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Battery EPR & Passport Readiness Checklist 2026–27.
Twenty-four questions we ask every producer before mapping their obligations. Work through it with your team, print it, or send us your answers and we'll turn it into a confirmed obligation map.
1Scope — what are you actually placing on the market?
- Battery categories inventoriedPortable, industrial (>2 kWh), EV, LMT and SLI β including batteries inside equipment and appliances.
- Chemistries known per product lineLi-ion (NMC/LFP/LCO), NiMH, lead-acid β chemistry drives classification, treatment route and passport data.
- Every market you sell into listedDirect sales, distributors and marketplaces all count. Each market keeps its own register and calendar.
- Volumes placed per market estimatedQuantities by category and chemistry β the raw material of every declaration you'll file.
2Legal presence — who can register you?
- Local legal entities mapped against marketsIn most regimes, no local entity means you cannot register without an appointed Authorised Representative.
- Authorised Representative appointed where requiredOne appointment letter per market β the AR carries registration, reporting and correspondence with authorities.
- Marketplace verification anticipatedMarketplaces increasingly verify EPR registration numbers before listing. Know which numbers you'll be asked for.
- Responsibility chain agreed with distributorsWho legally places the battery on each market β you or them β settled in writing, market by market.
3Registration, schemes & fees
- Producer registrations current in every marketRegistered before placing on the market β and kept current as company details change.
- Compliance scheme memberships in placeWhere a market discharges obligations through schemes: contracts, renewals and audits managed.
- Producer fees and eco-modulation understoodFee logic differs per market; eco-modulated charges reward design choices in several regimes.
- Declaration calendar consolidatedMonthly, quarterly and annual deadlines merged into one calendar someone actually owns.
4Data — one format, every market
- One internal reporting format agreedStructured once β categories, chemistries, weights β then transformed to each market's requirements.
- Evidence retained and retrievableRegistrations, declarations and payments held as auditable records for when a regulator or customer asks.
- Regulatory watch assignedThe EU Battery Regulation phases in year by year; someone must own tracking the changes before they bite.
- Carbon-footprint declarations plannedTiming now follows the delayed methodology delegated act (12 months after it enters into force) β but the underlying data takes longest to build, so start now.
5Battery passport — ready for February 2027?
- Passport scope confirmedEV, LMT and industrial batteries above 2 kWh placed on the EU market must carry a digital passport from Feb 2027, accessible via QR code.
- Data model aligned to the standardsStructured data, not PDFs β built against the emerging European passport specifications.
- Unique identifiers & QR plan per battery modelWho mints them, where they resolve, and who updates the record across the battery's life.
- End-of-life data source identifiedThe hardest chapter: who evidences what was recovered? Most passport vendors can't. Our recycling operations can.
6End of life — the part that proves everything
- Take-back route establishedWaste batteries need a compliant, documented route back β including free take-back duties for industrial batteries.
- Treatment & recovery evidence flowingRecovery evidenced at the point of treatment is what compliance schemes ultimately count.
- Chain-of-custody digital, not paperDigital duty of care and movement records per consignment β the same record serving EPR, passports and audits.
- Recycled-content strategy startedFrom Aug 2031 new industrial, EV and SLI batteries must declare minimum recycled content. Supply of verified recyclate starts now.
Scored more empty boxes than you'd like?
Send us your half-finished checklist β seriously. It's exactly the input we need to return a confirmed, written obligation map. hello@rawbatt.com ·.
Planning aid summarising headline duties under Regulation (EU) 2023/1542 and national battery EPR regimes β not legal advice. Obligations depend on category, volumes and role in the chain. Last reviewed July 2026.