TECHNOLOGY EXPLAINER
The EU Batteries Regulation and the Battery Passport
— "when does what apply" is not settled by the dates in the text alone
The EU Batteries Regulation (Regulation (EU) 2023/1542) deals with a battery's design, materials, manufacture, use and collection in one law, and requires an electronic record called the "battery passport". Yet many of its application dates are written as "or N months after the delegated or implementing act enters into force, whichever is later", and some have since been amended or postponed. This article sets out the structure of the regulation, the dates checked and sorted into proposed, adopted and in application, and, as far as official material allows, how related rules in Japan, the United States and China compare.
- What the Batteries Regulation is (the short version)
- Structure of the regulation — what is required of whom
- Sorting the application dates — the text's dates and what could be confirmed
- Postponement and simplification — confirmed amendments and proposals
- Carbon footprint and recycled content — what they mean for materials
- Our calculation: when life changes, the denominator of the carbon footprint changes
- Due diligence — what is required in sourcing materials
- The battery passport — what goes in and who can see it
- Comparison with related rules in Japan, the United States and China
- Limits, and what could not be confirmed
- How to read evaluations and standards
- Glossary
- References (primary sources)
- Claim-to-source audit
Sourced = stated in published material (link given)
Our calculation = a figure this article derived, with the assumptions spelled out
Not yet confirmed = a proposal, schedule or conditional date whose force or implementation has not been confirmed
Materials-design interpretations are marked separately as Commentary. Inference is shown in bold. For legislation, proposal / adoption / entry into application are kept distinct.
Laws are amended and their interpretation and implementation change. What follows is a summary of official material as it could be confirmed on 10 October 2026; it is not a judgement on whether any product or company complies with the regulation, nor legal advice. For actual compliance, rely on the current legal text and on the competent authorities and qualified experts.
1. What the Batteries Regulation is (the short version)
- One law for a battery's whole life: Regulation (EU) 2023/1542 concerns batteries and waste batteries. It was adopted on 12 July 2023, entered into force on 17 August 2023, and has applied since 18 February 2024, with phased requirements running to 2031 and beyondSourced [Sources 1, 8]
- It covers batteries sold in the EU: batteries placed on the market or put into service, with requirements that differ by category (portable, SLI, industrial, electric vehicle, and light means of transport [LMT])Sourced [Source 1]
- The dates are conditional: application dates for items such as carbon footprint and labelling are "whichever is later" of a fixed date and 12–24 months after a delegated or implementing act enters into force, so they do not begin until those acts exist. Some, such as due diligence, have also been postponedSourced [Sources 1, 2]
"The date written in the article" and "the date an obligation actually starts" can differ. Many requirements make the application date depend on a delegated or implementing act having been adopted. Acts that could not be confirmed as adopted on the date checked (10 October 2026) are set out separately in Section 3.
2. Structure of the regulation — what is required of whom
The regulation has 14 chapters (Articles 1 to 96)Sourced [Source 1]. The table follows the chapters that bear on battery materials and design.
| Chapter / Article | Content (as in the regulation) | What it means for battery materials and design |
|---|---|---|
| Chapter II: sustainability and safety requirements (Arts. 6–12) | Art. 6: restrictions on substances. Art. 7: carbon footprint. Art. 8: recycled content. Arts. 9, 10: performance and durability (portable; industrial, LMT and EV). Art. 11: removability and replaceability of portable and LMT batteries. Art. 12: safety of stationary battery energy storage systems | Bears directly on material choice, design and evaluation methods |
| Chapter III: labelling and information (Arts. 13, 14) | Art. 13: labelling and marking (separate-collection symbol, capacity, QR code and so on). Art. 14: state of health and expected lifetime (data kept in the battery management system of stationary, LMT and EV batteries) | Fixes what data the battery management system must hold |
| Chapters IV–VI (Arts. 15–46) | Presumption of conformity, common specifications, conformity assessment, CE marking, notified bodies, obligations of manufacturers, importers and others | The framework for testing and certification |
| Chapter VII: due diligence (Arts. 47–53) | Battery due diligence policies, risk management, third-party verification, disclosure, recognition of schemes | Concerns sourcing of cobalt, natural graphite, lithium and nickel [Source 2] |
| Chapter VIII: waste batteries (Arts. 54–76) | Producer responsibility, collection, treatment, targets for recycling efficiency and material recovery | Covered in our explainer on battery recycling and second life |
| Chapter IX: digital battery passport (Arts. 77, 78) | Requires an electronic record (battery passport) for LMT batteries, industrial batteries above 2 kWh and EV batteries | Materials, performance and history are kept as a record (Section 8) |
All Sourced (the text of Regulation (EU) 2023/1542 [Source 1]). The grouping into chapters and the "what it means" column are this article's own sorting.
Which batteries the requirements reach
Many requirements reach electric vehicle batteries, rechargeable industrial batteries above 2 kWh, and LMT batteries. The carbon footprint declaration and the battery passport, for example, apply to these three categories. Recycled content applies to industrial batteries above 2 kWh (except those with exclusively external storage), electric vehicle batteries and SLI batteriesSourced [Source 1].
3. Sorting the application dates — the text's dates and what could be confirmed
| Requirement (Article) | Date in the original text | What could be confirmed (checked 10 October 2026) |
|---|---|---|
| General application (Art. 96) | 18 February 2024 | In application. The Commission page says "application date 18 February 2024, with phased requirements rolling out through 2031" [8] (the regulation text also contains a requirement for 18 August 2036) |
| Performance and durability document (Art. 10(1)), safety of stationary storage (Art. 12(2)), state-of-health data (Art. 14) | 18 August 2024 | The date has passed. The delegated acts setting minimum values under Art. 10 (deadlines: industrial 18 February 2026; LMT 18 February 2027) could not be confirmed as adopted Not yet confirmed |
| Obligations of economic operators (Chapter VI), conformity assessment (Art. 17) | 18 August 2024 | The date has passed |
| Separate-collection symbol (Art. 13(4)), waste battery management (Chapter VIII) | 18 August 2025 | The date has passed |
| Due diligence (Art. 48(1)) | 18 August 2025 | Postponed to 18 August 2027. Amended by Regulation (EU) 2025/1561 (of 18 July 2025; published 30.7.2025; in force the next day) [2, 3] |
| Carbon footprint declaration (Art. 7(1)): EV batteries | 18 February 2025, or 12 months after the delegated or implementing act enters into force, whichever is later | A draft annex of the delegated act on the EV battery method was put to consultation on 30 April 2024, but adoption could not be confirmed [9] Not yet confirmed |
| Carbon footprint performance classes (Art. 7(2)): EV batteries | 18 August 2026, or 18 months after the act enters into force, whichever is later | The deadline for the delegated act was 18 February 2025. Adoption could not be confirmed Not yet confirmed |
| Carbon footprint maximum threshold (Art. 7(3)): EV batteries | 18 February 2028, or 18 months after the delegated act enters into force, whichever is later | The deadline for the delegated act was 18 August 2026. Adoption could not be confirmed Not yet confirmed |
| Labels (Art. 13(1)–(3)) | 18 August 2026, or 18 months after the implementing act enters into force, whichever is later | The deadline for the implementing act was 18 August 2025. Adoption could not be confirmed Not yet confirmed |
| QR code (Art. 13(6)), battery passport (Art. 77) | 18 February 2027 | In the future. The Commission describes Implementing Regulation (EU) 2026/1778 on the registry as dated 16 July 2026 and the registry as operational from 20 July 2026 [4, 5, 6]. The implementing act on access rights is in development [4] Not yet confirmed |
| Removability and replaceability of portable batteries (Art. 11) | 18 February 2027 | In the future. On 14 July 2026 the Commission adopted a delegated act adding exempt products (it goes to the Parliament and Council for scrutiny and enters into force 20 days after publication in the Official Journal if neither objects) [7] Not yet confirmed |
| Recycled content: documentation (Art. 8(1)) | 18 August 2028, or 24 months after the delegated act enters into force, whichever is later | The deadline for the delegated act was 18 August 2026. Adoption could not be confirmed Not yet confirmed |
| Recycled content: minimum shares (Art. 8(2), (3)) | 18 August 2031 / 18 August 2036 | In the future. Values are given in Section 5 |
The dates in the original text are Sourced (the regulation [1]). "Could not be confirmed" means that no record of adoption was found on the EUR-Lex page for the regulation (which lists amending and completing acts) or on the official Commission pages consulted; it does not assert that the act has not been adopted.
Even where application dates are conditional, the text of the regulation already fixes what is to be measured and recorded. The performance and durability document, for example, must give rated capacity, capacity fade, power, internal resistance, round-trip efficiency, and expected life in cycles and years, and explain the discharge and charge rates and depth of discharge used (Annex IV)Sourced [Source 1]. For a materials supplier, holding data on how its material affects a battery's evaluation values now, without waiting for the delegated acts, is preparation for customer enquiries (Commentary). How these are measured is covered in our explainer on battery evaluation and degradation.
4. Postponement and simplification — confirmed amendments and proposals
The EUR-Lex page for Regulation (EU) 2023/1542 lists acts that amend or complete it and proposals to amend it. This is the picture on the date checkedSourced [Source 3].
| Act / document | Content | Stage |
|---|---|---|
| Regulation (EU) 2024/1781 (Ecodesign Regulation) | Listed on EUR-Lex as an amendment adding paragraph 10 to Article 77 (dated 18 July 2024). The content of the added paragraph was not checked | In force |
| Delegated Regulation (EU) 2025/606 | Methodology for calculating and verifying recycling efficiency and material recovery rates for waste batteries. Listed on EUR-Lex as completing the regulation, dated 24 July 2025 | Adopted (listed on EUR-Lex) |
| Regulation (EU) 2025/1561 | Amends Article 48. Moves the application date of due diligence from 18 August 2025 to 18 August 2027, and the deadline for the Commission's guidelines from 18 February 2025 to 26 July 2026. Reasons given: notified bodies are taking longer to designate, and recognised due diligence schemes are not yet in place | In force (31 July 2025) |
| Regulation (EU) 2026/1738 (circularity requirements for vehicle design and end-of-life vehicles) | Replaces Annex I of Regulation (EU) 2023/1542 (13 August 2026) | In force |
| COM(2025) 501 | A simplification proposal extending mitigating measures for small and medium-sized enterprises to small mid-cap enterprises; covers several regulations including Regulation (EU) 2023/1542 | Proposal (adoption not confirmed) |
| COM(2025) 504 | Proposal on digitalisation and common specifications, including amendments to Regulation (EU) 2023/1542; for example, supplying instructions and safety information for stationary storage through the battery passport, with paper copies on request | Proposal (adoption not confirmed) |
| Other proposals | The EUR-Lex page also lists a proposal to suspend the rule on authorised representatives for extended producer responsibility and a public procurement proposal as related to amending Regulation (EU) 2023/1542 | Proposals (adoption not confirmed) |
All Sourced (the EUR-Lex page [3] and the documents themselves [2, 10, 11, 17]). The content of proposals can change as the legislative procedure moves on.
What Regulation (EU) 2025/1561 changed was only the dates in Article 48 (the date in paragraph 1 and the date in paragraph 5). The content of the due diligence obligations and the materials covered were not changed. Its recitals give the need for battery makers to analyse and adjust supply chains in a shifting geopolitical landscape, and the slow designation of notified bodies, as reasons for a two-year postponementSourced [Source 2].
5. Carbon footprint and recycled content — what they mean for materials
Carbon footprint (Article 7)
Electric vehicle batteries, rechargeable industrial batteries above 2 kWh and LMT batteries require a carbon footprint declaration for each battery model per manufacturing plant. The value is expressed as kg CO2e per kWh of the total energy provided by the battery over its expected service life, and also broken down by life-cycle stage (Annex II sets the essential elements of the method)Sourced [Source 1].
- The method is not yet settled: the Commission's Joint Research Centre (JRC) page reports that a draft annex of the delegated act on the EV battery method was put to consultation on 30 April 2024, that a report on the method for industrial batteries was published in April 2025, and that the method for LMT batteries is under development. Adoption of the EV delegated act could not be confirmedSourced [Source 9]
- Performance classes and a maximum threshold: after the declaration, the performance class shown on the label (Art. 7(2)) and a maximum threshold (Art. 7(3)) are introduced in stages. Both presuppose delegated actsSourced [Source 1]
Recycled content (Article 8)
For industrial batteries (above 2 kWh, except those with exclusively external storage), EV batteries and SLI batteries that contain cobalt, lead, lithium or nickel in active materials, documentation of the share recovered from manufacturing waste or post-consumer waste and then minimum shares are required in these stagesSourced [Source 1].
| Stage | Requirement (regulation text) | Cobalt | Lead | Lithium | Nickel |
|---|---|---|---|---|---|
| Documentation | From 18 August 2028 or 24 months after the delegated act enters into force, whichever is later: documentation of the recovered share per model, year and manufacturing plant | A document stating the share (no minimum required) | |||
| Minimum shares, stage 1 | From 18 August 2031, demonstrated in the technical documentation | 16% | 85% | 6% | 6% |
| Minimum shares, stage 2 | From 18 August 2036, demonstrated in the technical documentation | 26% | 85% | 12% | 15% |
All Sourced (Article 8 of the regulation [1]). The Commission is to assess whether to revise the targets by 31 December 2028.
The recycled share is the portion of the cobalt, lithium and nickel contained in active materials that was recovered from manufacturing waste or post-consumer waste (for lead, the amount in the battery) [Source 1]. It can be counted only if the recycled metal can be traced back into precursor and cathode active material production. The numerator includes recovered process scrap. Early in a ramp-up, when electrode yield is low, a lot of scrap is generated, so which process scrap counts as "manufacturing waste" is decided in the calculation method (the delegated act) (Inference: this depends on the content of a delegated act whose adoption could not be confirmed).
Chemical analysis alone cannot tell whether a metal is of recycled or mined origin. The distinction has to be made through records of material flow (mass balance and traceability), which links to the battery passport below (Commentary).
6. Our calculation: when life changes, the denominator of the carbon footprint changes
By the regulation's definition the footprint is divided by the total energy the battery provides over its service life. Assume a manufacturing footprint of 80 kgCO2e per kWh of battery capacity (hypothetical) and an average retained capacity of 0.9 over life, then vary the lifeOur calculation.
- 500 cycles: 80 ÷ (500 × 0.9) = about 0.178 kgCO2e/kWh
- 1,000 cycles: 80 ÷ (1,000 × 0.9) = about 0.089
- 2,000 cycles: 80 ÷ (2,000 × 0.9) = about 0.044
- 3,000 cycles: 80 ÷ (3,000 × 0.9) = about 0.030
- 5,000 cycles: 80 ÷ (5,000 × 0.9) = about 0.018
Assumptions and limits: 80 kgCO2e/kWh and 0.9 are hypothetical values to show the form of the calculation; they are not values of any real battery. One cycle is taken as 1 kWh per kWh of capacity (100% depth of discharge), and emissions after the use stage are not included. The actual method (a delegated act) could not be confirmed as adopted for EV batteries, and how the service life is set is decided there. Even so, the way the denominator works is certain: with the same manufacturing emissions, ten times the life gives about one tenth the value per kWh.
This calculation shows that materials technology that extends life (stabilising the SEI, suppressing particle cracking, controlling moisture and so on) is also a way of lowering the carbon footprint. Degradation mechanisms are covered in our explainer on battery evaluation and degradation. Note, though, that adding active material or additives to extend life can raise the manufacturing emissions, and which is better depends on the calculation method (how life is set and the scope of stages) (Commentary).
7. Due diligence — what is required in sourcing materials
Chapter VII (Articles 47–53) requires economic operators placing batteries on the market to set up and implement battery due diligence policies. They cover the sourcing, processing and trading of the cobalt, natural graphite, lithium and nickel used in battery manufacture (as summarised in the recitals of Regulation (EU) 2025/1561)Sourced [Source 2].
- Third-party verification: policies are verified by a notified body and periodically audited. The documentation is kept for 10 years after the last battery was placed on the market (Art. 48(2), (3))
- Disclosure: a report on the policy is made public each year, in a form that identifies the batteries concerned (Art. 52(3)). Information from the report also becomes the "responsible sourcing" item of the battery passport (Annex XIII)
- Application date: the original text said 18 August 2025, but it was postponed to 18 August 2027 (Regulation (EU) 2025/1561). The deadline for the Commission's guidelines was changed to 26 July 2026, but whether the guidelines have been published could not be confirmedSourced / Not yet confirmed [Sources 1, 2]
- The Commission FAQ: states that the due diligence report is required from August 2027 [Source 4]
That the covered materials include natural graphite bears on how a material supply is designed (recitals of Regulation (EU) 2025/1561) [Source 2]. Inference: whether the anode uses synthetic graphite, natural graphite or a blend may change the scope of due diligence. Where resources come from and how they are procured is covered in our explainer on battery material resources and sourcing. The details of Annex X, including whether synthetic graphite is outside the scope, were not checked here.
8. The battery passport — what goes in and who can see it
Article 77 requires that, from 18 February 2027, each LMT battery, each industrial battery above 2 kWh and each EV battery placed on the market or put into service have an electronic record called a battery passport. It holds information on the battery model and information specific to the individual battery, including that arising from use (Annex XIII)Sourced [Source 1].
The public items include evaluation values
Point 1 of Annex XIII (information accessible to the public) lists materials and performance itemsSourced [Source 1].
- Material composition (chemistry, hazardous substances other than mercury, cadmium and lead, and critical raw materials)
- Carbon footprint, the responsible sourcing report, the recycled content, and the share of renewable content
- Rated capacity (Ah), minimum, nominal and maximum voltage (with temperature ranges), and original power capability (W)
- Expected battery lifetime in cycles and the reference test used, and the capacity threshold for exhaustion (EV batteries only)
- Initial round-trip energy efficiency and that at 50% of cycle life, internal cell and pack resistance, and the C-rate of the cycle-life test
In other words, a life figure is published together with the test and C-rate used to measure it. This is the same idea as the "numbers with conditions" in our explainer on battery evaluation and degradation. Definitions of capacity fade and internal resistance are given in Annex IV [Source 1].
The registry and access rights
The passport is built on the common digital product passport system laid down by the Ecodesign Regulation (EU) 2024/1781, not on a battery-specific one. According to the Commission's official pages and FAQSourced [Sources 4, 5, 6]:
- The passport applies to the finished battery. The operator placing the battery on the EU market registers it in the digital product passport registry. The registry records identifiers and metadata, and the detailed battery information is managed by the economic operator in a decentralised system
- The implementing rules for the registry are in Commission Implementing Regulation (EU) 2026/1778 (16 July 2026). In it, "digital product passport" includes the battery passport of Article 77 of Regulation (EU) 2023/1542. The registry became operational on 20 July 2026
- The battery information is reached through a QR code (Art. 13(6), from 18 February 2027)
- Access for "persons with a legitimate interest" (recyclers, repairers and so on) depends on an implementing act in development; the FAQ says a draft is expected for public feedback in October or November 2026 Not yet confirmed
- The FAQ does not directly address batteries placed on the market before February 2027, but says a battery that is remanufactured after the requirements apply will need a passport
Point 2 of Annex XIII sets detailed composition, including the materials used in the cathode, anode and electrolyte, as an item visible only to persons with a legitimate interest [Source 1]. The public composition stays at a summary (chemistry, hazardous substances, critical raw materials), so formulation details are protected by design. Battery makers, however, will need to ask materials suppliers for composition data in order to supply this information. What is passed on, at what granularity and under what confidentiality becomes a point in supply contracts (Commentary).
Dismantling information (sequence, tools, warnings) and spare-part numbers are also items, so the choice of adhesives and encapsulants is judged as ease of repair and recycling. For adhesive and encapsulant choices, see related explainers such as automotive silicones and encapsulants.
Removability and replaceability (Article 11)
From 18 February 2027, Article 11 requires products that use portable batteries to be designed so that users can remove and replace the battery with commercially available tools (with exceptions such as appliances that must be washable). On 14 July 2026 the Commission adopted a delegated act adding exempt products (said to be six categories, including wearable devices, electric toys and equipment within the ATEX Directive). It will enter into force 20 days after publication in the Official Journal after scrutiny by the European Parliament and the CouncilSourced / Not yet confirmed [Sources 1, 7]. This is a requirement for portable batteries, not for energy storage or EV batteries.
9. Comparison with related rules in Japan, the United States and China
A system like the EU's, which handles design, materials, information and collection together in one law, could not be confirmed in Japan, the United States or China from the official material consulted. Each pursues similar aims by different means.
| Region | What could be confirmed (official material) | Stage |
|---|---|---|
| EU | Regulation (EU) 2023/1542. Legal requirements on carbon footprint, recycled content, due diligence, battery passport, replaceability and labels (conditional dates; postponements) [1, 2, 3] | In force (requirements phased) |
| Japan | Japan's Ministry of Economy, Trade and Industry (METI) published a battery industry strategy on 31 August 2022 through its public–private council; the topics include "rules for strengthening supply-chain management" and "promoting recycling and reuse" [12]. A METI document (21 April 2023) describes a carbon footprint trial project with about 50 participants (raw material procurement and manufacture, distribution and use stages; AIST's IDEA database as the basis) and a draft calculation method for automotive batteries, ver. 1.0 [13]. The Automotive and Battery Traceability Center (ABtC) operates a data-exchange system and was certified on 1 September 2024 as a "public-interest digital platform operator" (certification period to 31 August 2026) [14] | A strategy, a draft calculation method and a private data-exchange platform. No EU-style obligation could be confirmed. Renewal of ABtC's certification could not be confirmed |
| United States | No federal battery passport or carbon-footprint labelling obligation could be confirmed. Instead, supply chains are steered through tax credits. The advanced manufacturing production credit under section 45X of the Internal Revenue Code excludes components that include material assistance from a "prohibited foreign entity" for taxable years beginning after 4 July 2025, under the law enacted on 4 July 2025 (P.L. 119-21). The IRS gave interim guidance in Notice 2026-15 and says it intends to issue more comprehensive proposed regulations [15] | Enacted tax rules. Detailed regulations in preparation (proposed regulations not confirmed) |
| China | Mandatory national standard GB 38031-2025 (traction battery safety, in force from 1 July 2026). In addition, the "Interim Measures for the Recycling and Comprehensive Utilization of Retired New-Energy-Vehicle Traction Batteries" (Order No. 73 of six ministries including the Ministry of Industry and Information Technology; promulgated 31 December 2025; in force 1 April 2026) require battery companies to code batteries according to GB/T 34014 and mark cells, modules and packs, and say the state will set up a "digital identity card" system, with specific methods to be provided separately (Arts. 9 and 12) [16] | In force. The specific methods for the digital identity card are to be provided separately (not confirmed) |
All Sourced (source numbers in each row). The systems differ in aims and means, so this article does not compare which is stricter. Their scopes also differ (EV batteries, all batteries, or waste batteries).
The EU and China move in a similar direction on battery-by-battery identification and digital records (EU: QR code and battery passport; China: coding and a digital identity card). In the articles of the Chinese measures this article checked, however, the digital identity card's methods are to be set out separately, and the range of information recorded could not be confirmed. Japan has first prepared a calculation method and a data-exchange platform, and no obligation could be confirmed. The United States restricts the origin of procurement through tax rules rather than through environmental labelling (this article's own sorting).
10. Limits, and what could not be confirmed
(1) Confirmation of adoption
Adoption or publication could not be confirmed for the delegated and implementing acts on carbon footprint (including EV batteries), the labelling implementing act, the delegated act on minimum performance and durability values, the delegated act on calculating recycled content, and the due diligence guidelines. The scope of checking was the EUR-Lex page for the regulation and official Commission pages. This does not assert that they have not been adopted.
(2) The fate of proposals
Whether proposals such as COM(2025) 501 and COM(2025) 504 were adopted, and in what form, has not been confirmed.
(3) Scope of other countries' rules
Japanese statutes (such as the Act on the Promotion of Effective Utilization of Resources), US state laws (such as California's) and Chinese standards on carbon footprint were not checked. The detailed definition of "prohibited foreign entity" and the threshold percentages in the United States are not given.
(4) Interpreting the text
For the details of scope (definitions of battery, exemptions, transitional measures), label formats and the data format of the battery passport, consult the regulation and the implementing acts.
- The EU Batteries Regulation has applied since 18 February 2024, and its requirements are phased through 2031 and beyondSourced
- Many dates are "N months after the delegated or implementing act, whichever is later", and for some, such as the delegated act on EV battery carbon footprint, adoption could not be confirmedSourced / Not yet confirmed
- Due diligence has been postponed to 18 August 2027 (Regulation (EU) 2025/1561), an amendment that changes the date, not the contentSourced
- The battery passport starts on 18 February 2027. The registry became operational on 20 July 2026, and the implementing act on access for persons with a legitimate interest is in developmentSourced / Not yet confirmed
- Life figures are to be published with their test conditions, and the denominator of the carbon footprint is set by lifeSourced / Our calculation
- No single law of the EU's form could be confirmed in Japan, the United States or China; they use other means — a calculation method and a platform (Japan), tax rules (United States), and coding with a digital identity card (China)Sourced
11. How to read evaluations and standards
Before comparing which number is larger, align the basis of comparison in the following order. This is an editorial reading checklist, not a set of test conditions or acceptance limits prescribed by a standard.
- 1. What was measured?
- covered products, application dates, required data and calculation boundary. Check the units and whether the result describes a material, component or complete system.
- 2. Under which conditions?
- legal version, delegated/implementing acts, market, calculation method and transition period. Treat results under different conditions as separate results before comparing them.
- 3. The comparison trap
- Distinguish adopted law, proposals and companies' implementation plans.
- 4. What does the standard cover?
- Check the identifier, title, edition and scope in the issuing body’s material. Distinguish test methods, safety, interoperability and management requirements. Naming a standard alone does not establish that a test, conformity assessment or certification has been completed.
Keep a comparison note containing the object, units, conditions, sample count and variation, comparator, standard edition and unresolved points. Do not invent numerical conditions or acceptance limits from a public abstract of a standard.
12. Glossary
- Battery passport
- An electronic record tied to a battery: composition, carbon footprint, performance, history and more.
- LMT battery
- A battery for light means of transport (e-bikes, e-scooters and similar).
- SLI battery
- A starting, lighting and ignition battery (mainly lead-acid).
- Delegated / implementing act
- Commission acts that complete a basic law. Delegated acts supplement or amend it; implementing acts set uniform conditions for implementation.
- Notified body
- A third-party body that a Member State has notified to the Commission for tasks such as conformity assessment.
- Due diligence
- A system for identifying and addressing environmental and human-rights risks in sourcing.
- Carbon footprint
- Greenhouse-gas emissions over a product's life cycle, expressed as CO2 equivalent.
- Recycled content
- The share of cobalt, lithium and nickel in active materials that was recovered from manufacturing waste or post-consumer waste.
- DPP registry
- The Commission's registry that records identifiers and metadata of digital product passports.
- PFE (prohibited foreign entity)
- In US tax law, an entity defined by its ties to countries of concern.
- Coding / digital identity card
- China's traction-battery identification code / a digital ID that links information on the battery.
- ABtC
- The Automotive and Battery Traceability Center, operator of Japan's data-exchange system for automotive and battery supply chains.
13. References (primary sources)
- European Parliament and Council Regulation (EU) 2023/1542 of 12 July 2023 concerning batteries and waste batteries (OJ L 191, 28.7.2023, original text) — eur-lex.europa.eu
- European Parliament and Council Regulation (EU) 2025/1561 of 18 July 2025 amending Regulation (EU) 2023/1542 as regards obligations of economic operators concerning battery due diligence policies (OJ L, 30.7.2025) — eur-lex.europa.eu
- EUR-Lex Page for Regulation (EU) 2023/1542 (list of amending and completing acts and of proposed amendments) — eur-lex.europa.eu
- European Commission "EU Digital Product Passport FAQ for Batteries" — single-market-economy.ec.europa.eu
- European Commission "Batteries" (digital product passport page; timelines stated to be indicative) — single-market-economy.ec.europa.eu
- European Commission Implementing Regulation (EU) 2026/1778 of 16 July 2026 laying down the implementation arrangements for the digital product passport registry — eur-lex.europa.eu
- European Commission, DG Environment "Commission adds exemptions to portable battery removal rules", 14 July 2026 — environment.ec.europa.eu
- European Commission, DG Environment "Batteries" (overview page for the Batteries Regulation) — environment.ec.europa.eu
- European Commission, JRC "Carbon footprint – Batteries" (Knowledge4Policy) — knowledge4policy.ec.europa.eu
- European Commission COM(2025) 504 final (proposal on digitalisation and common specifications, including amendments to Regulation (EU) 2023/1542) — eur-lex.europa.eu
- European Parliament and Council Regulation (EU) 2026/1738 on circularity requirements for vehicle design and on management of end-of-life vehicles (including amendments to Regulation (EU) 2023/1542) — eur-lex.europa.eu
- Ministry of Economy, Trade and Industry (METI), Japan "Public-Private Council on Battery Industry Strategy" (battery industry strategy published 31 August 2022; in Japanese) — meti.go.jp
- METI "Carbon footprint of storage batteries", 21 April 2023 (PDF, in Japanese) — meti.go.jp
- METI "The Automotive and Battery Traceability Center certified for the first time as a public-interest digital platform operator", 2 September 2024 (in Japanese) — meti.go.jp
- US Internal Revenue Service Notice 2026-15 (interim guidance on material assistance from prohibited foreign entities) — irs.gov
- China: Ministry of Industry and Information Technology and others (posted in the Ministry of Commerce's legal database) "Interim Measures for the Recycling and Comprehensive Utilization of Retired New-Energy-Vehicle Traction Batteries" (Order No. 73, promulgated 31 December 2025, in force 1 April 2026; in Chinese) — policy.mofcom.gov.cn
- European Commission COM(2025) 501 final (simplification proposal extending mitigating measures for SMEs to small mid-cap enterprises, including Regulation (EU) 2023/1542) — eur-lex.europa.eu
14. Claim-to-source audit
| Claim in the text | Basis | Class |
|---|---|---|
| The title and structure of Regulation (EU) 2023/1542 (14 chapters, Articles 1–96), adoption on 12 July 2023, entry into force on 17 August 2023 (EUR-Lex dates), application from 18 February 2024. The content of Articles 6–14; Article 7 (definition of the carbon footprint and its dates); Article 8 (recycled content documentation and minimum shares: 16%/85%/6%/6% in 2031, 26%/85%/12%/15% in 2036); Article 10 and Annex IV (performance and durability); Articles 11, 12 and 13 (labelling, separate-collection symbol 18 August 2025, QR code 18 February 2027); Article 14; Article 48 (original date); Article 77 (18 February 2027); Article 96; Annex XIII (battery passport information) | Regulation (EU) 2023/1542, original text Reference 1 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R1542 | Sourced |
| Regulation (EU) 2025/1561: the date in Article 48(1) changed from 18 August 2025 to 18 August 2027 and the date in Article 48(5) from 18 February 2025 to 26 July 2026; the reasons (delay in designating notified bodies, schemes not yet in place, the geopolitical situation); that the covered materials are cobalt, natural graphite, lithium and nickel; dated 18 July 2025 and in force the next day | Regulation (EU) 2025/1561 Reference 2 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L_202501561 | Sourced |
| The list of acts amending and completing Regulation (EU) 2023/1542 and of proposals (Regulation (EU) 2024/1781, Delegated Regulation (EU) 2025/606, Regulation (EU) 2025/1561, Regulation (EU) 2026/1738, COM(2025) 258, 501, 504, 981 and 982, COM(2026) 590) | EUR-Lex page for the regulation Reference 3 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32023R1542 | Sourced |
| That the battery passport applies to the finished battery; registration in the registry; that the access-rights implementing act is in development with a draft expected in October–November 2026; that the registry became operational on 20 July 2026; that remanufactured batteries after February 2027 need a passport; that the due diligence report is required from August 2027 | Commission FAQ and page Reference 4 https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/eu-digital-product-passport-faq-batteries_en Reference 5 https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/batteries_en | Sourced |
| The implementing rules for the digital product passport registry, Implementing Regulation (EU) 2026/1778 (16 July 2026), which defines the digital product passport as including the battery passport | Commission Implementing Regulation (EU) 2026/1778 Reference 6 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026R1778 | Sourced |
| The adoption on 14 July 2026 of a delegated act adding exempt products to the portable-battery removability rule, the six categories (three of them wearable devices, electric toys and ATEX equipment), and the scrutiny and entry-into-force procedure | Commission, DG Environment Reference 7 https://environment.ec.europa.eu/news/commission-adds-exemptions-portable-battery-removal-rules-2026-07-14_en | Sourced |
| The entry into force on 17 August 2023 and application from 18 February 2024, with phased requirements said to run through 2031 | Commission, DG Environment Reference 8 https://environment.ec.europa.eu/topics/waste-and-recycling/batteries_en | Sourced |
| That a draft annex of the delegated act on the EV battery carbon footprint method went to consultation on 30 April 2024, that a report on the industrial battery method was published in April 2025, and that the LMT battery method is under development | Commission, JRC Reference 9 https://knowledge4policy.ec.europa.eu/projects-activities/carbon-footprint-batteries_en | Sourced |
| The content of COM(2025) 504 (for example supplying stationary-storage instructions and safety information through the battery passport), the purpose of COM(2025) 501, and that Regulation (EU) 2026/1738 replaces Annex I | The documents themselves Reference 10 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025PC0504 Reference 17 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025PC0501 Reference 11 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026R1738 | Sourced |
| METI's battery industry strategy (31 August 2022) and its topics; the carbon footprint trial project (about 50 participants, IDEA, four stages) and the draft calculation method ver. 1.0 (21 April 2023); ABtC's certification (announced 2 September 2024; period 1 September 2024 to 31 August 2026) | METI Reference 12 https://www.meti.go.jp/policy/mono_info_service/joho/conference/battery_strategy.html Reference 13 https://www.meti.go.jp/shingikai/mono_info_service/chikudenchi_sustainability/pdf/004_03_00.pdf Reference 14 https://www.meti.go.jp/press/2024/09/20240902002/20240902002.html | Sourced |
| United States: the restriction on material assistance from prohibited foreign entities under section 45X by P.L. 119-21, and the interim guidance in Notice 2026-15 (with an intention to issue proposed regulations) | IRS Notice 2026-15 Reference 15 https://www.irs.gov/pub/irs-drop/n-26-15.pdf | Sourced |
| China: Order No. 73 (promulgated 31 December 2025, in force 1 April 2026), Article 9 (coding and marking according to GB/T 34014), Article 12 (digital identity card system, with specific methods to be provided separately) | Interim Measures of the Ministry of Industry and Information Technology and others Reference 16 https://policy.mofcom.gov.cn/claw/clawContent.shtml?id=105536 | Sourced |
| Whether the delegated and implementing acts on which the original application dates depend were adopted (carbon footprint, labels, minimum performance and durability values, recycled content calculation, due diligence guidelines), the implementing act on passport access rights, and the fate of proposals such as COM(2025) 501 and 504 | Conditional dates in the original text, and items whose adoption could not be confirmed. This does not assert that they have not been adopted Reference 1 https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R1542 Reference 3 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32023R1542 | Not yet confirmed |
| Manufacturing emission of 80 kgCO2e/kWh (hypothetical), average capacity 0.9 (hypothetical), and the values for lives of 500 to 5,000 cycles (about 0.178, 0.089, 0.044, 0.030 and 0.018) | Our calculation: 80 / (cycles x 0.9). Hypothetical values, not including emissions after the use stage, and not the regulation's calculation method (a delegated act) | Our calculation |
| That no single law of the EU's form could be confirmed in Japan, the United States or China; the status of national digital IDs and data platforms; that no US federal labelling obligation could be confirmed; the renewal status of ABtC's certification | Not given, because they could not be confirmed in the official material accessible to this article | Commentary |
| The readings “data preparation starts before the dates are settled”, “the denominator and numerator are defined in the language of materials”, “a longer life is also a lower environmental load”, “being asked for detailed composition”, and “only natural graphite is named”. The comparison of similarities and differences across countries. The outlook on recycled-content calculation (Inference) | This article's own sorting and commentary based on the published material. Not a view stated by any company or body | Commentary |
| That Figs. 2, 4 and 5 are explanatory drawings, not official diagrams or real data, and that Figs. 1 and 3 are AI-generated images | Note from this article | Commentary |
Last updated 10 October 2026. Sources are limited to primary material (laws on EUR-Lex and official pages of the European Commission, the Japanese Ministry of Economy, Trade and Industry, the US Internal Revenue Service and Chinese government bodies). Laws are amended, and changes after the date checked are not reflected. Because the article includes structural readings and materials-design interpretations, those are marked as Commentary and kept separate from sourced fact. The adoption of the delegated and implementing acts (EV battery carbon footprint, labels, minimum performance and durability values, recycled content calculation), the publication of the due diligence guidelines, the fate of proposals such as COM(2025) 501 and 504, and the details of the Japanese, US and Chinese systems could not be confirmed and are not stated here. This article is not legal advice and does not judge whether any product or company complies with the regulation. All figures are explanatory concept graphics. Figs. 2, 4 and 5 are vector drawings; Figs. 1 and 3 are AI-generated images, and none of them shows an official diagram of any system or a real product.