01 Who is affected
- Manufacturers of batteries and of products containing batteries
- Importers and distributors of such products in the EU
- Suppliers of cells and modules asked for carbon-footprint and due-diligence data
02 Main obligations
- CE marking, conformity assessment and labelling, including the separate-collection symbol
- Removability and replaceability of portable batteries in consumer products (Art. 11)
- Carbon-footprint declaration and, later, performance classes for certain categories
- Battery passport for LMT, industrial (above 2 kWh) and electric-vehicle batteries
- Supply-chain due diligence (Art. 48) applying from 18 August 2027
- Authorised representative (Art. 40) and national EPR registration
Summary only; several requirements depend on delegated and implementing acts.
03 What ZC delivers
- Product-by-product obligation map and gap analysis
- Labelling and technical documentation review
- Due-diligence policy, supplier questionnaires and management system outline
- Authorised-representative and EPR set-up
04 Key dates
| Date | Milestone | Source |
|---|---|---|
| 18 Aug 2027 | Due-diligence obligations apply (Art. 48, as postponed by the Omnibus IV amendment) | Regulation (EU) 2023/1542 |
| 18 Feb 2027 | Battery passport for LMT, industrial and EV batteries (Art. 77) | Regulation (EU) 2023/1542 |