same time, the implementing act itself is already significantly delayed. The result is a compliance environment in which businesses are expected to prepare for substantial operational changes without a binding final text.
For many undertakings, the key question is therefore no longer whether additional battery-labelling obligations are coming, but which implementation date should realistically be used in current compliance and product-planning timelines.
Full text of Regulation (EU) 2023/1542: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1542
