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Analyses · 2026-10-03

Batteries: staged entry into force makes partial compliance normal

Batteries are the one category in this series where the difficulty sits on a timeline rather than between markets. The EU battery regulation does not arrive all at once; it lays its obligations out by date. This splits them into what has landed, what has not, and what is the same everywhere.

The difficulty is on the timeline, not between markets

The first three articles asked what one product has to clear in ten markets. Batteries differ: in most markets the baseline obligation is the same set of transport tests, and the real variation sits in the EU regulation that phases in by year.

That makes the habit worth building here simple: saying "our batteries are compliant" is incomplete. It needs a date. The same cell, before and after August 2025, is not subject to the same list.

Two obligations already in place

The EU Batteries Regulation (EU) 2023/1542 was published in the Official Journal on 28 July 2023 (OJ L 191) and has applied since 18 February 2024. By 18 August 2025, two obligations had landed.

First, all batteries must carry the separate-collection symbol, the crossed-out bin. This one is not tiered by battery type; portable, industrial and automotive are all in. Second, the older Batteries Directive 2006/66/EC was repealed as of the same date, so any compliance document still citing the old directive went out of date that day.

Both of these sit on the product itself rather than in a file, which is why a buyer tends to find them when opening the box: the symbol is not there.

Still ahead: QR codes, and the Commission's own deadlines

Under the text, all batteries must carry a QR code from 18 February 2027 (Annex VI, Part C).

A second group of dates is easy to misread. The ones appearing along the carbon footprint line, such as 18 February 2025 and 18 August 2026, are mostly deadlines for the European Commission to adopt delegated or implementing acts. They are not dates on which manufacturers have to file something. Confusing the two turns "the Commission has not published the detail yet" into "the factory is already in breach".

Further stages follow, on recycled content, due diligence and the battery passport. When citing this regulation, naming the article and the date is worth far more than naming the regulation.

The one that is the same everywhere: transport

Lithium batteries have to pass UN 38.3, the tests in section 38.3 of the UN Manual of Tests and Criteria. This does not change with the destination and is not waived by battery type; it is the common precondition in every market.

In national law it appears as 49 CFR 173.185 in the US, with equivalents in Canada, Australia-New Zealand and elsewhere. What matters for a buyer is that the transport test report is a separate document from product safety certification. The two are routinely asked for, and answered, as one.

China: GB 31241 and CCC where listed

For lithium-ion cells and packs for portable electronic products, China's baseline is the GB 31241 series. Batteries and battery-containing products inside the CCC mandatory certification catalogue, power banks among them, need certification through a designated body; those outside carry product liability under the mandatory standards and a declaration.

The catalogue and its batches have been adjusted in recent years, so which products are in must be checked against the current announcement. We have marked that as unverified rather than writing it into the page.

Japan, Korea, Brazil, Australia-NZ

Japan takes UN 38.3 for transport and adds small rechargeable battery collection duties under its resource recycling legislation. Korea takes UN 38.3 and, on the product side, KC safety certification and confirmation for batteries. Brazil applies mandatory INMETRO certification to lithium batteries, usually led by the importer. Australia and New Zealand take UN 38.3, with state-level producer responsibility legislation for batteries moving forward.

For these markets we currently have the regime described but no primary text, so the page states the regime and no document numbers.

Ten markets side by side

Putting the stages next to the markets gives this picture:

The table says one thing: batteries vary less across markets than other categories do, and their real complexity is on their own timeline. The most valuable action is not comparing ten markets but pinning the EU phase-in schedule into the purchasing process.

What to ask before you order

Ask for batteries in three parts: cell and pack safety testing (which standard, which laboratory, which abuse tests covered), transport testing (the UN 38.3 report, remembering it is usually issued per cell type and packing method, so a change of packaging may mean a new report), and marking (when the separate-collection symbol started appearing, and whether the artwork has a place reserved for the QR code).

That last question is a good filter before 2027. A factory that has already reserved space for the QR code is tracking the regulatory calendar; one that answers "we will deal with it then" usually starts reworking the tooling only when a customer pushes. To work through these in order, start with the free verification checklist. The previous article in this series is lighting rules; the next, textiles and apparel, is the opposite extreme, where one category carries three or four obligations that do not substitute for each other. To see how certifications and test reports are recorded, look at a report sample, or get in touch.