Checklist for portable and starter batteries without a passport duty

Which battery do you have?

Tick the type that describes your battery and how you bring it to market. Both types share most duties below; the QR-code content and the recycled-content rules differ. The articles in brackets point to Regulation (EU) 2023/1542.

• Portable battery: sealed, up to 5 kg, neither an EV, LMT, SLI nor industrial battery; this includes portable batteries of general use such as AA, AAA, C, D and 9 V (Art. 3).
• SLI battery: designed to supply power for starting, lighting or ignition of vehicles, including as auxiliary or backup battery (Art. 3).
• You place the battery itself on the market, or a product it is built into: both trigger duties, partly different ones.

Your duties

Everything Regulation (EU) 2023/1542 asks of whoever places portable or SLI batteries on the market, without a passport. Tick off what is already in place; every item names its article, and the deadlines below say when it applies.

• Respect the substance restrictions: mercury at most 0.0005 %, cadmium in portable batteries at most 0.002 %, lead in portable batteries at most 0.01 % (Art. 6, Annex I).
• Attach the separate collection symbol, since 18 August 2025 on every battery, with the Cd or Pb symbol beneath it where the limits are exceeded (Art. 13(4) and (5)).
• Attach the label with the general information, from 18 August 2026 (Art. 13(1)).
• State the capacity on the label: rechargeable portable batteries and SLI batteries, from 18 August 2026 (Art. 13(2)).
• Print the minimum average duration in typical use and the words “non-rechargeable”: non-rechargeable portable batteries, from 18 August 2026 (Art. 13(3)).
• Print or engrave the QR code visibly, legibly and indelibly, from 18 February 2027; it leads to the labelling, the EU declaration of conformity, the due-diligence report and the disposal information (Art. 13(6)(b) and (7)).
• Show the recycled content through the QR code: for SLI batteries the recovered shares of cobalt, lead, lithium and nickel (Art. 13(6)(c)).
• Build portable batteries removable and replaceable by end users when you place products with built-in batteries on the market, from 18 February 2027; instructions permanently online, spare batteries for five years after the last device, no software lock (Art. 11).
• Meet the minimum values for electrochemical performance and durability: portable batteries of general use except button cells, from 18 August 2028 or 24 months after the delegated act (Art. 9, Annex III).
• Document the recovered shares per model, year and plant: SLI batteries from 18 August 2028 or 24 months after the act on the method; minimum shares from 2031 and 2036 (Art. 8).
• Carry out the conformity assessment, issue the EU declaration of conformity, affix the CE marking (Art. 17 to 20).
• Set up supply-chain due diligence, have it verified and report on it, from 18 August 2027; applies from EUR 40 million net turnover (Art. 47 to 52).
• Register as a producer under extended producer responsibility and meet the collection targets: portable batteries 63 % by the end of 2027 and 73 % by the end of 2030 (Art. 55 ff.).

What the QR code has to deliver

The code on a portable or SLI battery has to lead to this information, complete, up to date and accurate:

• The information of the label: general information, capacity or minimum duration, separate collection symbol, Cd or Pb symbol (Art. 13(1) to (5))
• The EU declaration of conformity (Art. 18)
• The due-diligence report, once required (Art. 52(3))
• The information on the prevention and management of waste batteries: the role of end users in collection, collection systems, hazards of improper disposal, meaning of the symbols (Art. 74(1)(a) to (f))
• For SLI batteries the recycled content under Article 8

Deadlines

The dates that matter for portable and SLI batteries, taken from the application articles of the regulation. The later ones hang on delegated acts the Commission has not adopted yet and are marked as such.

1. 18 February 2024
   The regulation applies

   Most provisions of the Batteries Regulation apply from this day (Art. 96). Everything below builds on it; batteries placed on the market since then fall under its conformity rules.

2. 18 August 2024
   Lead limit for portable batteries

   Portable batteries may contain at most 0.01 % lead by weight (Annex I); zinc-air button cells are exempt until 18 August 2028. Already due; check your cell specifications.

3. 18 August 2025
   Separate collection symbol

   Every battery carries the crossed-out bin symbol, with the Cd or Pb symbol beneath it where the limits are exceeded (Art. 13(4) and (5)). Already due; check your current label.

4. 18 August 2026
   Label with information, capacity or minimum duration

   Every battery carries a label with the general information of Annex VI; rechargeable portable and SLI batteries add their capacity, non-rechargeable ones their minimum average duration and the words "non-rechargeable" (Art. 13(1) to (3)). Shifts if the implementing act on the format arrives later.

5. 18 February 2027
   QR code and removability

   From this day every battery carries a QR code leading to its labelling, declaration of conformity and disposal information (Art. 13(6)), and products with built-in portable batteries must let the end user remove and replace them (Art. 11).

6. 18 August 2027
   Supply-chain due diligence

   Companies above EUR 40 million net turnover run a supply-chain due-diligence policy, have it verified and report on it (Art. 47 ff.). Postponed from 2025 by Regulation (EU) 2025/1561.

7. 31 December 2027
   Collection target of 63 %

   Producers of portable batteries must collect 63 % of what they place on the market, through their producer responsibility scheme (Art. 59).

8. 18 August 2028
   Performance, durability and recycled content

   Portable batteries of general use must meet the minimum electrochemical performance and durability values of Annex III (Art. 9), and SLI batteries document their recovered shares of cobalt, lithium, nickel and lead (Art. 8(1)); each 24 months after its delegated act if that comes later.

9. 31 December 2030
   Collection target of 73 % and carbon-footprint review

   The collection target for portable batteries rises to 73 % (Art. 59), and the Commission assesses whether to extend the carbon-footprint duties to portable batteries (Art. 7(4)).

10. 18 August 2031
    First minimum recycled shares for SLI batteries

    The active materials of SLI batteries must contain at least 16 % recovered cobalt, 85 % lead, 6 % lithium and 6 % nickel (Art. 8(2)). A sourcing question for the contracts you sign in 2029.

11. 18 August 2036
    Higher minimum recycled shares for SLI batteries

    The shares rise to 26 % cobalt, 85 % lead, 12 % lithium and 15 % nickel (Art. 8(3)).

Sources

The documents this checklist is drawn from, and what each one is good for.

How to prepare

Five steps in the order they pay off, from the label you already print to the passport you may choose to offer.

1. Check label and symbols: compare your current labelling with Article 13. The separate collection symbol has been mandatory since 2025; capacity or minimum duration follow in 2026.
2. Plan the QR code: decide where the code sits on battery or packaging and where it leads. It has to stay readable over the whole lifetime and must not depend on a service that can disappear.
3. Check removability: if you sell devices with built-in batteries, clarify with engineering whether end users can replace the battery with commercially available tools and whether spare batteries stay available for five years.
4. Consider a voluntary passport: the QR code has to lead to labelling, declaration of conformity and disposal information anyway. A product passport delivers exactly that, in every official language, and is ready should the Commission extend the duties. Register for free and create one model.
5. Schedule recycled content and due diligence: for SLI batteries the recovered shares sit with the cell manufacturers; put them into the purchasing contracts. From EUR 40 million turnover the due-diligence duties arrive in 2027.