(EU) 2023/1542

What you do not owe yet: battery passport duties that have not fallen due

This guide exists because the rest of the market argues the opposite. Vendors like to sell preparation for every field at once, because a bundle is easier to invoice than a distinction. But the regulation does not fall due all at once, and some fields do not fall due before the end of the decade. If you are paying today to prepare data you will need in 2033, you are paying too early.

A conditional deadline is not a delay, it is uncertainty

Where the regulation says something applies from a stated date or a number of months after a Commission act enters into force, whichever is the latest, there is no absolute date. That is not the same as “later”. It means the date cannot be stated today — and anyone who quotes you one has chosen it themselves.

Why we still put it in the contract

Not owing a field yet does not mean ignoring it. Supply contracts run for years. A clause about data that falls due in 2028 costs nothing today; in 2028 it is a negotiation. The distinction is between when you pay for preparation and when you secure access.

Fields that have not fallen due

Computed from the rule set at render time. Where no absolute date exists we do not state one; we state the condition.

conditionalCarbon footprint informationLegal basis: Annex XIII(1)(c) · Article 7(1) and (2)The deadline depends on a delegated or implementing act, so no absolute date can be confirmed. Applies from 18 February 2026 or 18 months after the act enters into force — whichever is later.Field explained conditionalRecycled content informationLegal basis: Annex XIII(1)(e) · Article 8(1)The deadline depends on a delegated or implementing act, so no absolute date can be confirmed. Applies from 18 August 2028 or 24 months after the act enters into force — whichever is later.Field explained

How to use this when reviewing a quote

When you receive a quote for battery passport preparation, ask which fields are in the price and when each one falls due. If the vendor cannot answer field by field, they are selling a bundle rather than work. This is not a test of the vendor's honesty but of whether they know the difference at all.

The limit of this guide

A field not being due does not mean you will never need it. It means it is not on the critical path today. When a delegated or implementing act is adopted, a conditional deadline becomes an absolute one — and our regulatory watcher exists precisely so that this is noticed before you notice it.

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