The EU Battery Regulation for trucks and buses: which batteries, which duties, which dates

Regulation (EU) 2023/1542 on batteries and waste batteries has applied in every EU Member State since 18 February 2024, and it treats the traction battery of an electric or hybrid truck, bus, coach or trailer as an “electric vehicle battery”: its definition names vehicle categories M, N and O. For those batteries a performance and durability document and state-of-health data in the battery management system have been required since 18 August 2024, producer registration and free take-back since 18 August 2025, and a QR code with a battery passport is required from 18 February 2027. Due diligence on cobalt, natural graphite, lithium and nickel starts on 18 August 2027 for economic operators above a turnover threshold, after Regulation (EU) 2025/1561 moved it back by two years. The carbon footprint declaration and the new labels have no fixed start date, because the Commission acts they depend on had not been adopted on 6 October 2026. A truck’s starter battery is an “SLI battery”: it gets labels, a QR code and free take-back, but no passport.

Status as of 6 October 2026. Read that day: the Official Journal text of Regulation (EU) 2023/1542 and the EUR-Lex consolidated text of 13 August 2026; the three Regulations that have amended it, (EU) 2024/1781, (EU) 2025/1561 and (EU) 2026/1738; the EUR-Lex records of acts amending or based on it; the European Commission’s “Have your say” records for the acts still pending; and the European Parliament’s Legislative Observatory files for the amending proposals. The consolidated text is a documentation tool without legal effect; article numbers below are those of the Regulation.

The obligations and their dates at a glance

Which batteries in trucks, buses and trailers are covered

The Regulation applies to all categories of batteries “regardless of their shape, volume, weight, design, material composition, chemistry, use or purpose”, including batteries incorporated into products (Article 1(3)). What a battery must do depends on its category, and three of the five categories matter for trucks, buses and trailers.

Electric vehicle battery. Article 3(1)(14) covers “a battery that is specifically designed to provide electric power for traction in hybrid or electric vehicles of categories M, N or O as provided for in Regulation (EU) 2018/858”. The same definition sets a weight condition of more than 25 kg, but only for vehicles of category L. Article 4(1) of Regulation (EU) 2018/858 defines category M as motor vehicles designed and constructed primarily for the carriage of passengers, with M2 and M3 having more than eight seating positions besides the driver’s and a maximum mass up to and above 5 tonnes respectively; category N as goods vehicles, with N2 above 3.5 tonnes up to 12 tonnes and N3 above 12 tonnes; and category O as trailers. The traction battery of a battery-electric or hybrid truck, city bus or coach is therefore an electric vehicle battery, and so is a battery specifically designed to provide traction power in a hybrid or electric trailer.

SLI battery. Article 3(1)(12) defines a starting, lighting and ignition battery as one “specifically designed to supply electric power for starting, lighting, or ignition and that can also be used for auxiliary or backup purposes in vehicles, other means of transport or machinery”.

Industrial battery. Article 3(1)(13) includes “any other battery that weighs more than 5 kg and that is neither an electric vehicle battery, an LMT battery, nor an SLI battery”. A battery on a vehicle that is designed neither for traction nor for starting, lighting or ignition is thus measured against this definition. For industrial batteries the passport applies above a capacity of 2 kWh, and the carbon footprint rules apply to rechargeable industrial batteries above 2 kWh.

Where a battery can be considered to fall under more than one category, it is deemed to fall under the category with the strictest requirements for the purposes of Chapter II, the sustainability and safety chapter (Article 1(3)).

What already applies: documents, battery data, conformity and collection marks

Performance and durability document. Since 18 August 2024 electric vehicle batteries “shall be accompanied by a document containing values for the electrochemical performance and durability parameters set out in Part A of Annex IV” (Article 10(1)). Part A lists rated capacity in Ah and capacity fade, power and power fade, internal resistance and its increase, where applicable energy round trip efficiency and its fade, and the expected lifetime in cycles and calendar years. The technical documentation must explain how the values were measured, including the discharge and charge rates and the depth of discharge in the cycle-life test (Part B). Article 10 provides for minimum values, to be laid down in delegated acts, only for rechargeable industrial batteries above 2 kWh and for LMT batteries (paragraphs 2, 3 and 5); for electric vehicle batteries the duty is the document.

State-of-health data. Since the same date the battery management system of an electric vehicle battery must hold up-to-date data for the parameters of Annex VII (Article 14(1)); for electric vehicle batteries Annex VII names one parameter, “state of certified energy (SOCE)”. Read-only access to those data is given to the person who has legally purchased the battery, including independent operators, for purposes listed in Article 14(2), such as evaluating residual value or remaining lifetime. Article 14(5) states that the Article applies in addition to vehicle type-approval law. How these provisions relate to the state-of-health thresholds in makers’ warranty terms is set out in how electric truck battery warranties are defined.

Conformity. Conformity assessment (Article 17) and the obligations of manufacturers, importers and distributors (Chapter VI) have applied since 18 August 2024 (Article 96(2)(b)); the exception is Article 17(2), on assessing compliance with Articles 7 and 8, which applies 12 months after the first publication of the list of notified bodies. The EU declaration of conformity states that compliance with Articles 6 to 10, 12, 13 and 14 has been demonstrated (Article 18(1)), and the CE marking is affixed before the battery is placed on the market or put into service (Article 20(2)).

Marks and substances. Since 18 August 2025 all batteries have had to carry the separate collection symbol (Article 13(4)). Batteries containing more than 0.002 % cadmium or more than 0.004 % lead are also marked Cd or Pb beneath it (Article 13(5)). Annex I limits mercury to 0.0005 % by weight in all batteries, “whether or not present in and incorporated into appliances, light means of transport or other vehicles”.

Producer responsibility and free take-back since 18 August 2025

Chapter VIII, on waste batteries, has applied since 18 August 2025 (Article 96(2)(c)). The Regulation’s definition of “producer” extends to batteries “incorporated in appliances, light means of transport or other vehicles”: among others, it covers anyone established in a Member State who “supplies for the first time in that Member State on a professional basis” such batteries from another Member State or a third country (Article 3(1)(47)(c)). Producers register in each Member State where they first make batteries available, and may make them available there, “including those incorporated in appliances, light means of transport or other vehicles”, only once registered (Article 55(2)); the application names the battery category and chemistry (Article 55(3)(c)).

Producers of SLI, industrial and electric vehicle batteries, or the producer responsibility organisation they appoint, “shall take back, free of charge and without an obligation on the end-user to buy a new battery, nor to have bought the battery from them” all waste batteries of the category they first made available in that Member State, “regardless of their nature, chemical composition, condition, brand, or origin” (Article 61(1)). Their financial contributions cover separate collection, transport and treatment, among other costs (Article 56(4)). Distributors take back waste SLI, industrial and electric vehicle batteries at or in the vicinity of their retail outlet (Article 62(1)(b)), limited to the categories they have or had in their offer (Article 62(2)(b)), and treatment facilities for end-of-life vehicles hand over the waste batteries they remove to producers, producer responsibility organisations or selected waste management operators (Article 65(1)).

The QR code and the battery passport from 18 February 2027

From 18 February 2027 all batteries “shall be marked with a QR code” (Article 13(6)). For an electric vehicle battery, or an industrial battery above 2 kWh, the code leads to the battery passport; for an SLI battery it leads to the label information, the declaration of conformity, the due diligence report, the waste information of Article 74 and the amount of cobalt, lead, lithium or nickel recovered from waste in its active materials.

Article 77(1): “From 18 February 2027 each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market or put into service shall have an electronic record (‘battery passport’).” Responsibility lies with the economic operator placing the battery on the market. It attributes the unique identifier to which the QR code links, with the QR code and identifier complying with the ISO/IEC 15459 series or their equivalent (Article 77(3)), and it “shall ensure that the information in the battery passport is accurate, complete and up to date”, with the option of authorising another operator in writing to act on its behalf (Article 77(4)). Under Article 77(10), added by Regulation (EU) 2024/1781, the operator placing the battery on the market or putting it into service uploads the unique identifier to the digital product passport registry of that Regulation, which its Article 13(1) required the Commission to set up by 19 July 2026.

The rated capacity in the passport is a figure in ampere-hours under reference conditions (Annex IV), not the kWh figures in truck data sheets; those are explained in installed vs usable battery capacity. A battery that is repurposed or remanufactured gets a new passport linked to the original one, and the duty passes to the operator who places it on the market; when the battery becomes waste the duty passes to the producer, the producer responsibility organisation or the selected waste management operator (Article 77(7)). The passport “shall cease to exist after the battery has been recycled” (Article 77(8)).

Who counts as a person with a legitimate interest is left to an implementing act that Article 77(9) required by 18 August 2026. The Commission’s record for it, read on 6 October 2026, lists the initiative as planned, with adoption scheduled for the fourth quarter of 2026. Annex XIII also lists carbon footprint information among the public items, and the Regulation includes passport information “to the extent applicable to the category or sub-category of battery concerned” (Article 77(2)); the texts read for this page do not say how a passport shows carbon footprint data before Article 7 applies.

Carbon footprint: in the Regulation, waiting for the Commission

Article 7(1) requires a carbon footprint declaration “for each battery model per manufacturing plant”. It contains administrative information on the manufacturer, the battery model, the location of the plant, the carbon footprint “calculated as kg of carbon dioxide equivalent per one kWh of the total energy provided by the battery over its expected service life”, the footprint by life-cycle stage, the identification number of the EU declaration of conformity and a web link to a public version of the supporting study. Annex II defines that total energy as the number of cycles multiplied by the energy delivered in each cycle, and allows a different functional unit in exceptional cases, “such as for batteries for hybrid non-plug-in vehicles”.

For electric vehicle batteries the declaration applies from “18 February 2025 or 12 months after the date of entry into force either of the delegated act or of the implementing act”, whichever is latest; the Commission was to adopt both by 18 February 2024. The Commission’s records, read on 6 October 2026, list the methodology delegated act and the format implementing act at the draft stage, after a feedback period from 30 April to 28 May 2024; the planned adoption periods they give, the third quarter of 2025 and the second quarter of 2026, have passed. EUR-Lex lists no adopted act. The start date therefore depends on acts not yet adopted.

Two further steps follow the same pattern. A label with the carbon footprint performance class applies from 18 August 2026 or 18 months after the acts establishing the classes and the label format enter into force, whichever is latest (Article 7(2)); the Commission’s record for the classes lists the initiative as planned, with adoption in the fourth quarter of 2026. A maximum life-cycle carbon footprint applies from 18 February 2028 or 18 months after the delegated act setting it enters into force, whichever is later (Article 7(3)); that act was due by 18 August 2026, and the Commission’s list of battery initiatives read for this page contains no record for it.

Recycled content and the new labels

From 18 August 2028, or 24 months after the methodology delegated act enters into force if that is later, electric vehicle batteries, SLI batteries and industrial batteries above 2 kWh (except those with exclusively external storage) “that contain cobalt, lead, lithium or nickel in active materials” must be accompanied by documentation on the share of those metals recovered from waste, per battery model, year and plant (Article 8(1)). The delegated act was due by 18 August 2026; the Commission published a draft for feedback from 12 August to 9 September 2026, and its record gives the third quarter of 2026 for adoption. The minimum shares themselves are written into Article 8 with fixed dates: 16 % cobalt, 85 % lead, 6 % lithium and 6 % nickel from 18 August 2031, and 26 % cobalt, 85 % lead, 12 % lithium and 15 % nickel from 18 August 2036. Which chemistries truck makers state for their packs, and so which of these metals they contain, is covered in battery chemistries in heavy trucks.

The general label of Article 13(1) lists the manufacturer, the battery category and identification, the place and date of manufacture, the weight, the capacity, the chemistry, hazardous substances other than mercury, cadmium or lead, the usable extinguishing agent and critical raw materials above 0.1 % (Annex VI, Part A). SLI batteries also carry a capacity label (Article 13(2)). Both apply from “18 August 2026 or 18 months after the date of entry into force of the implementing act referred to in paragraph 10, whichever is the latest”. That act was due by 18 August 2025; the Commission’s draft was open for feedback from 15 December 2025 to 26 January 2026, and EUR-Lex lists no adopted act. Because 18 August 2026 has passed, the labels become mandatory 18 months after the act enters into force.

Due diligence: what Regulation (EU) 2025/1561 changed

Regulation (EU) 2025/1561 of 18 July 2025 amends only Article 48. In paragraph 1 it replaces “18 August 2025” by “18 August 2027”; in paragraph 5 it replaces “18 February 2025” by “26 July 2026”. It entered into force on the day after its publication in the Official Journal of 30 July 2025. Its recitals give the reasons: the designation of notified bodies “is taking longer than expected”, and the dates for the Commission’s guidelines should be harmonised with those under Directive (EU) 2024/1760 on corporate sustainability due diligence. It does not touch the passport or QR code dates.

As amended, Article 48(1) reads: “From 18 August 2027, economic operators that place batteries on the market or put them into service shall fulfil the due diligence obligations”. The policies cover the raw materials of Annex X, cobalt, natural graphite, lithium and nickel and their compounds needed for active materials. They are verified and periodically audited by a notified body (Article 48(2)), documentation is kept for 10 years after the last battery made under the policy has been placed on the market (Article 48(3)), and the operator publishes a report on its policy each year (Article 52(3)). Chapter VII does not apply to economic operators with a net turnover below EUR 40 million in the financial year preceding the last one that are not part of a group exceeding that limit on a consolidated basis (Article 47). Article 48(5) required the Commission to publish guidelines by 26 July 2026; whether they had been published could not be confirmed from the official sources read for this page.

Removal from the vehicle, and what Regulation (EU) 2026/1738 amends

The Battery Regulation’s removability and replaceability rule, Article 11, concerns portable batteries and LMT batteries and applies from 18 February 2027 (Article 96(2)(a)); it does not cover electric vehicle batteries. Their removal from vehicles is addressed in the End-of-Life Vehicles Regulation (EU) 2026/1738, which applies to vehicles of categories M2, M3, N2, N3 and O from 1 September 2031 (Article 2(1)(c)) and lists in Article 2(3) the provisions that do not apply to them. Article 7, under whose paragraph 2 each vehicle of a new type type-approved from 1 September 2032 under Regulation (EU) 2018/858 “shall be designed to enable, in a readily and non-destructive manner, the removal and replacement of electric vehicle batteries and their battery packs”, and Article 11, on information for the removal and replacement of electric vehicle batteries and other parts, are not on that list. How those articles will work in the type-approval of heavy vehicles is beyond this page.

Regulation (EU) 2026/1738 amends the Battery Regulation in one place: Article 53 replaces the table in Annex I, with effect from 13 August 2026 (Article 59(2)). The new entries limit cadmium, lead and hexavalent chromium in batteries incorporated in vehicles of categories M1 and N1, with exemptions such as SLI batteries in 12 V applications. None of the new entries names categories M2, M3, N2, N3 or O; the mercury limit for all batteries and the cadmium and lead limits for portable batteries remain.

Buses bought by public authorities

Article 85 requires contracting authorities and contracting entities, when procuring “batteries or products containing batteries” under the public procurement directives, to take account of the environmental impacts of those batteries over their life cycle. Award criteria become binding 12 months after the first delegated act setting them enters into force, and the Commission adopts that act 12 months after the latest of the delegated acts under Articles 7(2), 8(1), 9(2) and 10(5), none of which had been adopted on 6 October 2026. The Commission’s proposal for a Public Procurement Act, COM(2026) 590 of 9 September 2026, would delete Article 85; references to it would be read as references to Article 54 of the new act. The vehicle-side procurement rules for buses are covered in the Clean Vehicles Directive and public bus procurement.

Amendments proposed but not adopted

The Commission proposals are the texts as tabled; the agreed texts approved in committee were not available to this page, and the adopted wording may differ.

The Commission regulations under the Battery Regulation that EUR-Lex records as published in the Official Journal by 6 October 2026 concern recyclers and Member States rather than vehicle or battery makers: Delegated Regulation (EU) 2025/606 sets the method for calculating recycling efficiency and the recovery of materials from waste batteries, and Implementing Regulation (EU) 2025/2289 sets the format in which Member States report collection and treatment data. Access to repair information for the vehicle as a whole comes from type-approval law, set out in repair information access rights.