EU Battery Regulation (EU) 2023/1542 and Digital Battery Passport: A Comprehensive Guide for Turkish Exporting Manufacturers

A new era: Transition from Directive to Regulation

The European Union has radically reformed its regulations on batteries. The old Battery Directive of 2006 (2006/66/EC) has been replaced by a directly applicable Regulation, the Battery Regulation (EU) 2023/1542. While a “directive” requires individual member states to transpose it into their national law, a “regulation” is binding simultaneously and uniformly throughout the EU. For manufacturers, this means a single set of rules instead of 27 different national pieces of legislation.

The regulation covers the entire life cycle of a battery: from the supply of raw materials to design, production, market launch, use, collection, and recycling. The aim is to make batteries on the EU market more sustainable, more traceable, and more compatible with the circular economy. The obligations are not introduced all at once, but rather gradually over several years.

• Old framework: Directive 2006/66/EC (transmitted into national law by member states)
• New framework: Regulation (EU) 2023/1542 (directly binding throughout the EU)
• Scope: all aspects including raw materials, design, production, use, collection, and recycling.
• Implementation logic: not all at once, but with a phased schedule.

Who will be affected?

The regulation covers almost every type of battery placed on the EU market. It divides batteries into five categories and differentiates some of the obligations according to these categories. Therefore, the first answer to the question "Does this apply to me?" is to determine which category your product falls into.

The crucial point is this: the regulation holds accountable whoever puts the battery on the EU market. Even if you ship your product through an EU importer or distributor, it is the responsibility of your supply chain to ensure that the product complies with the regulation and that the necessary technical documentation is available. Furthermore, if your device has a built-in battery (e.g., in an electronic device, power tool, or light vehicle), that battery also falls under the scope of the regulation.

• Portable batteries — generally ≤5 kg, found in most consumer devices.
• SLI batteries — vehicle starter, lighting and ignition batteries (like lead-acid batteries)
• Light vehicle batteries (LMT) — for vehicles such as e-bikes and e-scooters.
• Industrial batteries — for industrial and energy storage applications.
• EV (electric vehicle) batteries — hybrid and electric vehicle traction batteries
• Device manufacturers that incorporate batteries will also be indirectly affected.

Basic obligations

The regulations govern both the environmental footprint of batteries and their practical aspects for both users and recyclers. These obligations come into effect according to category and schedule; they do not all apply simultaneously to every battery. The following headings are the main groups of obligations introduced by the regulations.

Some of these obligations (particularly carbon footprint and recycled content thresholds) depend on supplementary methods (delegation and implementation measures) to be issued by the European Commission. As these supplementary methods are delayed, the relevant implementation dates may also be postponed. Therefore, it is necessary to follow current EU announcements when planning the exact implementation date.

• Carbon footprint declaration: Calculation and declaration of footprint for EV, industrial and LMT batteries (phased schedule, subject to complementary methods)
• Recycled content: declaration first, then minimum percentage thresholds for cobalt, lead, lithium and nickel (phased out after 2028)
• Performance and durability: minimum performance and lifespan criteria for specific battery types.
• Detachability and replaceability: portable batteries can be easily removed and replaced by the end user.
• Mandatory collection, recycling targets and extended producer responsibility (EPR)
• Information access via labeling, CE mark and QR code.

What is a Digital Battery Passport?

The Digital Battery Passport (DBP) is a unique, electronically recorded identity for each battery. Accessed via a QR code on the battery, it contains data such as the battery's origin, composition, carbon footprint, recycled content percentage, performance/durability data, and end-of-life information. The aim is to ensure transparency and traceability throughout the supply chain, making it easier for users, repairers, and recyclers to access accurate information.

The Passport is the most talked-about innovation of the regulation because it requires a continuously updated data infrastructure linked to a physical product. This obliges manufacturers to start collecting product, supply, and sustainability data in an organized manner from today. The Passport obligation is initially primarily for EV batteries, light vehicle (LMT) batteries, and industrial batteries with a capacity exceeding 2 kWh.

The information presented in this article is for informational purposes only and does not constitute a commitment to any certification, conformity assessment, or CE marking service. It is recommended that you evaluate how your passport and conformity obligations apply to your product with an authorized conformity assessment body and your legal advisor.

• Electronic identification system for the battery, accessed via QR code.
• Content: origin, composition, carbon footprint, recycled ingredients, performance, and end-of-life information.
• Initial scope: EVs, LMTs, and industrial batteries above 2 kWh.
• Impact on the producer: structuring product and sustainability data from today.

Important dates

The regulation entered into force on 17 August 2023, and general application began on 18 February 2024. The period after that is a phased timetable. The dates below are nominal dates in the regulation text; however, some obligations, such as carbon footprint and recycled content, may be postponed in practice as they depend on the publication of supplementary methods to be issued by the Commission.

For Turkish manufacturers, the clearest and most critical date today is February 18, 2027: on this date, the Digital Battery Passport (with QR code) will be activated for certain batteries, and the obligation to remove/replace portable batteries will also be implemented on the same date.

• August 17, 2023 — The regulations entered into force.
• February 18, 2024 — General implementation began.
• August 18, 2025 — The old Directive 2006/66/EC ceased to exist (approximately two years later)
• February 18, 2025 (nominal) — Carbon footprint declaration for EV batteries (may be postponed due to delay in the supplementary method)
• February 18, 2026 (nominal) — Carbon footprint declaration for rechargeable industrial batteries over 2 kWh.
• February 18, 2027 — Digital Battery Passport + QR code (EV, LMT and industrial batteries over 2 kWh) and detachability/replaceability in portable batteries.
• August 18, 2028 and onwards — Recycled content declaration; minimum thresholds will come into effect gradually from 2031 onwards.

What does this mean for Turkish manufacturers?

The EU is Türkiye's largest export market, and batteries and battery-powered electrical appliances constitute a significant part of this trade. The regulation applies to every battery placed on the EU market, regardless of where it is manufactured. Therefore, the real question for a Turkish manufacturer should not be "Does this apply to me?", but rather "Which category do I fall into and what do I need to have ready by what date?".

Practical preparation begins with data. Carbon footprint, recycled content, and supply chain traceability can only be addressed with data collected starting today. The Digital Battery Passport, in particular, requires data that is difficult to collect retrospectively (raw material origin, composition, production carbon footprint), so manufacturers who start early will have an advantage. Clarifying responsibility sharing at the contractual level with your EU importer/distributor partners is also a critical step.

Finally: this regulation is a living code with technical and legal layers, evolving through complementary methods. The most reliable approach is to plan by confirming the exact implementation dates and product-specific obligations with up-to-date EU resources and through your authorized consultants.

• Clarify which of the five categories your product falls into.
• Start collecting carbon footprint and recycled content data today.
• Configure your product and supplier data for the Digital Battery Passport.
• Clarify compliance responsibilities with EU importers/distributors through contracts.
• Follow the latest EU announcements regarding the dates related to complementary methods.

Frequently Asked Questions

Does the Battery Regulation only concern battery manufacturers?

No. The regulation applies to batteries placed on the EU market, and also indirectly affects manufacturers of devices with embedded batteries. Importers and distributors also bear responsibility in the compliance chain. Even if you are shipping your product through an EU partner, it is the responsibility of your supply chain to ensure that the necessary technical documentation and data are available.

When will the Digital Battery Passport become mandatory?

According to the regulation, as of February 18, 2027, a Digital Battery Passport will become mandatory for certain batteries (EV, light vehicle/LMT, and industrial batteries with a capacity exceeding 2 kWh), accessible via QR code. This is one of the clearest and most critical dates in the regulation to date.

Why are carbon footprint dates said to be 'postponable'?

Some obligations, such as carbon footprint declarations, are contingent upon supplementary regulations to be issued by the European Commission, such as the calculation method and declaration format. Delays in these supplementary methods can effectively postpone the relevant implementation dates. Therefore, nominal dates should be evaluated in conjunction with the latest EU announcements.

Is the old Battery Directive (2006/66/EC) still valid?

No. The new regulation (EU) 2023/1542 has replaced the old directive, which ceased to exist as of 18 August 2025. A single, directly binding set of rules now applies throughout the EU.

Does AES provide battery certification or CE marking in this regard?

No. This content is for objective informational purposes only. AES is a Type A electrical inspection body accredited by TÜRKAK; its scope is electrical inspection. It does not undertake battery product certification, conformity assessment, or CE marking. It is recommended that you evaluate your product-specific conformity obligations with an authorized conformity assessment body and your legal advisor.

This content is for informational purposes only and does not constitute legal opinion or compliance assessment. The current official legislation text (EUR-Lex) should be used for precise requirements.