EU Battery Regulation 2023/1542: what applies now

Regulation (EU) 2023/1542 replaced the old Batteries Directive and applies to every battery placed on the EU market — portable, industrial, EV, and light-transport (e-bike, scooter) — regardless of where it was manufactured. If your hardware product ships with a built-in or removable battery, this regulation sits alongside, not instead of, your usual CE marking obligations.

Who it applies to

The regulation reaches every economic operator in the chain: manufacturers, importers, distributors and retailers. There's no small-manufacturer carve-out in the source legislation — a hardware startup shipping a battery-powered device into the EU carries the same battery-specific obligations as a large OEM, scaled to the size and category of the battery involved.

Labeling requirements

Batteries — and, importantly, the devices they're built into — need readable labeling covering capacity, expected lifespan, performance and chemical composition, plus correct-disposal information (the crossed-out wheelie bin symbol most people already recognise from WEEE). For a built-in battery, that labeling obligation extends to the device itself, not just a battery you'd never see once it's installed.

Carbon footprint declarations

The most consequential near-term deadline is for larger batteries, not typical consumer electronics: as of 18 February 2026, rechargeable industrial batteries above 2 kWh require a verified carbon footprint declaration. Most hardware startups' coin cells, lithium-polymer pouches and standard consumer battery packs sit well under that threshold, but it's worth checking your specific cell capacity if your product uses a larger pack (power tools, e-bikes, backup power units).

What's coming after 2026

A Battery Passport — a digital record of a battery's composition, origin and lifecycle data — becomes mandatory in 2027 for industrial batteries above 2 kWh, EV batteries, and light-transport batteries. If your product is anywhere near those categories, it's worth designing your supply-chain data collection now rather than retrofitting it under deadline pressure.

Practical first steps

• Identify which battery category your product's cell falls into (portable / industrial / LMT / EV) — the obligations scale sharply by category.
• Confirm your battery supplier can provide the composition and lifecycle data you'll need for labeling, and eventually for a passport if your capacity crosses the industrial threshold.
• Fold battery labeling into the same technical file you're building for CE marking and WEEE registration — the three obligations overlap heavily for battery-powered devices.