Regulation (EU) 2023/1542 · Practical guide

The EU Battery Regulation, without the jargon

A deep dive for the brands that keep asking "do I really need a battery passport?" — covering the five Article 3 categories, the 2026 labelling QR, Article 11 removability, the 2030 carbon footprint wall, EPR registration and what to actually do on Monday morning.

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Does my battery need a passport?

Regulation (EU) 2023/1542 replaced the old three-bucket split with five Article 3 categories. The digital battery passport under Article 77 applies to three of them. Every other duty still applies to all five.

Portable

Sealed, ≤5 kg, not an LMT, EV or SLI battery, not specifically designed for industrial use.

No passport ≤5 kg, sealed

Examples: cordless drills, stick vacs, electric toothbrushes, lawnmower packs ≤5 kg

Portable of general use

Interoperable consumer formats: AAAA, AAA, AA, C, D, 9V (PP3), 4.5V (3R12), A23, button cell.

No passport Consumer cells

Examples: alkaline AA, button cells, 9V PP3

LMT

Light Means of Transport: wheeled vehicles powered by motor (or motor + human power), ≤25 kg.

Passport required ≤25 kg, light traction

Examples: e-bikes, e-scooters, e-mopeds, mobility scooters

Industrial

Specifically designed for industrial use, OR any battery >5 kg that is not LMT/EV/SLI.

Passport required >5 kg or industrial-only

Examples: home & grid storage, telecoms UPS, agricultural / off-road traction

SLI

Starting, Lighting, Ignition — the 12V battery that starts a combustion-engine vehicle.

No passport ICE starters

Examples: 12V car / motorcycle / lawn tractor starter batteries

EV

Traction batteries for type-approved M, N, O vehicles, or category L vehicles >25 kg.

Passport required Type-approved traction

Examples: car / van / truck / bus packs, heavy motorcycles

The legislation

Article 3 sets the definitions. Article 77 sets the passport obligation and applies only to LMT batteries, industrial batteries with capacity above 2 kWh and EV batteries. The 2 kWh threshold is industrial-only — an e-scooter pack of 0.4 kWh still needs a passport because it is LMT, not because of capacity.

The passport itself becomes mandatory on 18 February 2027. Carbon footprint and due diligence obligations stack on earlier dates — see the Timeline tab.

In plain English

If the host product is sold on Amazon, B&Q, Bauhaus, Leroy Merlin or your local high street and the battery weighs 5 kg or less, it is a portable battery. No passport. But you still owe removability, labelling QR, EPR registration and (from 2030) a carbon footprint declaration.

If you also sell a professional >5 kg pack to landscapers or contractors, that SKU flips into the industrial bucket and the 2 kWh test decides whether it needs a passport.

The 5 kg rule is per SKU, not per brand

Brands that sell the same chemistry across consumer and professional channels often have one portable SKU and one industrial SKU with the same cells inside. The compliance obligations diverge on packaging, labelling and — above 2 kWh — passport scope. Audit per SKU, not per platform.

Primary sources

Read the regulation yourself

Third-party interpretation lags the source as delegated acts publish. Bookmark these:

One QR, every category, every audience

SmartLinks issues GS1 Digital Link QR codes and resolves them to the right view per audience and per legal obligation — labelling subset for portables, full passport for LMT / industrial / EV. Same code, same print spec, same data layer, scoped per SKU.

See the Digital Link levels Talk to the battery team