Pick up almost any product in a sourcing catalogue today and there is a battery in it. LED lamps, toys, fans, massage guns, earbuds, kitchen scales, pet trackers. In a large share of them the cell is glued in, soldered to the board and not meant to come out. From 18 February 2027 that design can no longer be placed on the EU market (source: Regulation (EU) 2023/1542, Article 11 and Article 96).
The Battery Regulation, Regulation (EU) 2023/1542, replaced the old Batteries Directive on 18 August 2025. Most articles about it are written for battery makers and car manufacturers. This one is written for the other group it hits: the importer or brand owner who buys finished consumer products in Asia and puts them on Amazon, Bol or a webshop. If that is you, the battery in your product is your battery under this regulation, and four sets of obligations land on your desk: the CE marking of the battery, the labels on it, the registration and fees for collection, and the removability rule that starts in February 2027.
E-bikes, e-scooters and other light means of transport have their own battery category with a battery passport; they are out of scope here.
1. The short answer
Four things apply to every consumer product with a battery, whether the battery is built in, supplied in the box or sold on its own.
Since 18 August 2024 the battery needs a CE marking with an EU declaration of conformity and technical documentation behind it, and it may not contain more than 0.01% lead (source: Regulation (EU) 2023/1542, Article 17 and Annex I). If you import the product from a factory outside the EU, you are the importer of that battery and you have to check that this is in order before you sell.
Since 18 August 2025 the producer responsibility rules apply: whoever first makes a battery available in a member state, including one inside a product, has to be registered there and pay for collection and recycling (source: Regulation (EU) 2023/1542, Chapter VIII).
From 18 August 2026 the battery has to carry the harmonised label with manufacturer, chemistry, capacity and other details, with the note that the exact format depends on a Commission implementing act; from 18 February 2027 a QR code comes on top (source: Regulation (EU) 2023/1542, Article 13).
From 18 February 2027 a portable battery in a product has to be readily removable and replaceable by the end user with commonly available tools, and spare batteries have to stay available for five years (source: Regulation (EU) 2023/1542, Article 11).
The first three are paperwork and labels. The fourth is a product design change, and it is the one that takes longest to fix through a supply chain in Asia.
| Date | What applies | Where in the regulation |
|---|---|---|
| 18 August 2024 | CE marking of the battery, lead limit of 0.01% | Article 17, Annex I |
| 18 August 2025 | Producer registration and fees per member state, crossed-out bin symbol | Chapter VIII, Article 13(4) |
| 18 August 2026 | Harmonised label, subject to the Commission implementing act | Article 13(1) and 13(10) |
| 18 February 2027 | QR code on the battery, battery removable and replaceable by the user | Article 13(6), Article 11 |
2. Which batteries this covers
The regulation covers every battery placed on the EU market, whether on its own or incorporated in a product, and it sorts them into five categories: portable, light means of transport (LMT), starting lighting and ignition (SLI), industrial and electric vehicle (source: Regulation (EU) 2023/1542, Article 1 and Article 3).
For consumer goods the relevant category is the portable battery: a sealed battery of five kilograms or less that is not designed for industrial use, not an EV battery, not an LMT battery and not an SLI battery. Within that group, a "portable battery of general use" is a standard format such as AA, AAA, 9V, C, D or a button cell (source: Regulation (EU) 2023/1542, Article 3(9) and 3(10)).
The practical point: it makes no difference whether the battery is soldered inside a toy, packed loose in the box of a remote control, or sold as a two-pack of AA cells. In all three cases the battery is placed on the EU market, and in all three cases the party doing that has obligations.
3. CE marking and the lead limit: in force since August 2024
Batteries have carried CE marking since 18 August 2024. Before that date the Batteries Directive had no conformity assessment at all, which is why so many product files from before 2024 contain a test report for the product but nothing for the cell inside it.
What CE marking on a battery means in practice: the battery manufacturer has run a conformity assessment, drawn up technical documentation and signed an EU declaration of conformity, and keeps both for ten years (source: Regulation (EU) 2023/1542, Articles 17, 18 and 38). The battery carries the CE mark, a type or batch number and the manufacturer's name and address, either on the battery or, where that is not possible, on its packaging or accompanying documents.
At the same date a lead limit came in: a portable battery may not contain more than 0.01% lead by weight. Zinc-air button cells are exempt until 18 August 2028. Mercury and cadmium were already restricted, at 0.0005% and 0.002% (source: Regulation (EU) 2023/1542, Annex I).
For an importer of finished products this translates into one question to ask the factory before the deposit: which cell is in this product, who made it, and can you send me that cell's EU declaration of conformity? A product test report to IEC 62133 or a UN 38.3 transport test is useful, but it is not the declaration. If the factory cannot name the cell manufacturer, that is the moment to stop, not after the container has landed.
4. Labels: what changes on 18 August 2026 and 18 February 2027
Article 13 of the regulation stacks three label requirements on top of each other.
The separate collection symbol, the crossed-out wheeled bin, has been mandatory since 18 August 2025 and follows the size rules of Annex VI Part B: at least 3% of the largest surface of the battery, up to 5 by 5 centimetres. Batteries containing more than 0.002% cadmium or 0.004% lead carry the chemical symbol Cd or Pb below the bin (source: Regulation (EU) 2023/1542, Article 13(4) and (5), Annex VI).
The harmonised label with general information applies from 18 August 2026: manufacturer, battery category, place and date of manufacture, weight, capacity, chemistry and hazardous substances (source: Regulation (EU) 2023/1542, Article 13(1) and Annex VI Part A). The regulation ties this date to a Commission implementing act that sets the format: the label applies from 18 August 2026 or 18 months after that act enters into force, whichever is later (source: Regulation (EU) 2023/1542, Article 13(10)). At the time of writing the Commission had consulted on the format in early 2026 but, as far as public sources show, not yet adopted it. So the August 2026 date has in practice moved, and the information itself is not in question, only the layout. Prepare the artwork with the Annex VI Part A fields now and adjust the format when the act lands.
From 18 February 2027 every battery carries a QR code that gives access to the label information and the declaration of conformity (source: Regulation (EU) 2023/1542, Article 13(6)). For a portable battery that is a link to a web page, not a battery passport; the passport only applies to LMT, EV and large industrial batteries.
Where the battery is too small for the label, the information goes on the packaging and the accompanying documents (source: Regulation (EU) 2023/1542, Article 13(7)). For a product with a built-in battery that means the product box and the manual, so the label work lands on the same artwork file as the GPSR information and the packaging rules.
5. The removability rule of 18 February 2027
This is the change that matters most for anyone sourcing finished electronics, and it has the least room to manoeuvre.
From 18 February 2027, any product with a portable battery must be designed so that the end user can remove and replace the battery at any time during the product's life (source: Regulation (EU) 2023/1542, Article 11(1)). "Readily removable" means with commercially available tools and without damaging the product or the battery; no specialised tools unless they are supplied free with the product, no heat, no solvents (source: Regulation (EU) 2023/1542, Article 11(1) and Commission guidelines C/2025/214). "Readily replaceable" means that a compatible battery keeps the product working and that batteries stay available as spare parts, at a reasonable price, for at least five years after the last unit of the model is placed on the market (source: Regulation (EU) 2023/1542, Article 11(7)).
The obligation sits with the party that places the product on the market. If the factory in Shenzhen designs it and you put your brand on it and sell it in the EU, that is you.
Two derogations exist, and they are narrow. Products designed for environments regularly subject to water splashing, streams or immersion, such as an electric toothbrush or a shaver, may have a battery that is removable only by an independent professional, provided user removal would compromise safety (source: Regulation (EU) 2023/1542, Article 11(2)). And products where continuity of power supply is needed for safety or data integrity, such as certain medical devices and payment terminals, are exempt (source: Regulation (EU) 2023/1542, Article 11(3)). A cheap pair of earbuds, a children's toy with a lithium cell, an LED table lamp or a massage gun does not fall under either.
The Commission's guidelines on the article were published on 10 January 2025 and are worth reading if you sell anything with a rechargeable cell. They define the end user as an adult without special skills or qualifications, and they describe what "commonly available tools" covers (source: European Commission, Guidelines on removability and replaceability of portable batteries, C/2025/214).
The rule applies to units placed on the market from 18 February 2027. Stock that is already in the EU before that date can be sold through. Everything that arrives after it must comply, so the design conversation with the factory has to happen in the coming months, not in January 2027.
6. Registration and fees: producer responsibility per country
Since 18 August 2025 the end-of-life rules of the regulation apply, and they follow the same logic as packaging and WEEE: whoever places a battery on the market in a member state for the first time is a producer there, registers in the national producer register, reports quantities and pays for collection and recycling (source: Regulation (EU) 2023/1542, Articles 55 and 56). A battery inside a product counts.
A producer that is not established in the member state has to appoint an authorised representative there for these obligations, so for a seller shipping to consumers in several countries this is a per-country task, exactly as it is for packaging (source: Regulation (EU) 2023/1542, Article 3(48) and Article 56). In the Netherlands the register is run through Stibat, in Germany through the register of stiftung ear under the Batteriegesetz, in France through the eco-organisations Corepile and Screlec.
The collection targets behind these fees are rising: 45% of waste portable batteries by the end of 2023, 63% by the end of 2027 and 73% by the end of 2030 (source: Regulation (EU) 2023/1542, Article 59). Member states will be pushed to close the gap, and that pressure ends up in the fees producers pay.
If you already handle packaging and WEEE registrations per country, batteries are a third stream next to those two, and it makes sense to set them up together. We handle EPR registration for packaging in Germany and France. If you sell there and need a battery registration as well, ask us and we will tell you what is possible.
7. What to ask the factory before you order
Most of the work above is upstream. This is the list to run through with a supplier before you confirm a product with a battery in it.
- Which cell is in the product, who manufactures it, and can they send the EU declaration of conformity and the CE technical documentation for that cell?
- Does the cell carry the CE mark, a batch number and the manufacturer's details, or is that information on the packaging?
- What is the lead, cadmium and mercury content, with the test report that shows it?
- Is the crossed-out bin symbol on the battery at the required size, or on the packaging if the battery is too small?
- Can the end user remove and replace the battery without heat, solvents or special tools? Ask for photos of the battery compartment, not a yes.
- Will the factory supply the same battery as a spare part for five years, and at what price?
- Which of the Annex VI Part A label fields can the factory print now, so the artwork is ready when the format is fixed?
A factory that answers these seven questions in writing is a factory you can build a technical file with. One that answers "CE OK" is not.
The battery questions belong in the same round as the rest of the product check. A product compliance check before the deposit is where they get asked, together with GPSR, packaging and labelling.
8. Conclusion
The Battery Regulation reaches importers of consumer products through the battery inside the product, and it does so in four steps: CE marking and the lead limit since 2024, producer registration since 2025, the harmonised label from 2026 onward once the format is fixed, and user-replaceable batteries from 18 February 2027. The first three are documents and artwork. The last one is a design change that has to be agreed with the factory before the next production run.
Put the seven questions above in your supplier checklist now, and treat a glued-in cell in a new product as a reason to look for another supplier.
Not sure whether the products you sell fall under the removability rule? Send us the product page or the supplier spec sheet through the contact page and we will tell you where you stand.
Sources
- Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 concerning batteries and waste batteries, amending Directive 2008/98/EC and Regulation (EU) 2019/1020 and repealing Directive 2006/66/EC. Articles 1, 3, 11, 13, 17, 18, 38 to 41, 54 to 59, 96; Annex I; Annex VI. OJ L 191, 28 July 2023.
- European Commission, Guidelines on the removability and replaceability of portable batteries and LMT batteries by end-users or independent operators, C/2025/214, published 10 January 2025.
- Regulation (EU) 2025/1561 of 18 July 2025 amending Regulation (EU) 2023/1542 as regards the application date of the due diligence obligations (postponed to 18 August 2027).
- CMS, EU Sustainable Batteries Regulation: where are we now?, November 2025.
- European Portable Battery Association (EPBA), EU Batteries Regulation timeline.
- Prodlaw, EU Battery Regulation: removability and replaceability requirements explained, February 2025.
