The draft is out — here is what it contains
On 22 December 2025 the EU notified the WTO of a draft Commission Implementing Regulation under Articles 7(2) and 13(10) of Regulation (EU) 2023/1542 (the Battery Regulation), laying down the format and harmonised specifications for certain labelling requirements (notification G/TBT/N/EU/1181). The full draft is public on EUR-Lex (Ares(2025)11169592), together with its five annexes.
Important: the draft has not been adopted or published in the Official Journal yet. The document carries a placeholder number "(EU) …/..." and expressly states it does not constitute the final position of the Commission. Comments from China and the US were submitted in February 2026; the EU replied on 6 July 2026. Adoption and publication in the OJ are expected in the coming months — but nothing is legally binding until it appears in the OJ.
Which batteries are covered
All categories of batteries: portable batteries, SLI (starting, lighting, ignition) batteries, LMT (light means of transport) batteries, electric vehicle batteries and industrial batteries — regardless of shape, volume, weight, design, material composition, chemistry, use or purpose, including batteries incorporated into or added to products. Battery packs (cells connected or encapsulated in an outer casing to form a complete unit) are also covered.
Where a battery can be considered to fall under more than one category, the strictest labelling requirements apply.
What the label must show
The draft sets out the labelling information per battery category in five annexes:
- Portable non-rechargeable batteries (Annex I): manufacturer name/address/web/email, category and model identification, place and date of manufacture, mass, electrochemical composition, restricted and hazardous substances, usable extinguishing agent or fire class, critical raw materials above 0.1% w/w — and, new, the minimum average duration for up to three representative applications (Annex I Part C).
- Portable rechargeable, SLI and LMT batteries (Annex II): the same core information plus capacity in mAh or Ah (and cranking current in amperes for SLI batteries).
- EV batteries and industrial batteries (Annex III): the same core information, with extinguishing-agent information expressed accordingly.
- Electrochemical composition nomenclature (Annex IV): simplified categories such as "alkaline", "sodium", "zinc" or "lithium", plus molecular formulae for specific chemistries — including Pb, Ni-Cd, Ni-MH, Li-ion NMC/LFP/LMO/LCO/NCA, Li-metal and Na-ion.
- Carbon footprint label (Annex V, per Article 7): performance class (A–E), declared carbon footprint and functional unit, with colour specifications (CMYK) and minimum print dimensions.
For all batteries, hazardous substances other than mercury, cadmium and lead must also be indicated on the label.
Design specifications in the draft
- Typeface: Noto Sans or any other open-source font fully compatible with all EU official languages
- Main text minimum font size: 5.7 pt; electrochemical composition heading: 18 pt bold; model identification and mass: 12 pt bold; average duration: 8.5 pt bold
- Margin border: 3 mm
- The QR code may be placed on the label instead of elsewhere on the battery surface
When does it apply?
Under the draft, the Article 13(1) labelling requirements apply 18 months after the entry into force of the implementing regulation (the exact date is a placeholder in the draft, to be fixed in the final act). The carbon footprint performance-class requirements for EV, LMT and rechargeable industrial batteries above 2 kWh follow the dates in Article 7(2) per battery category.
What to do now
Even though the text is still a draft, the specifications are already very detailed. Manufacturers placing batteries on the EU market should:
- Audit current labels against the draft annexes (information items per category).
- Prepare artwork for the Noto Sans layout, 3 mm border and font-size hierarchy.
- Collect the data the label requires: electrochemical composition, critical raw materials above 0.1% w/w, extinguishing agent/fire class, and — for non-rechargeable portable batteries — minimum average duration test data.
- Watch the OJ — the final act is expected soon, and the 18-month transition starts at its entry into force.
ComplyMatrix tracks EU regulatory changes like this one continuously. Try the free compliance checker to see which regulations apply to your products, or contact us for expert verification of your labelling and technical documentation.
Sources: WTO TBT notification G/TBT/N/EU/1181 (technical-barriers-trade.ec.europa.eu); Draft Commission Implementing Regulation, EUR-Lex Ares(2025)11169592; European Commission, Batteries page.