The EU Battery Regulation gave Brussels until 18 February 2025 to define carbon-footprint grades for EV batteries: eighteen months on, the grade still does not exist, and the next deadline, for industrial batteries, falls on the same day the label is due

A label with a grade the EU has not yet defined

The Battery Regulation entered into force on 17 August 2023, replacing the 2006 Battery Directive with rules that apply directly across all 27 member states. Article 7 covers three battery categories: electric-vehicle (EV) batteries, batteries for light means of transport (LMT, the packs inside e-bikes and e-scooters), and rechargeable industrial batteries with a capacity above 2 kWh. Ordinary portable batteries, the kind inside a torch, a remote control or most consumer electronics, sit outside Article 7's carbon-footprint regime entirely. For the categories it does cover, the article does three things in sequence: it requires a carbon-footprint declaration per battery model and manufacturing plant, it requires that declaration to appear on a label, and it requires the label to state which performance class the battery falls into, a classification the Commission has to build first. The regulation's own text sets the Commission four separate deadlines to adopt that classification by delegated act: 18 February 2025 for EV batteries, 18 August 2026 for industrial batteries except those with exclusively external storage, 18 August 2028 for LMT batteries, and 18 August 2030 for industrial batteries with external storage. The first of those four deadlines has already passed unmet.

The numbers behind a rulebook still being written

One number is how late the Commission already is on its first Article 7 deadline. One is how many separate delegated-act deadlines the article sets across battery categories. One is how much runway industrial-battery manufacturers have between the rulebook and the label, compared to the eighteen months EV batteries were supposed to get.

The real subject: a compliance obligation with the EU on the critical path

Most coverage of EU battery rules treats delegated acts as background plumbing, technical detail that specialists track so brands don't have to. Article 7 makes that plumbing load-bearing. A battery carbon-footprint label is not something a manufacturer can build from first principles; it requires a classification scale the Commission alone can issue, because the whole point of a performance class is that every manufacturer is graded against the same benchmark. When the Commission misses its own deadline to publish that scale, as it has for EV batteries since February 2025, it does not just delay its own paperwork. It leaves every EV battery manufacturer selling into the EU without the one input needed to know what their label is supposed to say, while the underlying obligation to declare a carbon footprint has not gone away, only the fixed date it was tied to. The industrial-battery deadline arriving this 18 August is the sharper version of the same structural problem: unlike EV batteries, which had an 18-month gap between the rulebook deadline and anyone needing to comply, industrial batteries above 2 kWh get no gap at all. If the Commission adopts its delegated act on 18 August 2026 itself, or later, manufacturers are being asked to display a label built from a methodology that, on paper, arrives the same day it is due, or after. This is a pattern worth watching beyond batteries: when a regulation makes Brussels itself the first mover on a technical definition, a brand's compliance timeline is only as reliable as the Commission's own delivery record on that specific article, which for Article 7 is one missed deadline out of one so far.

Why it matters for brands

Article 7's scope is narrower than it first sounds: it does not touch the coin cells, AA batteries or built-in electronics batteries in most consumer products, only EV batteries, LMT batteries (the packs inside e-bikes, e-scooters and similar light vehicles) and rechargeable industrial batteries above 2 kWh, the category that covers power tools, energy-storage units and similar equipment batteries. For retail and consumer-goods brands that sell e-bikes, e-scooters, power tools or battery-backed equipment into the EU, three things follow from a rulebook that keeps arriving late or on the wire. First, a compliance calendar built around a single printed date is the wrong tool here; the EV experience shows the operative trigger can be the delegated act's entry into force plus a fixed period, not a date fixed at the outset, so tracking has to follow the act itself, not just the regulation's original text. Second, a brand sourcing industrial batteries above 2 kWh should not assume a comfortable lead time before the 18 August 2026 label requirement, because the Commission's own deadline to define the grading scale lands on the same day, which means the classification a supplier's label relies on could be published only days, or weeks, before or after it is legally due. Third, the practical fallback in this kind of gap is the underlying carbon-footprint declaration itself, the raw life-cycle data per battery model and manufacturing plant, which does not depend on the Commission's classification scale to be prepared and does not become less necessary just because the grade it feeds is delayed. A brand that has that declaration built and traceable back to a specific plant and model is ready to plug in a performance class the moment one exists; a brand waiting on the classification before starting the underlying data work is choosing to compress its own compliance timeline to match the Commission's delay.

Two ways to read 18 August

Frequently asked questions

Sources

1. EUR-Lex: Regulation (EU) 2023/1542 of 12 July 2023 concerning batteries and waste batteries (Batteries Regulation), Article 7
2. European Commission, Have Your Say: "Batteries for electric vehicles: carbon footprint methodology" (draft delegated act published 30 April 2024, consultation closed 28 May 2024)
3. SGS: "Key Requirements and Impacts of the EU Battery Regulation 2023/1542" (July 2026)
4. Joint Research Centre: "Calculating the carbon footprint of industrial batteries: a methodological support" (2025)
5. European Commission, Have Your Say: "Batteries: format of carbon footprint declaration"