For EU importers and the software vendors that serve them. Several battery obligations are often quoted with a fixed date, but the Regulation says they apply from the later of that date or a period after a Commission act that has not been adopted yet. This page lists each obligation, the article the date comes from, and which Commission acts are still missing. Every row quotes the Official Journal.
2023/956 Art 2a(1) · CBAM-01
“shall be exempted from the obligations under this Regulation, where the net mass of the imported goods in a given calendar year does not cumulatively exceed the single mass-based threshold”32025R2083 · text checked 2026-10-28
2023/956 Annex VII point 1 · CBAM-02
“The single mass-based threshold referred to in Article 2a shall be set at 50 tonnes of net mass.”32025R2083 · text checked 2026-10-28
2023/956 Art 2a(2) · CBAM-03
“shall be subject to all obligations under this Regulation in respect of all emissions embedded in all goods imported in that calendar year”32025R2083 · text checked 2026-10-28
2023/956 Art 2a(3) · CBAM-04
“By 30 April of each calendar year, the Commission shall assess”32025R2083 · text checked 2026-10-28
2023/956 Art 5(1) · CBAM-05
“shall, prior to importing goods into the customs territory of the Union, apply for the status of authorised CBAM declarant”32025R2083 · text checked 2026-10-28
2023/956 Art 5(1a) · CBAM-06
“An indirect customs representative shall obtain the status of authorised CBAM declarant prior to importing goods”32025R2083 · text checked 2026-10-28
2023/956 Art 5(1b) · CBAM-07
“the importer shall submit the application for an authorisation in cases where that importer expects to exceed the single mass-based threshold”32025R2083 · text checked 2026-10-28
2023/956 Art 5(2) · CBAM-08
“Where an importer is not established in a Member State, the indirect customs representative shall obtain the status of authorised CBAM declarant”32025R2083 · text checked 2026-10-28
2023/956 Art 17(7a) · CBAM-09
“has submitted an application in accordance with Article 5 by 31 March 2026, such an importer or indirect customs representative may provisionally continue to import goods”32025R2083 · text checked 2026-10-28
2023/956 Art 6(1) · CBAM-10
“By 30 September of each year, and for the first time in 2027 for the year 2026, each authorised CBAM declarant shall use the CBAM registry”32025R2083 · text checked 2026-10-28
2023/956 Art 6(2)(a) · CBAM-11
“including the imported goods below the single mass-based threshold”32025R2083 · text checked 2026-10-28
2023/956 Art 8(1) · CBAM-12
“are verified by a verifier accredited pursuant to Article 18”32025R2083 · text checked 2026-10-28
2023/956 Art 9(2)(3) · CBAM-13
“until the end of the fourth year after the year during which the CBAM declaration has been or should have been submitted”32025R2083 · text checked 2026-10-28
2023/956 Art 9(4) · CBAM-14
“As from 2027, the Commission may, for third countries where carbon pricing rules are in place, determine and make available”32025R2083 · text checked 2026-10-28
Implementing act under 2023/956 Art 9(5) · CBAM-15
“the Commission will adopt an Implementing Act setting the rules for the deduction of a carbon price effectively paid in third countries in Q1 2026”52025DC0783 · text checked 2026-10-28
2023/956 Art 20(1) · CBAM-16
“From 1 February 2027, a Member State shall sell CBAM certificates on a common central platform”32025R2083 · text checked 2026-10-28
2023/956 Art 21(1a) · CBAM-17
“as the quarterly average of the closing prices of EU ETS allowances”32025R2083 · text checked 2026-10-28
2023/956 Art 22(1) · CBAM-18
“By 30 September of each year, and for the first time in 2027 for the year 2026, the authorised CBAM declarant shall surrender via the CBAM registry”32025R2083 · text checked 2026-10-28
2023/956 Art 22(2) · CBAM-19
“corresponds to at least 50 % of the embedded emissions in all goods it has imported since the beginning of the calendar year”32025R2083 · text checked 2026-10-28
2023/956 Art 22(2a) · CBAM-20
“by the end of the quarter following that in which the single mass-based threshold is exceeded”32025R2083 · text checked 2026-10-28
2023/956 Art 26(1) · CBAM-21
“Such a penalty shall be identical to the excess emissions penalty set out in Article 16(3) of Directive 2003/87/EC”32025R2083 · text checked 2026-10-28
2023/956 Art 26(1a) · CBAM-22
“as a result of incorrect information provided by a third party, namely an operator, a verifier or an independent person”32025R2083 · text checked 2026-10-28
2023/956 Art 26(2) · CBAM-23
“be an amount from three to five times the penalty referred to in paragraph 1”32023R0956 · text checked 2026-10-28
2023/956 Art 26(2a) · CBAM-24
“where an importer exceeded the single mass-based threshold by no more than 10 % of that threshold”32025R2083 · text checked 2026-10-28
2023/956 Art 35(1) · CBAM-25
“no later than one month after the end of that quarter”32023R0956 · text checked 2026-10-28
2023/956 Art 36(2)(b) · CBAM-26
“Article 2(2) and Articles 2a, 4, 6 to 9, 10a, 15, 19 and 21, Article 22(1) and 22(3) and Articles 23 to 27 and 31 shall apply from 1 January 2026.”32025R2083 · text checked 2026-10-28
2023/956 Art 36(2)(c) · CBAM-27
“Article 22(2) shall apply from 1 January 2027;”32025R2083 · text checked 2026-10-28
2025/2621 Art 2 · CBAM-28
“It shall apply from 1 January 2026.”32025R2621 · text checked 2026-10-28
Review of default values (COM(2025) 783) · CBAM-29
“where a review is planned in 2027”52025DC0783 · text checked 2026-10-28
Proposal COM(2025) 989 · CBAM-30
“shall apply from 1 January 2028”52025PC0989 · text checked 2026-10-28
2023/1542 Art 13(1) · BAT-01
Applies from the later of the date in the article or a period after the act below enters into force. Art 13(10) implementing act on labelling specifications (due 2025-08-18: not found in EUR-Lex index on 2026-10-28)
“From 18 August 2026 or 18 months after the date of entry into force of the implementing act referred to in paragraph 10, whichever is the latest, batteries shall bear a label containing the general information on batteries set out in Part A of Annex VI.”32023R1542 · text checked 2026-10-28
2023/1542 Art 13(2) · BAT-02
Applies from the later of the date in the article or a period after the act below enters into force. Art 13(10) implementing act on labelling specifications (due 2025-08-18: not found in EUR-Lex index on 2026-10-28)
“rechargeable portable batteries, LMT batteries and SLI batteries shall bear a label containing information on their capacity”32023R1542 · text checked 2026-10-28
2023/1542 Art 13(3) · BAT-03
Applies from the later of the date in the article or a period after the act below enters into force. Art 13(10) implementing act on labelling specifications (due 2025-08-18: not found in EUR-Lex index on 2026-10-28)
“non-rechargeable portable batteries shall bear a label containing information on their minimum average duration when used in specific applications”32023R1542 · text checked 2026-10-28
2023/1542 Art 13(4) · BAT-04
“From 18 August 2025, all batteries shall be marked with the symbol for separate collection of batteries”32023R1542 · text checked 2026-10-28
2023/1542 Art 13(5) · BAT-05
“All batteries containing more than 0,002 % cadmium or more than 0,004 % lead, shall be marked with the chemical symbol for the metal concerned: Cd or Pb.”32023R1542 · text checked 2026-10-28
2023/1542 Art 13(6) · BAT-06
“From 18 February 2027, all batteries shall be marked with a QR code as described in Part C of Annex VI.”32023R1542 · text checked 2026-10-28
2023/1542 Art 13(10) · BAT-07
“The Commission shall, by 18 August 2025, adopt implementing acts to establish harmonised specifications for the labelling requirements referred to in paragraphs 1, 2 and 3 of this Article.”32023R1542 · text checked 2026-10-28
2023/1542 Art 7(1) 2nd subpara. (a) · BAT-08
Applies from the later of the date in the article or a period after the act below enters into force. Art 7(1) 4th subpara. (a) delegated act on calculation method (due 2024-02-18: not found in EUR-Lex index on 2026-10-28); Art 7(1) 4th subpara. (b) implementing act on declaration format (due 2024-02-18: not found in EUR-Lex index on 2026-10-28)
“18 February 2025 or 12 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest”32023R1542 · text checked 2026-10-28
2023/1542 Art 7(1) 2nd subpara. (b) · BAT-09
Applies from the later of the date in the article or a period after the act below enters into force. Art 7(1) 4th subpara. (a) delegated act on calculation method (due 2025-02-18: not found in EUR-Lex index on 2026-10-28); Art 7(1) 4th subpara. (b) implementing act on declaration format (due 2025-02-18: not found in EUR-Lex index on 2026-10-28)
“18 February 2026 or 18 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest”32023R1542 · text checked 2026-10-28
2023/1542 Art 7(1) 2nd subpara. (c) · BAT-10
Applies from the later of the date in the article or a period after the act below enters into force. Art 7(1) 4th subpara. (a) delegated act on calculation method (due 2027-02-18: not found in EUR-Lex index on 2026-10-28); Art 7(1) 4th subpara. (b) implementing act on declaration format (due 2027-02-18: not found in EUR-Lex index on 2026-10-28)
“18 August 2028 or 18 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest”32023R1542 · text checked 2026-10-28
2023/1542 Art 7(1) 4th subpara. · BAT-11
“The Commission shall, by 18 February 2024 for electric vehicle batteries, 18 February 2025 for rechargeable industrial batteries, except those with external storage, 18 February 2027 for LMT batteries and 18 February 2029 for industrial batteries with external storage, adopt:”32023R1542 · text checked 2026-10-28
2023/1542 Art 7(2) 3rd subpara. (a) · BAT-12
Applies from the later of the date in the article or a period after the act below enters into force. Art 7(2) 4th subpara. (a) delegated act on performance classes (due 2025-02-18: not found in EUR-Lex index on 2026-10-28); Art 7(2) 4th subpara. (b) implementing act on label format (due 2025-02-18: not found in EUR-Lex index on 2026-10-28)
“18 August 2026 or 18 months after the date of entry into force either of the delegated act or of the implementing act respectively referred to in the fourth subparagraph, points (a) and (b), whichever is the latest, for electric vehicle batteries”32023R1542 · text checked 2026-10-28
2023/1542 Art 7(3) 2nd subpara. (a) · BAT-13
Applies from the later of the date in the article or a period after the act below enters into force. Art 7(3) 3rd subpara. delegated act on maximum threshold (EV) (due 2026-08-18: not found in EUR-Lex index on 2026-10-28)
“18 February 2028 or 18 months after the date of entry into force of the delegated act referred to in the third subparagraph, whichever is the latest, for electric vehicle batteries”32023R1542 · text checked 2026-10-28
2023/1542 Art 8(1) 1st subpara. · BAT-14
Applies from the later of the date in the article or a period after the act below enters into force. Art 8(1) 3rd subpara. delegated act on calculation and verification method (due 2026-08-18: not found in EUR-Lex index on 2026-10-28)
“From 18 August 2028 or 24 months after the date of entry into force of the delegated act referred to in the third subparagraph, whichever is the latest, industrial batteries with a capacity greater than 2 kWh”32023R1542 · text checked 2026-10-28
2023/1542 Art 8(1) 2nd subpara. · BAT-15
“The first subparagraph shall apply from 18 August 2033 to LMT batteries that contain cobalt, lead, lithium or nickel in active materials.”32023R1542 · text checked 2026-10-28
2023/1542 Art 8(2) · BAT-16
“From 18 August 2031, for industrial batteries with a capacity greater than 2 kWh, except those with exclusively external storage, electric vehicle batteries and SLI batteries”32023R1542 · text checked 2026-10-28
2023/1542 Art 9(1) · BAT-17
Applies from the later of the date in the article or a period after the act below enters into force. Art 9(2) delegated act on minimum values (due 2027-08-18: not found in EUR-Lex index on 2026-10-28)
“From 18 August 2028 or 24 months after the date of entry into force of the delegated act referred to in paragraph 2, whichever is the latest, portable batteries of general use, excluding button cells”32023R1542 · text checked 2026-10-28
2023/1542 Art 10(1) · BAT-18
“From 18 August 2024, rechargeable industrial batteries with a capacity greater than 2 kWh, LMT batteries and electric vehicle batteries shall be accompanied by a document”32023R1542 · text checked 2026-10-28
2023/1542 Art 10(2) · BAT-19
Applies from the later of the date in the article or a period after the act below enters into force. Art 10(5) 1st subpara. delegated act on minimum values (due 2026-02-18: not found in EUR-Lex index on 2026-10-28)
“From either 18 August 2027 or 18 months after the date of entry into force of the delegated act referred to in the first subparagraph of paragraph 5, whichever is the latest, rechargeable industrial batteries”32023R1542 · text checked 2026-10-28
2023/1542 Art 11(1) · BAT-20
“Article 11 shall apply from 18 February 2027;”32023R1542 · text checked 2026-10-28
2023/1542 Art 11(5) · BAT-21
“as well as individual battery modules included in the battery pack, are readily removable and replaceable by an independent professional”52025PC0981 · text checked 2026-10-28
2023/1542 Art 14(1) · BAT-22
“From 18 August 2024, up-to-date data for the parameters for determining the state of health and expected lifetime of batteries”32023R1542 · text checked 2026-10-28
2023/1542 Art 48(1) · BAT-23
“in paragraph 1, the date ‘18 August 2025’ is replaced by ‘18 August 2027’;”32025R1561 · text checked 2026-10-28
2023/1542 Art 47 · BAT-24
“This Chapter does not apply to economic operators that had a net turnover of less than EUR 40 million in the financial year preceding the last financial year”32023R1542 · text checked 2026-10-28
2023/1542 Art 48(5) · BAT-25
“in paragraph 5, the date ‘18 February 2025’ is replaced by ‘26 July 2026’.”32025R1561 · text checked 2026-10-28
2023/1542 Art 54(4) · BAT-26
“By 18 November 2025, Member States shall notify the Commission of the names and addresses of the competent authorities”32023R1542 · text checked 2026-10-28
2023/1542 Art 55(2) · BAT-27
“Producers shall register in the register referred to in paragraph 1. They shall to that end submit an application for registration in each Member State where they make a battery available on the market for the first time.”32023R1542 · text checked 2026-10-28
2023/1542 Art 59(3)(b) · BAT-28
“63 % by 31 December 2027;”32023R1542 · text checked 2026-10-28
2023/1542 Art 71(4) · BAT-29
“The Commission shall, by 18 February 2025, adopt a delegated act in accordance with Article 89 to supplement this Regulation by establishing the methodology for calculation and verification of rates for recycling efficiency and recovery of materials”32023R1542 · text checked 2026-10-28
2023/1542 Art 76(5) · BAT-30
“The Commission shall, by 18 August 2025, adopt implementing acts laying down the format for the data and information to be reported to the Commission”32023R1542 · text checked 2026-10-28
2023/1542 Art 77(1) · BAT-31
“From 18 February 2027 each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market or put into service shall have an electronic record (‘battery passport’).”32023R1542 · text checked 2026-10-28
2023/1542 Art 77(9) · BAT-32
“By 18 August 2026, the Commission shall adopt implementing acts specifying which persons are to be considered persons with a legitimate interest”32023R1542 · text checked 2026-10-28
2023/1542 Annex I（Art 6(1)） · BAT-33
“Article 53 shall apply from 13 August 2026”32026R1738 · text checked 2026-10-28