EU Battery Regulation: What Distributors Need by 2027

From 18 February 2027, every home battery above 2 kWh placed on the EU market needs a digital battery passport, reached through a QR code on the battery. It is the most visible deadline in the EU Battery Regulation, but not the only one. Several obligations already apply. For a distributor, three questions matter: which role do you hold, what must you check before selling, and where must you register?

Where home storage sits in the regulation

The regulation sorts batteries into five categories: portable, starting-lighting-ignition (SLI), light means of transport (LMT), electric vehicle and industrial. A home battery is an industrial battery. The regulation also defines a "stationary battery energy storage system" as an industrial battery with internal storage that is designed to store energy from the grid or deliver it to the grid or the end user, wherever it is used. A wall-mounted battery in a garage is in this group, even though it is sold to households.

This matters because the passport applies only to three groups: LMT batteries, electric vehicle batteries and industrial batteries with a capacity greater than 2 kWh. Almost every home storage product is above that threshold.

Which role do you hold?

Your obligations depend on your role, not on what you call your company.

Role	Who it is	Main obligations
Manufacturer	Makes the battery, or has it made and sells it under its own name or trademark	Conformity assessment, CE marking, labels, documentation, battery passport
Importer	Places a battery that originates from a third country on the EU market	Checks that the manufacturer has done its part; adds its own name and address
Distributor	Anyone else in the supply chain who makes the battery available on the market	Checks before selling (see below)
Producer (for take-back)	Whoever makes a battery available for the first time in a Member State, which can be a manufacturer, importer or distributor	Registration and extended producer responsibility in that Member State

Two points often catch distributors out. First, if you sell a battery under your own brand, you are treated as the manufacturer for that battery. Second, the "producer" role is decided per country: if you are the first to make a battery available in a Member State, you must register there, even if another company has already registered the same model elsewhere.

The timeline

Key dates for home batteries

18 February 2024the regulation applies
18 August 2024conformity assessment and CE marking
18 August 2025separate collection symbol; producer responsibility and take-back rules
18 August 2026full label content, or 18 months after the label implementing act if later
18 February 2027QR code on all batteries; battery passport above 2 kWh
18 August 2027supply chain due diligence (larger companies)

Dates as set in the regulation, as amended by Regulation (EU) 2025/1561. The label date depends on an implementing act that was still in draft in late summer 2026.

A few of these need explaining:

Labels. The full label information in Annex VI (manufacturer, category, chemistry, capacity, weight, hazardous substances and more) applies from 18 August 2026 or 18 months after the implementing act on label format enters into force, whichever is later. The Commission has published that act only in draft, so in practice the date depends on when it is adopted. The separate collection symbol (the crossed-out wheeled bin) has applied to all batteries since 18 August 2025.
Carbon footprint. Rechargeable industrial batteries will need a carbon footprint declaration, but only from a date linked to the delegated and implementing acts that set out the calculation method and format. Those acts have not been adopted for industrial batteries, so the declaration does not yet apply.
Due diligence. Regulation (EU) 2025/1561 postponed the supply chain due diligence obligations by two years, to 18 August 2027. Companies with a net turnover below EUR 40 million that are not part of a larger group are exempt.

What the battery passport is

The battery passport is an electronic record for each individual battery, not only for each model. The economic operator that places the battery on the market is responsible for it and must keep the information accurate, complete and up to date. It may appoint another party to manage the passport on its behalf.

Unique identifier. Each battery gets a unique identifier, assigned by the operator placing it on the market.
QR code. A QR code on the battery links to the passport. From 18 February 2027 all batteries need a QR code; for batteries without a passport it links to other required information.
Open formats. Data must be in open, interoperable, machine-readable formats, and the passport must stay available even if the company that created it stops trading in the EU.
Free access. Consumers, economic operators and other relevant actors can access it free of charge, according to their access rights.

The information is split into three access levels:

Who sees what in the battery passport

Everyone

Public informationmodel data: label details, materials and chemistry, capacity and performance, carbon footprint, recycled content, declaration of conformity

Persons with a legitimate interest

Repair, repurposing and recyclingdetailed information for those who work on the battery, such as dismantling and safety data

Authorities

Notified bodies, market surveillance, Commissiontest reports and evidence of compliance

The three access levels set out in Article 77(2) and Annex XIII. The exact data fields and the technical design of the passport are still being set in implementing acts and European standards.

When a battery is prepared for re-use, repurposed (for example, an EV battery turned into home storage) or remanufactured, it gets a new passport linked to the original one, and the operator doing that work becomes responsible for it.

What distributors must check before selling

Article 42 lists what a distributor must verify before making a battery available on the market:

The producer is registered in the register of producers of the Member State concerned.
The battery carries the CE marking and is marked and labelled as the regulation requires.
The battery comes with the required documents, and with instructions and safety information in a language end users can easily understand.
The manufacturer and the importer have met their own labelling and identification obligations.

If a distributor believes a battery does not comply, it must not make it available until it has been brought into conformity. It must also inform the manufacturer or importer and, where there is a risk, the market surveillance authorities.

From 18 February 2027, we also recommend a fifth, practical check for batteries above 2 kWh: the QR code works and leads to a live battery passport for that individual unit. Article 42 does not list it, but a missing passport is a compliance gap on the side of the manufacturer or importer you buy from.

Registration and take-back in each country

Extended producer responsibility has applied since 18 August 2025 and is organised country by country. A producer must apply for registration in each Member State where it first makes batteries available. It must also finance and organise the collection and treatment of waste batteries there, usually through a producer responsibility organisation. Registration numbers, fees and reporting differ between countries.

For distributors who import directly or move batteries across borders, this is often the biggest task. Before the first shipment to a new country, check who will act as producer there, and whether that company is registered.

Checklist for distributors

Know your role per product and per country: manufacturer (own brand), importer, distributor, and whether you are the producer in each Member State.
Check the CE marking and declaration of conformity for each battery model you sell.
Check the labels: separate collection symbol now; full Annex VI label information once it applies.
Check the producer registration, yours or your supplier's, in each country where you sell.
Ask for documentation and instructions in the languages of your markets.
Prepare for 18 February 2027: confirm with each supplier that batteries above 2 kWh will carry a QR code and a live passport, who manages it, and how you will access the information your customers and installers need.
Agree data for second life and recycling: who provides it, and how installers and recyclers will reach the restricted part of the passport.
Watch the open dates: the label implementing act, the carbon footprint acts and the passport implementing acts can still move the details.

How VaySunic can help

VaySunic designs and manufactures home batteries, including PowerCube and the VB5000D battery packs, at its R&D and manufacturing centre in Wuxi, with headquarters in Germany. Distributors can ask us for the CE documentation, labels and instructions for the models they plan to sell, and for the current status of each model under the Battery Regulation in their market. Our distributor programme explains how we work with partners; more about the company is on our About page.