The regulation covers all batteries placed on the EU market, but the obligations vary significantly depending on the category. Understanding where your product sits determines which requirements apply and when.

Batteries designed for military, aerospace, or nuclear applications are fully excluded from the regulation. No CE marking, no EPR, no DPP.

SLI batteries (starting, lighting and ignition, used in conventional vehicles) are within scope but excluded from the most demanding requirements: no Digital Product Passport, no due diligence on raw materials, no recycled content targets, no replaceability obligations under Article 11. CE marking, EPR registration, labelling, and waste management compliance still apply.

Batteries incorporated into medical devices sit in a more constrained position. They fall fully within the regulation’s scope, with only limited exemptions available under Article 11 for specific device categories where end-user replaceability would create safety risks. CE marking, EPR, labelling, and all other obligations apply in full.

Fully in scope:

Industrial batteries cover applications ranging from stationary energy storage to large manufacturing equipment. The most demanding obligations apply to rechargeable industrial batteries above 2 kWh: Digital Product Passport from February 2027, carbon footprint reporting, recycled content targets, and full due diligence on raw material supply chains. Industrial batteries below that threshold face a lighter set of requirements.

Portable batteries are batteries weighing up to 5 kg, not designed for industrial use and not EV or LMT batteries. They are subject to CE marking, EPR, labelling, and the replaceability requirements of Article 11 from February 2027. The Digital Product Passport for portable batteries is not expected before 2030.

Under the Battery Regulation, the concept of “producer” carries specific legal weight and does not map directly onto the manufacturer role. The decisive factor is who places the battery on a specific national market for the first time. A German manufacturer selling directly to end users in France and Spain becomes the producer in both countries. An online seller based outside the EU who ships batteries to Italian customers becomes the producer in Italy, with full EPR obligations attached to that role. Understanding where your company sits in this chain is the first compliance step, and the answer is not always obvious.

From February 18, 2027, manufacturers of products incorporating portable batteries must design those products so that end users can remove and replace the battery without specialized tools and without damaging the product.

This applies at the product design level: enclosure architecture, fastening systems, compartment accessibility, and spare parts availability for at least five years after the last unit reaches the market. Products currently in development that will reach the market after that date need to address replaceability now.

Certain categories already carry exemptions, including medical devices and waterproof appliances. A draft delegated act published in April 2026 proposes extending partial exemptions to wearables, electric toys, and ATEX equipment, with final adoption expected by end of 2026.

All batteries placed on the EU market must carry a QR code linking to basic product information accessible online.

The Digital Product Passport is a separate and more comprehensive digital record, covering technical specifications, carbon footprint data, recycled content, supply chain information, and end-of-life instructions. For industrial batteries, EV batteries, and LMT batteries, the DPP becomes mandatory on February 18, 2027, a date now close enough to require active preparation. Although the QR code and the DPP are regulated separately, the underlying data they draw on substantially overlaps. From a practical standpoint, treating them as a single data management project is more efficient than building two parallel documentation processes.

Extended Producer Responsibility obligations have applied since August 2025. Producers must register in each EU member state where they place batteries on the market for the first time, and they must finance or organize the collection, treatment, and recycling of waste batteries.

Non-EU manufacturers who qualify as producers in one or more member states must appoint an EPR Authorized Representative in each of those countries. Producer Responsibility Organizations can fulfil EPR obligations on behalf of producers, but registration remains the direct responsibility of the producer.