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Battery Regulation 2023/1542 — article-by-article coverage

Five Battery Regulation articles map to the TracePass battery passport schema. Each article shows the requirement, the TracePass fields that satisfy it, and a status flag where an implementing act is still refining the detail.

Regulation (EU) 2023/1542 of the European Parliament and of the Council concerning batteries and waste batteries

Status

  • Modeled

    First-class fields in the schema; no further implementing-act dependency.

  • Partial

    Modeled to draft, but an implementing act continues to refine methodology or thresholds.

  • Pending act

    Not modeled; awaiting the implementing act before we add fields.

Article 6

Carbon footprint

Partial

Tell buyers how much CO₂ your battery's whole life puts in the air, broken down by stage, with a link to your study and a class rating.

Requirement

Carbon footprint declaration for electric-vehicle, light-means-of-transport (LMT), and rechargeable industrial batteries above 2 kWh: total CF and per-lifecycle-stage breakdown, plus a study URL and a performance class.

TracePass fields

  • carbonFootprintTotal
  • cfRawMaterialAcquisition
  • cfMainProductProduction
  • cfDistribution
  • cfEndOfLifeRecycling
  • carbonFootprintPerformanceClass
  • carbonFootprintStudyUrl
  • carbonFootprintLabel

Notes

Implementing Regulation (EU) 2024/1564 sets the calculation methodology and the performance-class boundaries; both can shift in subsequent amendments. The schema captures the data points already; values declared against an older methodology stay valid until the customer republishes.

EUR-Lex

Article 7

Recycled content

Modeled

Say what share of the cobalt, lithium, nickel, and lead in your battery came from recycling, and back it up with proof.

Requirement

Declared recycled content for cobalt, lithium, nickel, and lead in industrial, EV, and SLI batteries — supported by documentation that the recycled fraction is verifiable.

TracePass fields

  • recycledContentCobalt
  • recycledContentLithium
  • recycledContentNickel
  • recycledContentLead
  • recycledContentDocumentation

Notes

Threshold percentages step up over time (notably from August 2031 and again from 2036 for EV batteries). The schema stores declared values; the verification of compliance against the active threshold is a customer responsibility, not a vendor one.

EUR-Lex

Article 11

Removability and replaceability

Modeled

Users must be able to take the battery out and swap it themselves. Document how to remove it, what spare parts are available, and how to handle it safely at end of life.

Requirement

Portable batteries shall be readily removable and replaceable by end-users — with documentation on removal procedure, dismantling, available spare parts, and end-of-life safety.

TracePass fields

  • batteryRemovabilityReplaceability
  • removalInformation
  • dismantlingInformation
  • sparePartsInformation
  • safetyInformationEndOfLife
EUR-Lex

Article 14

State of health and lifetime

Partial

Track how the battery is aging — health, remaining capacity, how it's been charged, what temperatures it's seen — and make that data available to the right people for the battery's entire life.

Requirement

For industrial batteries above 2 kWh and EV batteries: state-of-health, remaining capacity, fade values, charging history, and historical thermal conditions — accessible to authorised parties throughout the battery's life.

TracePass fields

  • stateOfHealth
  • stateOfCertifiedEnergy
  • remainingCapacity
  • remainingPowerCapability
  • remainingEnergy
  • currentInternalResistancePack
  • internalResistanceIncrease
  • capacityFade
  • powerFade
  • roundTripEfficiencyFade
  • evolutionOfSelfDischargeRate
  • numberOfFullEquivalentChargingCycles
  • numberOfChargingEvents
  • dateOfServiceEntry
  • negativeEvents
  • currentStateOfCharge
  • temperatureConditionsHistorical

Notes

Measurement methodology for state-of-health and the cycle-life test (Annex IV of the regulation, plus implementing acts) continues to evolve. Fields are present; reporting against newer methodology versions is a re-measurement at the customer level, not a schema migration.

EUR-Lex

Article 77

Battery Passport

Modeled

Every battery you sell in the EU needs its own digital passport behind a QR code, with a unique ID, who made it, when and where, what type it is, and where it is in its life.

Requirement

Each LMT, industrial (>2 kWh), and EV battery placed on the EU market shall have a unique digital passport accessible via QR code, containing identifier, manufacturer details, manufacturing date and place, battery category, and lifecycle status.

TracePass fields

  • batteryUniqueIdentifier
  • batteryIdDmcCode
  • batteryPassportIdentifier
  • manufacturerName
  • manufacturerTradeName
  • manufacturerPostalAddress
  • manufacturerEmail
  • manufacturerWebAddress
  • manufacturingDate
  • manufacturingPlace
  • batteryCategory
  • batteryStatus

Notes

Article 77 mandate becomes binding 18 February 2027 — the data carrier (QR / GS1 Digital Link), the Annex XIII data spec, who must comply (manufacturer or importer), and the public/restricted/authority access tiers. The dedicated Article 77 page sets out the requirement in full.

EUR-LexFull Article 77 requirements

Where this fits: see the buyer's guide

/buyers-guide →

Reviewed by Malin Ivanov, Managing Director — on