The EU Battery Regulation is being rolled out in steps, and it touches pretty much everyone placing batteries on the EU market – EV and industrial batteries, LMT and SLI batteries, and even everyday portable batteries. The direction of travel is clear: better product evidence, clearer information for users, and much stronger end-of-life and supply-chain expectations.

Producer responsibility is becoming more operational

Extended Producer Responsibility (EPR) remains the backbone: producers are expected to fund and organise collection and treatment, meet targets, and report placed-on-market and waste data. The EU’s aim is higher collection and improved recycling outcomes, including ambitious recovery targets for key materials.

In practice, the “hard part” is rarely the principle – it’s the execution:

• identifying the correct legal entity as producer in each sales model (direct sales, distance selling, marketplaces, group entities),
• aligning registrations, reporting cycles, and product/battery categorisation across Member States,
• building a defensible audit trail for volumes and battery types.

If you wait until a customer, distributor, or authority asks for proof, it’s usually already too late to fix the underlying data.

Sustainability data is moving into the product file

The Regulation is designed to push sustainability into measurable, comparable requirements – covering aspects like hazardous substance restrictions, performance/durability expectations, and mandatory information such as carbon footprint-related requirements for certain batteries.

For many companies, the main challenge won’t be writing a statement – it will be proving it with consistent upstream inputs (BOM structures, supplier declarations, verified process data) and maintaining that proof through product changes. The European Commission also signals that delegated and implementing acts have been rolling out from 2024 onwards, which is why requirements can feel like a moving target if you’re not tracking updates systematically.

Labelling and digital access to information: QR codes and the battery passport

A major shift is how battery information must be made available. Labelling obligations expand from 2026, and the QR-code-based information requirements follow from 2027.

For LMT, industrial and EV batteries, the battery passport becomes the centrepiece: a digital record intended to make key battery information accessible across the value chain. Market guidance commonly references 18 February2027 as the date from which relevant batteries must be accompanied by a battery passport accessible via a QR code.

Even if technical formats and exchange mechanisms continue to mature, the preparation work is already clear: you need a reliable “single source of truth” for battery attributes and identifiers, and a process that keeps labels, documentation, and digital records aligned.

Design expectations: removability and replaceability

The Regulation also pushes product design and service concepts. One headline example: portable batteries incorporated into appliances should be removable and replaceable by the end user by 2027 (with defined derogations in specific cases).

This can affect not just design, but also user instructions, aftersales workflows, spare parts strategy, and product safety documentation – especially for brands selling consumer electronics with integrated batteries.

Due diligence is delayed – use the time

Despite the benefits, several challenges hinder effective battery recycling:

Supply-chain due diligence requirements target social and environmental risks linked to raw materials such as lithium, cobalt, nickel and natural graphite.

These obligations were postponed, with multiple compliance updates pointing to 18 August 2027 as the new application date.

That delay is useful breathing room, but it’s not a reason to ignore the topic. Due diligence tends to be hardest where supplier mapping is weak and documentation is fragmented – so starting early is usually the difference between a manageable programme and a last-minute scramble.

How Viron supports you

Viron Compliance Ltd helps companies selling batteries or battery-containing products in the EU turn the Regulation into a practical, auditable compliance setup – without overbuilding bureaucracy. Typical support includes:

• producer/EPR assessments and multi-country registration strategy,
• reporting data models and validation (placed-on-market, categories, evidence retention),
• labelling and documentation governance (so the story stays consistent across packaging, files, and digital data),
• battery passport readiness (attribute mapping, identifiers, data ownership),
• due diligence programme design ahead of 2027.