When do the EU battery labelling requirements actually apply?

Article 13 of Regulation (EU) 2023/1542 sets out what must appear on a battery placed on the EU market: the general information in Part A of Annex VI, capacity for rechargeable portable, LMT and SLI batteries, and minimum average duration plus the words “non-rechargeable” for non-rechargeable portable batteries.

The date usually given for all three is 18 August 2026. That is half of what the Regulation says.

The full wording

Each of those three obligations applies from 18 August 2026 or 18 months after the date of entry into force of the implementing act referred to in paragraph 10, whichever is the latest.

The phrase appears three times in Article 13, once for each obligation. It is not a footnote or a transitional provision. It is the operative text.

The implementing act was due in August 2025

Article 13(10) requires the Commission to adopt implementing acts establishing harmonised specifications for those labelling requirements by 18 August 2025.

The Commission published a draft implementing regulation covering both the Article 7 carbon footprint label and the Article 13 labelling requirements, with a consultation running from 15 December 2025 to 26 January 2026. Industry bodies including SolarPower Europe and the Battery Storage Europe Platform, DIGITALEUROPE and the Japan Business Council in Europe submitted responses. Reporting at the time expected adoption in the second quarter of 2026.

What that means for the date

Eighteen months before 18 August 2026 is 18 February 2025. The implementing act was still in draft in December 2025, so it cannot have entered into force before that point.

It follows that eighteen months after its entry into force falls later than 18 August 2026. Under the plain wording of Article 13, the later date governs.

What is already in force, and is not conditional

None of this touches the labelling obligations that already apply and carry no condition.

From 18 August 2025, all batteries must carry the separate collection symbol set out in Part B of Annex VI. Batteries containing more than 0.002 per cent cadmium or more than 0.004 per cent lead must carry the chemical symbol for that metal. Capacity marking carried over from the repealed Batteries Directive continues to apply.

From 18 February 2027, all batteries must be marked with a QR code under Article 13(6).

What the draft would require

The draft sets a common core across battery categories: manufacturer details and a unique identifier for the model or lot, place and date of manufacture, mass, electrochemical composition under a harmonised nomenclature, restricted or hazardous substances, a suitable extinguishing agent in case of fire, and critical raw materials present above a threshold.

It also addresses presentation, specifying the font, minimum text sizes and margins, and requiring the label to cover at least 5 per cent of the largest printable or markable surface. Where the battery cannot carry the full information, it may move to the packaging or accompanying documentation with a QR code providing access.

Why this matters in both directions

If you built your compliance programme around 18 August 2026, you have probably not missed anything, because the obligation is unlikely to have started.

If you have read the condition as an open-ended reprieve, that is also wrong. Eighteen months is a fixed period that begins the moment the act enters into force, and the specifications are already drafted. The work does not get easier for having been deferred.

What we could not establish

Whether the implementing act has been adopted, and if so on what date. We found the draft and the consultation but no record of adoption or publication in the Official Journal. That single fact sets the real deadline.

We also cannot rule out an earlier implementing act under Article 13(10) that we have not found, which would change the arithmetic. The Commission consulting on a draft in December 2025 is strong evidence against one, but it is not proof.

If you know the answer to either, we would like to hear it.

See every other date in the EU Batteries Regulation Calendar.