EvidencePass

(EU) 2023/1542

What you have already missed: battery regulation duties that started before the 2027 deadline

Almost everything you will read about the battery passport talks about 18 February 2027. That date is real, but it is also a trap: the regulation brought a series of duties into force earlier, and those are running today. Anyone building a plan around a single deadline misses them — and these are not minor formalities but requirements that reach into product design.

Why this happens at all

Regulation (EU) 2023/1542 has applied since 18 February 2024, and the passport is only one of its requirements, arriving eighteen months later. In between, the legislator introduced duties that the passport merely displays afterwards. Read only Article 77 and you see one date; read Articles 10, 13 and 48 and you see several.

Three kinds of deadline in one regulation

Some deadlines are absolute and written directly into the text. Others are conditional — they apply from a stated date or a number of months after a Commission act enters into force, whichever is the latest. A third kind is tied to the passport. Because they are interleaved in the text, a quick reading merges them into one.

Duties already running today

This list is computed from our rule set each time the page renders; it is not maintained by hand. Each item links to an explanation with article and evidence.

18 August 2025Responsible sourcing information from the due diligence reportLegal basis: Annex XIII(1)(d) · Article 52(3)Already applies since 18 August 2025 — a retroactive gap for most obligated parties.Field explained 18 August 2025Marking requirementsLegal basis: Annex XIII(1)(q) · Article 13(3) and (4)Already applies since 18 August 2025 — a retroactive gap for most obligated parties.Field explained 18 August 2024Rated capacity and capacity fadeLegal basis: Annex XIII(4)(a) -> Annex IV, Part A(1) · Article 10(1)Already applies since 18 August 2024 — a retroactive gap for most obligated parties.Field explained 18 August 2024Power and power fadeLegal basis: Annex XIII(4)(a) -> Annex IV, Part A(2) · Article 10(1)Already applies since 18 August 2024 — a retroactive gap for most obligated parties.Field explained 18 August 2024Internal resistance and its increaseLegal basis: Annex XIII(4)(a) -> Annex IV, Part A(3) · Article 10(1)Already applies since 18 August 2024 — a retroactive gap for most obligated parties.Field explained 18 August 2024Energy round trip efficiency and its fade, where applicableLegal basis: Annex XIII(4)(a) -> Annex IV, Part A(4) · Article 10(1)Already applies since 18 August 2024 — a retroactive gap for most obligated parties.Field explained 18 August 2024Expected lifetime under reference conditions, in cycles and calendar yearsLegal basis: Annex XIII(4)(a) -> Annex IV, Part A(5) · Article 10(1)Already applies since 18 August 2024 — a retroactive gap for most obligated parties.Field explained 18 August 2024State of health of the batteryLegal basis: Annex XIII(4)(b) -> Annex VII, Part A · Article 14Already applies since 18 August 2024 — a retroactive gap for most obligated parties.Field explained

What to do if you find a backlog

A backlog is no reason to panic, but it is a reason to set an order. First establish which of these requirements are properties of the product rather than documents — battery management system data and use logging are cases where nothing can be fixed retrospectively. Those decide what you can still place on the market at all. Only then turn to documents, which can be obtained later.

What this list deliberately omits

We do not list duties whose deadline depends on a Commission act whose status we have not verified at source. We would rather show less and stand behind every entry than lengthen the list with dates we cannot defend.

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