All batteries placed on the EU market are covered by the Battery Regulation (EU) 2023/1542, but the requirements depend on which of the regulation's five categories the battery belongs to.
The categories are portable batteries, LMT batteries, SLI batteries, EV batteries and industrial batteries. The classification is based on the battery's intended use and design, not its chemistry, and it determines everything from labelling requirements to the battery passport and the carbon footprint declaration.
Correct categorisation is the prerequisite for knowing which obligations apply. Misclassification can lead to non-compliance and, ultimately, a sales ban.
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The five categories
Portable batteries
Under Article 3, a portable battery is any battery that is sealed, weighs 5 kg or less and is not specifically designed for industrial use. The category works as a negative definition: a battery is only portable if it is neither an LMT, SLI nor EV battery.
Typical examples are batteries in smartphones, toys, hearing aids and hand-held tools.
Within the category there is a subgroup called "portable batteries of general use", covering standard formats such as AA, AAA, C, D, 9V and button cells. These are subject to specific performance and durability requirements.
LMT batteries (light means of transport)
The LMT category is new in the regulation and covers batteries for micromobility. An LMT battery is sealed, weighs 25 kg or less and is specifically designed to provide traction to wheeled vehicles powered by an electric motor or a combination of motor and human power.
Concrete examples are batteries in e-bikes, e-scooters, electric mopeds and monowheels.
The boundary with the EV category is based solely on weight: if a battery for a light vehicle (L category) weighs more than 25 kg, it automatically moves into the EV category.
SLI batteries (starting, lighting, ignition)
SLI batteries are specifically designed to supply power for starting, lighting or ignition in vehicles and machinery. Although the category is traditionally associated with lead-acid technology in combustion cars, the definition is technology-neutral: modern lithium-based starter batteries are also classified as SLI, as long as their main function is starting and supplying power to internal systems, not traction.
It is common for electric and hybrid cars to contain both an EV battery for propulsion and a separate SLI battery for safety systems and lighting. The two batteries are subject to different requirements.
EV batteries (electric vehicles)
EV batteries are specifically designed to provide electric energy for traction in vehicles of categories M, N or O (cars, buses, vans, trucks and trailers) and L-category vehicles with batteries over 25 kg. The definition explicitly includes batteries for plug-in hybrid cars, as these provide traction whether or not they operate together with a combustion engine.
The EV category has the most extensive requirements in the regulation: carbon footprint declaration, digital battery passport, due diligence, recycled content and performance documentation.
Industrial batteries
Industrial batteries are a broad catch-all category covering:
- Batteries specifically designed for industrial use
- Batteries converted for industrial use (repurposing)
- Any battery over 5 kg that cannot be classified as LMT, SLI or EV
The applications are many: stationary energy storage (BESS), uninterruptible power supplies (UPS), forklifts, trains, ships and batteries for solar installations in private homes, which are explicitly regarded as industrial batteries regardless of their location.
An important subcategory is industrial batteries with external storage (such as redox flow batteries), which have considerably longer deadlines for several of the regulation's requirements.
Which requirements apply to which categories?
The regulation is hierarchical: the most environmentally significant batteries (EV, LMT and large industrial batteries) carry the heaviest requirements. Here is an overview of the most important obligations.
Carbon footprint declaration (Article 7) applies to EV batteries, industrial batteries over 2 kWh and LMT batteries. Portable batteries and SLI batteries are exempt.
Digital battery passport (Article 77) becomes mandatory from February 2027 for EV batteries, LMT batteries and industrial batteries over 2 kWh.
Due diligence (Articles 47-52) applies in principle to all categories, but is limited by the turnover threshold of EUR 40 million (consolidated). Entry into application has been postponed to August 2027.
Recycled content (Article 8) applies to EV batteries, SLI batteries and industrial batteries over 2 kWh from 2031, with material-specific minimum shares for cobalt, lead, lithium and nickel. LMT batteries become covered from August 2033.
Performance and durability (Articles 9-10) has required documentation of electrochemical parameters for EV, LMT and industrial batteries over 2 kWh since August 2024. Portable batteries of general use must meet minimum values from August 2028.
Removability (Article 11) applies from February 2027 to portable batteries, which must be removable by the end-user with ordinary tools. LMT batteries must be replaceable by an independent professional. There are specific exemptions for medical devices and waterproof designs.
Labelling and CE (Article 13) applies to all categories. All batteries must carry CE marking, and the labelling requirements are being extended step by step with requirements for a QR code, a carbon footprint label and a performance class.
Collection and recycling applies to all categories under extended producer responsibility (EPR), which took effect in August 2025.
Key deadlines per category
EV batteries
Carbon footprint declaration: statutory date February 2025, but the deadline has been postponed to 12 months after the delegated act is adopted. Battery passport from February 2027. Performance classes (A-G) were scheduled for August 2026. Maximum carbon footprint thresholds from February 2028. Recycled content from 2031.
Industrial batteries (> 2 kWh, without external storage)
Carbon footprint declaration: statutory date February 2026, but the deadline has been postponed to 18 months after the delegated act is adopted. Battery passport from February 2027. Performance classes expected August 2027. Maximum thresholds from February 2028. Recycled content from 2031.
Industrial batteries with external storage
A considerably longer timeline: carbon footprint declaration expected August 2030, maximum thresholds from 2032.
LMT batteries
Carbon footprint declaration from 2026/2028 (depends on the delegated act). Battery passport from February 2027. Recycled content from August 2033.
Portable batteries
Removability requirement from February 2027. Minimum performance values from August 2028 (batteries of general use). No requirement for a carbon footprint declaration or a battery passport.
SLI batteries
Recycled content from 2031. No requirement for a carbon footprint declaration or a battery passport.
Borderline cases and typical confusions
Many companies run into classification challenges at the boundaries between categories. The regulation states that if a battery could fall into several categories, it must be subject to the category with the strictest requirements.
The weight limit between LMT and EV. A battery pack for an e-scooter weighing 6 kg is LMT. If it weighs 26 kg, it is classified as an EV battery with all the associated requirements.
Drones. Batteries for private drones under 5 kg are classified as portable. Drones designed for industrial use (spraying, inspection) are regarded as industrial batteries regardless of weight.
Home batteries. Batteries for solar installations in private homes are explicitly industrial batteries and not portable, regardless of their physical location.
Second-life batteries. When an EV battery is converted to stationary storage (repurposing), it changes category to industrial battery. The operator carrying out the conversion legally becomes the new producer and must issue new CE marking and create a new or updated battery passport.
National variations: registration per category
The regulation applies directly in all EU countries, but extended producer responsibility (EPR) is administered nationally. Companies must register in each country where they market batteries.
In Denmark, Dansk Producentansvar (DPA) runs the register. Since August 2025, companies have had to report per battery category.
In Germany, the new BattDG has introduced a critical re-registration deadline: by 15 January 2026, all producers had to document their affiliation with an approved producer responsibility organisation (OfH) for each battery category. Missing registration results in an immediate sales ban.
Summary
Correct categorisation is the foundation of all compliance work under the Battery Regulation. The five categories (portable, LMT, SLI, EV and industrial) determine which requirements apply, when they take effect, and what must be documented.
For companies with products at the boundaries between categories, a legal assessment is necessary, as misclassification can lead to non-compliance and market restrictions.
The next step is to map the whole product portfolio against the five categories and identify which requirements are triggered for each product line, including whether the battery passport, the carbon footprint declaration and the due diligence requirements are relevant.
Syntakk is built to structure product data according to the categories and requirements of the Battery Regulation, so companies can manage compliance across their product portfolio.
