18 August 2026 and the EU Battery Regulation
Today is 18 August 2026. It’s the date written into Article 13 of Regulation (EU) 2023/1542 as the trigger point for harmonised battery labelling across the EU market.
But the picture is more nuanced than many compliance summaries suggest. Understanding exactly what today does and doesn’t change matters, because the deadline that carries the greatest practical urgency for EV and industrial battery manufacturers is actually six months away.
Here is the accurate position.
What Article 13 actually says about today’s date
The regulation sets out two conditions for when harmonised labelling becomes mandatory. Batteries must carry the full label information from Annex VI Part A, including capacity, battery category, chemistry and manufacturer details, from 18 August 2026 or 18 months after the date of entry into force of the implementing act referred to in Article 13(10), whichever is the latest.
The implementing act referred to in Article 13(10) is the European Commission’s harmonised specification for how battery labels must be formatted. The Commission was required to adopt it by 18 August 2025. It released a draft in December 2025 and expected formal adoption in Q2 2026, after a public consultation that ran until January 2026. As of today, we have not been able to confirm that the implementing act has been published in the Official Journal.
Why this matters
If the implementing act was published in, say, March 2026, the 18-month clock would put the effective labelling deadline around September 2027. If it was published in June 2026, the deadline falls around December 2027. The 18 August 2026 date in the regulation is therefore a floor, not a fixed ceiling. Many manufacturers planning for today may have more time than they thought for the harmonised label format specifically.We would strongly recommend checking the Official Journal of the European Union directly, or taking legal advice, to confirm the current effective date for your product category before assuming today is a hard compliance deadline for harmonised label format.What is definitely in force right now.
Two labelling requirements are not conditional on any implementing act and are already active.
- CE marking: required from 18 August 2024 for all batteries placed on the EU market. This one is long past.
- Separate collection symbol: required from 18 August 2025. All batteries must already bear the crossed wheelie bin symbol, covering at least 3% of the largest surface, up to 5x5cm.
Both of these are live. If your batteries don’t carry them, that is a current compliance failure regardless of the implementing act timing.
What is not delayed: the February 2027 deadline
Here is where the most important clarity lies. Multiple reputable sources, including Impala Services and EPBA Europe, explicitly note that the 18 February 2027 deadline for QR codes and Battery Passports carries no conditional trigger of this kind. It is fixed. It does not depend on an implementing act entering into force. It arrives on 18 February 2027, and for EV and industrial battery manufacturers, it represents a much more significant operational challenge than the harmonised label format.
18 February 2027; six months away
From this date, all batteries must carry a QR code linking to digital product information. For EV batteries, LMT batteries and industrial batteries above 2kWh, that QR code must link to a Digital Battery Passport containing structured data on carbon footprint, recycled content, state of health, raw material origins and recycling instructions. This deadline is fixed regardless of any implementing act timing.
The QR code must be printed or engraved visibly, legibly and indelibly on the battery. That word, indelible, is the one that matters for anyone currently using adhesive labels or inkjet codes. We’ve written about it in detail.
The deadline that has actually been delayed
Some of the confusion around ‘delays’ to the Battery Regulation comes from a genuine delay to a specific set of obligations that is often reported without enough precision. Regulation (EU) 2025/1561, published in July 2025, delayed the supply chain due diligence obligations from August 2025 to August 2027. These obligations require companies with annual turnover above 40 million euros to map and document their battery material supply chains for human rights and environmental risks, covering cobalt, lithium, nickel and graphite sourcing.
This delay is real and significant. But it has nothing to do with the physical marking and labelling requirements. Article 13 labelling, the QR code requirement, and the Battery Passport obligation are not affected by Regulation (EU) 2025/1561. If you have read that ‘the Battery Regulation has been delayed’, the chances are the source was referring to due diligence, not to marking and labelling.
The regulatory timeline: what applies when
This table reflects our best understanding of the current position. Given the implementing act uncertainty, we recommend verifying the harmonised label format deadline independently.
| Deadline | Requirement | Status |
| 18 August 2024 | CE marking affixed to all batteries placed on the EU market | PASSED |
| 18 August 2025 | Separate collection symbol mandatory on all batteries | PASSED |
| 18 August 2026 (or 18 months after the Article 13(10) implementing act enters into force, whichever is later) | Full harmonised labelling, including capacity information and general battery information per Annex VI Part A | THE REGULATORY DATE — actual effective date depends on implementing act |
| 18 February 2027 | QR code mandatory on all batteries; Digital Battery Passport for EV, LMT and industrial batteries above 2kWh. This date is fixed — not conditional on any implementing act. | SIX MONTHS |
| 18 August 2027 | Supply chain due diligence obligations (sourcing of cobalt, lithium, nickel, graphite). This deadline was extended from August 2025 by Regulation (EU) 2025/1561. | 14 MONTHS |
What to do with this information
The nuance around the implementing act does not reduce the urgency of preparing for February 2027. That deadline is fixed, it is six months away, and what it requires of the physical battery is demanding.
A laser-engraved or dot-peen QR code that will remain legible in a recycling facility in 2040 takes time to specify, procure and integrate into production. The data infrastructure to connect that physical code to a Battery Passport record is a software and process engineering project measured in months. If you haven’t started, the time to start is now.
If you are currently using adhesive labels to carry any battery identification or marking, you have a more immediate problem. Labels peel. They degrade under thermal cycling, chemical exposure and mechanical wear. They will not satisfy the indelibility requirement under Article 13(7), which applies to the QR code that must be on the battery from February 2027. For the full technical case against labels, read our earlier article.
- Confirm the current effective date for harmonised label format in your product category by checking the Official Journal or taking legal advice.
- Check that your batteries already carry CE marking and the separate collection symbol. Both are already required.
- Audit your current marking method against the indelibility standard. The question is whether it will remain visible and legible for the full service life of the battery, not just today.
- Start now on February 2027 compliance. Specifying, procuring and validating a laser marking system, and building the Battery Passport data connection, takes longer than six months from a standing start.
How we can help
We’ve been building permanent marking systems in Sheffield since 1849. EV battery marking brings together everything we know about high-volume automotive production, laser technology and demanding-environment durability.
Our fibre laser systems engrave QR codes and Data Matrix codes directly into battery housing surfaces. Our dot peen systems produce permanent identifiers on metal battery enclosures. Both produce marks that satisfy the indelibility requirement under Article 13(7). Our traceability software connects the marking station to your production data and, from there, to your Battery Passport data record.
If you’re working through what February 2027 compliance looks like for your production process, speak to our engineers. We’ve worked with automotive OEMs, battery manufacturers and tier one suppliers across the UK and internationally.
Get in touch
Call us on +44 114 276 6044 or email info@pryormarking.com. We’re based in Sheffield and we design and build every system ourselves, here.