EU Batteries Regulation: The Full Timeline from 2023 to 2036

Regulation (EU) 2023/1542 does not have one deadline but around fifteen, spread from 2023 to 2036 — and two of them run on a "whichever is the latest" clause that leaves them undetermined today. The battery passport itself has a hard date: 18 February 2027, with no suspensive condition. Here is the full timeline, article by article.

The firm timeline

These dates are fixed: they depend on no forthcoming delegated or implementing act.

The conditional carbon footprint timeline

This is where reading gets harder. Article 7 systematically applies a postponement clause: the obligation applies on the stated date "or" twelve to eighteen months after the entry into force of the corresponding delegated and implementing acts, "whichever is the latest".

A maximum life cycle carbon footprint threshold then applies from 18 February 2028 for electric vehicle batteries (Article 7(3)), on the same mechanism.

The practical consequence: the Commission was required to adopt the methodology delegated act for electric vehicle batteries by 18 February 2024. The draft went to public consultation from 30 April to 28 May 2024 and has not been adopted since. The twelve-month clock therefore never started — and the carbon footprint declaration for electric vehicle batteries is not enforceable today.

That is exactly what the Commission guidance of 15 August 2026 reflects, listing the carbon footprint declaration and label among the data points not to be filled in on 18 February 2027, with the format "still to be specified in the upcoming implementing act".

The recycled content timeline

Article 8 clearly separates two obligations that are often conflated: documenting a percentage, and meeting a threshold.

The delegated act setting the calculation and verification methodology was due by 18 August 2026 (Article 8(1), third subparagraph).

The late secondary acts

These delays do not have the same effect across articles. For Articles 7 and 8, the "whichever is the latest" clause mechanically postpones the obligation. For Article 77 there is no equivalent clause: the passport is still due on 18 February 2027, with content reduced to the points that actually apply.

What the timeline means for a passport project

1. 01.18 February 2027 is a market access date, not a progressive compliance target. A battery placed on the market without a passport on that date is non-compliant.
2. 02.The content due in 2027 is narrower than the full Regulation. 46 mandatory points for an electric vehicle battery, 49 for LMT, 32 for industrial — with neither carbon footprint nor recycled content.
3. 03.The 2027–2028 deadlines overlap. Passport in February 2027, due diligence in August 2027, recycled content documentation in August 2028: three distinct data programmes across eighteen months.
4. 04.Dormant fields are cheaper than migrations. Modelling carbon and recycled content fields in 2026 avoids a schema rework in 2028.

In short

Three timelines coexist in the Batteries Regulation: a firm one, which puts the passport and QR code on 18 February 2027 and due diligence on 18 August 2027; a conditional one for carbon footprint, currently frozen by the missing delegated act; and a progressive one for recycled content, from documentation in 2028 to thresholds in 2031 and 2036. Only the first sets a market access date.

Arianee supports passport rollout on the 2027 core scope, with the fields of later deadlines already modelled. See our Battery Pass page, the exact scope of batteries in scope, or request a demo.

Sources: Regulation (EU) 2023/1542, Articles 7, 8, 13, 48, 77 and 93 — consolidated text of 31 July 2025 (EUR-Lex) · Regulation (EU) 2025/1561 of 18 July 2025, OJ L 1561, 30 July 2025 · Guidance Document: Digital Batteries Passport – data points by category, v2.0, 15 August 2026 (European Commission) · Digital Product Passport — Batteries, European Commission.