EU Battery Regulation 2027: removable batteries and QR codes

EU Battery Regulation 2027: what applies from 18 February

Regulation (EU) 2023/1542 applies directly in every member state and covers batteries built into products (Article 1(3)). It has applied since 18 February 2024, but many duties start later (Article 96(2)). Three start on 18 February 2027.

Removable and replaceable: what Article 11 requires

Article 11 binds whoever places a product with a built-in portable battery on the market: the non-EU manufacturer selling directly, or the EU importer. The whole battery, not single cells, must be readily removable and replaceable by the end-user throughout the product's lifetime (Article 11(1)).

• Tools: commercially available tools, which include basic tools or none; specialised tools only if supplied free of charge; no proprietary tools, heat or solvents (Article 11(1); Commission guidelines C/2025/214, section 2.1).
• Instructions and safety information on use, removal and replacement accompany the product and stay permanently on a public website (Article 11(1)).
• Spare batteries stay available for at least five years after the last unit of the model, at a reasonable and non-discriminatory price (Article 11(7)).
• Software must not block compatible batteries (Article 11(6) and (8)); the guidelines cite parts pairing (section 5).

LMT batteries, such as e-bike batteries, and their cells must be replaceable by independent professionals (Article 11(5)). The date applies per unit: products placed on the market from 18 February 2027 must comply even if the model is older; earlier units may still be sold (Blue Guide, section 2.3).

Exceptions: wet use, medical devices, continuous power

Replacement by independent professionals is enough for washable or rinseable appliances designed specifically to operate primarily under regular splashing, water jets or immersion, where safety requires it, and for certain medical devices (Article 11(2)). The guidelines cite toothbrushes and shavers and expect documented evidence that end-user replacement would compromise safety and no redesign is possible (section 3).

Article 11(3) exempts products needing a permanent connection for safety or, where collecting data is the main function, for data integrity (guidelines, section 4). For smartphones and tablets, Ecodesign Regulation (EU) 2023/1670 prevails (section 2.2).

QR code, label and battery passport: which battery needs what

From 18 February 2027, every battery carries a QR code, printed or engraved on the battery or, if its size or nature does not allow it, on packaging and accompanying documents (Article 13(6) and (7)). For LMT, industrial over 2 kWh and EV batteries, it opens the battery passport. For all others, it leads to the applicable label information, the declaration of conformity, the due diligence report where required and waste information under Article 74(1), kept complete, up to date and accurate (Article 13(6)).

The battery passport is an electronic record for each LMT battery, industrial battery over 2 kWh and EV battery placed on the market from 18 February 2027 (Article 77(1)); the operator placing the battery on the market keeps it accurate and up to date (Article 77(4)). It comes from the Battery Regulation, not from the GPSR.

CE marking and conformity assessment for batteries

Since 18 August 2024, every battery needs a conformity assessment, an EU declaration of conformity and CE marking (Articles 17 and 38(2) and (3); Article 96(2)(b)). For portable batteries, internal production control (module A) is available (Article 17(1)); a notified body is needed only for carbon footprint and recycled content (Article 17(2)).

The technical documentation includes a risk analysis (Annex VIII, Part A, point 2); the declaration is electronic, translated and kept up to date (Article 18(2)). Keep both for 10 years (Article 38(4); see who signs the EU Declaration of Conformity). As of 28 September 2026, the only listed harmonised standard, EN 18060:2025, covers EV batteries (Implementing Decision (EU) 2026/2048).

The battery's manufacturer is whoever makes it, or has it designed or made, and markets it under its own name or trademark (Article 3(1), point 33). Settle this with your pack supplier; cell and module suppliers must provide the necessary data free of charge (Article 39).

Two different representatives: Article 40 and Article 56(3)

The Authorized Representative (Article 40) acts for the manufacturer under a written mandate it accepts in writing: it keeps the declaration and technical documentation for 10 years, answers reasoned requests and cooperates with authorities (Article 40(3)). Design, due diligence and drawing up the technical documentation stay with the manufacturer (Article 40(2)). As Article 91 added batteries to Article 4(5) of Regulation (EU) 2019/1020, each battery needs an EU economic operator, such as an importer or Authorized Representative (Authorized Representative or importer).

The authorised representative for extended producer responsibility (Article 56(3)) is a separate waste law role. Producers selling batteries, including those in appliances, by distance contract directly to end-users in a member state where they are not established must appoint one there and register in each such state (Articles 3(1), point 47(d), and 55(2)), since 18 August 2025.

A Commission proposal (COM(2025) 981), before Parliament as of 28 September 2026, would extend this to direct sales by any means and move LMT replaceability from cell to module level.

Where the GPSR still applies to battery-powered products

A Bluetooth speaker is radio equipment under Directive 2014/53/EU (Article 2(1), point 1), and its battery falls under the Battery Regulation. Where such harmonisation legislation covers a risk, the General Product Safety Regulation (EU) 2023/988 steps back, and the obligations in Chapter III, Section 1 (Articles 9 to 18) do not apply (Article 2(1) GPSR). Three duties remain:

• Online offers name the manufacturer, the EU responsible person, a product identifier and warnings (Article 19; see where each address must appear).
• Accidents are notified through the Safety Business Gateway; for a non-EU manufacturer, the responsible person who learns of one ensures notification (Article 20(1) and (4)).
• Recalls follow the rules on recall notices and remedies (Articles 36 and 37).

What to do before 18 February 2027

1. 1.Classify each battery as portable, LMT, industrial, EV or SLI (Article 3(1)).
2. 2.Redesign units placed on the market from 18 February 2027: no heat or solvents, ordinary tools, compatible batteries, no software lock (Article 11).
3. 3.Document any derogation before placing on the market (guidelines, section 3).
4. 4.Publish removal instructions and plan spare batteries for five years (Article 11(1) and (7)).
5. 5.Plan the QR code: position, content, who updates it (Article 13(6) and (7)).
6. 6.Complete conformity per battery model with your supplier's data (Articles 17, 18, 38 and 39).
7. 7.Secure your EU roles: an EU economic operator and, for direct distance sales, registration and an EPR representative per member state (Articles 55 and 56(3)).

Practical example: an Asian maker of Bluetooth speakers

An Asian maker of Bluetooth speakers supplies an importer in the Netherlands and sells directly to consumers in Germany and France from its own shop.

For imported units, the Dutch importer places the speakers on the market and carries the Article 11 duty; only the maker can change the design.

Common mistakes with the Battery Regulation

• A passport for every battery. Only LMT, industrial over 2 kWh and EV batteries need one (Article 77(1)).
• Trusting the IP rating. Waterproof alone is no derogation under Article 11(2).
• One representative for everything. Article 40 and Article 56(3) describe different roles.

Conclusion: redesign now, document the exceptions

The EU Battery Regulation 2027 changes the product, not just the paperwork. Check designs and supplier data now; a new housing needs lead time.

Our compliance consulting builds a roadmap for your range, reviews your documentation and checks labels and packaging. Our CE marking service helps you identify the applicable legislation and harmonized standards and compile and review your technical documentation; design and declaration remain the manufacturer's responsibility. For extended producer responsibility, the competent authority of each member state keeps the producer register (Article 55).

Frequently asked questions