How BatteryComply audits your PDF
Every finding BatteryComply surfaces is tied to a specific Article or Annex of EU Regulation 2023/1542 (or the adjacent regulations it references). No heuristics, no guesswork. This page is the full methodology — what we check, why, and how we map it to a verdict.
Article-numbering note
The original OJ text of 2023/1542 used Art. 38 for the Battery Passport and Art. 41 for the Authorised Representative. The consolidated text (18 July 2024), which is the one in force, renumbers them: Art. 40 = Authorised Representative, Art. 77 = Battery Passport. We cite the consolidated numbering.
Phase-in calendar (as of April 2026)
- 18 Feb 2024 — Reg. 2023/1542 entered into application. Dir. 2006/66/EC repealed.
- 18 Aug 2024 — Core sustainability/safety + DoC obligations apply.
- 18 Feb 2025 — Art. 7 carbon-footprint declaration for EV batteries.
- 18 Aug 2025 — Art. 13(4) separate-collection symbol mandatory on all batteries.
- 18 Feb 2026 — Art. 7 CF declaration for rechargeable industrial > 2 kWh (no external storage).
- 18 Aug 2026 — Art. 13(1)–(3) Annex VI Part A general label + capacity/duration labels.
- 18 Feb 2027 — Art. 77 Battery Passport for LMT, industrial > 2 kWh, and EV batteries.
- 18 Aug 2028 — Art. 7 CF declaration for LMT batteries.
- 18 Aug 2030 — Art. 7 CF declaration for industrial batteries with external storage.
Implication: BatteryComply never fails a product on a check whose trigger date has not yet passed. Pre-deadline obligations surface as INFO only.
The ten checks
1. Declaration of Conformity
Must contain: unique identification, manufacturer + (if any) authorised representative, sole-responsibility statement, object of declaration, statement of conformity with Reg. (EU) 2023/1542, harmonised standards, notified-body data where applicable, place/date/signature.
Verdict impact: No DoC → NOT APPROVED. DoC present but a required field missing → CONDITIONAL.
2. CE marking
CE mark on battery (or packaging + accompanying docs if size prevents direct marking), followed by the notified-body 4-digit number when a notified body participated in conformity assessment.
3. Annex VI labelling
Multi-element. Each sub-element is its own row so you see which specific label item is missing: manufacturer ID, category & battery ID, place & date of manufacture, weight, Wh capacity, chemistry, hazardous substances, usable extinguishing agent, critical raw materials ≥ 0.1% w/w. Plus the always-in-force symbols: separate-collection (crossed-out wheelie bin, Art. 13(4), in force from 18 Aug 2025) and Cd/Pb chemical symbol where thresholds are exceeded (Art. 13(5)).
4. Battery Passport / QR
Applies from 18 Feb 2027 to LMT batteries, industrial batteries > 2 kWh, and EV batteries. We check for QR code (ISO/IEC 18004), unique identifier (ISO/IEC 15459), and Annex XIII data elements. Out-of-scope categories and earlier placing-dates are not flagged.
5. EU Authorised Representative
Required for manufacturers established outside the Union. Must appear on the DoC or accompanying docs with name, postal address, contact. Absent + non-EU manufacturer → CONDITIONAL.
6. Restricted substances (Art. 6, not RoHS)
Batteries are explicitly excluded from RoHS scope (Directive 2011/65/EU Art. 2(4)). The limits live in Art. 6 + Annex I of Reg. 2023/1542: Hg < 0.0005 %, Cd < 0.002 % (portable), Pb < 0.01 % w/w.
7. REACH / SVHC disclosure
Supplier of an article containing an SVHC ≥ 0.1 % w/w must provide enough information for safe use, at minimum the substance name. Often in an accompanying letter or data sheet rather than the DoC.
8. UN 38.3 Transport Test Summary
Mandatory test summary for Li-ion / Li-metal cells and batteries from 1 Jan 2020. Required fields include manufacturer and contact, test-lab identification, unique report ID and date, cell description with Wh or Li content, model numbers, results of tests T.1–T.8, and signatory details. Usually a companion document to the DoC — we flag when missing for lithium chemistries.
9. Carbon Footprint declaration
Total CF in kg CO₂-eq / kWh over expected service life, broken down by life-cycle stage. Date-gated per category: EV (18 Feb 2025), industrial > 2 kWh without external storage (18 Feb 2026), LMT (18 Aug 2028), industrial with external storage (18 Aug 2030). Pre-deadline products: INFO advisory only.
10. Language of documentation
The language clause is not in Art. 13 / Annex VI. Art. 18(2) governs DoC translation; Art. 41(2) governs accompanying-doc language. In practice most Member States accept English for B2B/industrial products; consumer-facing products typically require the national language. We flag this as INFO — we never downgrade a verdict on language alone.
Verdict-mapping
NOT APPROVED — any CRITICAL gate missing and in force: DoC, CE, Art. 6 compliance, separate-collection symbol (from 18 Aug 2025), Cd/Pb symbol where required, Battery Passport (in-scope × date), UN 38.3 summary (Li chemistries), Art. 7 CF declaration (in-scope × date).
CONDITIONAL — all CRITICAL gates pass but IMPORTANT items missing: EU Authorised Representative when manufacturer is non-EU, REACH SVHC disclosure, Annex VI Part A items once in force.
APPROVED — all CRITICAL + IMPORTANT checks pass. INFO items may still appear for awareness (language of documentation, optional Annex XIII fields).
Open caveats
Because the regulation is young and some implementing acts are still landing, a few areas carry uncertainty we want our users to see:
- Verbatim text of Annex IX — the DoC model fields are inferred from Art. 18 + NLF convention + a real DoC sample. Cross-check before enforcing on a specific edge case.
- Exact Pb limit in Annex I — secondary sources split 0.005 % vs 0.01 % w/w.
- Status of the Art. 7 delegated/implementing acts as of April 2026 — trigger dates depend on the acts entering into force. We treat them as provisionally active unless JRC / EPLCA indicate otherwise.
- Norwegian/EEA incorporation date and Batteriforskriften replacement — relevant for Norwegian-market products.
- Art. 13(10) implementing act on the harmonised Annex VI Part A label format — confirm adoption before enforcing as CRITICAL on 18 Aug 2026.