Originally published on Medium.
The EU Batteries Regulation has a reputation as the one traceability mandate with teeth. A date, a liable party, market denial for non-conformity. On 18 February 2027, a battery placed on the EU market has to carry a passport.
Here is what has happened to the rest of the regulation’s calendar.
The supply-chain due diligence obligation under Article 48, covering cobalt, lithium, natural graphite and nickel, was supposed to apply from 18 August 2025. Regulation (EU) 2025/1561 moved it to 18 August 2027. Two years, granted on the reasoning that raw-material geopolitics were volatile, notified bodies were being designated too slowly, and due diligence schemes needed time to mature.
The Article 13(10) implementing act on labelling was due in August 2025. It has not been adopted.
The Article 7 delegated act setting the carbon footprint methodology has not been adopted either, which leaves the February 2025 carbon footprint obligations sitting there, technically in force and practically inert, because nobody has been told how to calculate the number.
And then the one that should get the industry’s attention. Article 77(9) required the Commission to adopt an implementing act by 18 August 2026 defining who counts as a person with a legitimate interest in the restricted parts of a battery passport, and what they may access, download, share and reuse. That deadline passed last month with no act adopted. The Commission’s own Digital Product Passport page now lists it for Q4 2026, roughly three months before the passports it governs become mandatory.
Against all of that, EUROBAT, the European battery industry association, has been publicly asking for a stop-the-clock: postpone passport enforcement from February 2027 to 2030. Their argument is not unreasonable on its face. Design requirements and the passport, they say, “should be enforced once the necessary infrastructure and technical standards have been finalised.”
So a battery importer reading the tea leaves in September 2026 has a defensible position available: this date is going to move, everything else did, and I should spend my money on something with a firmer deadline.
That position is probably right about the date. It is badly wrong about what follows from it.
What the slippage is made of
Be fair to the Commission for a moment, because the honest version of this story is more interesting than the cynical one.
The 18 February 2027 obligation has not moved. The Commission opened the battery passport registry on 20 July 2026 and described February 2027 as the first implementation deadline. Omnibus VIII simplified several things this year and left the passport date alone. Six horizontal DPP standards were published in May 2026 and cited in the Official Journal on 15 July 2026 through Commission Implementing Decision (EU) 2026/1736: unique identifiers, data carriers, data exchange, storage and persistence, APIs, interoperability. That is real, and it shipped.
And a reasonable analyst can argue, as some are, that the missed access-rights act barely touches manufacturers at all. The three access tiers were written into the regulation back in 2023. What is late is the operational detail of how a recycler proves they are a recycler. A brand can build the public tier and the authority tier today against Annex XIII and leave the legitimate-interest tier as a configurable role. That is sound advice and worth following.
But look at the shape of what slipped, rather than the size of it.
The six standards that made it into the Official Journal are the plumbing: identifiers, carriers, APIs, interoperability, persistence. The two that did not make it are EN 18239, on access control and confidentiality, and EN 18246, on the authentication, reliability and integrity of passport data. As of the last confirmed status, both were still working through approval, with definitive texts scheduled for September 2026.
The plumbing shipped. The locks are late. And the locks are late in a system where the one lock that was drafted, the authentication standard, had references to physical authentication elements removed from it, as the International Tax Stamp Association pointed out in November 2025.
Now stack the access-rights delay on top of that, and notice who is standing on the wrong side of it. The legitimate-interest tier exists for repairers, remanufacturers, second-life operators and recyclers. Those are precisely the people who handle a pack after its first life, who need to know its real composition before they cut it open or resell it, and who are least able to tell a genuine pack from a counterfeit one by looking. The rules for letting them in are the rules that are three months from go-live and not written.
The asymmetry
Every actor in this regulation has a negotiable schedule except one.
Manufacturers got two years on due diligence. The Commission has taken an extension on labelling, on carbon footprint methodology, and on access rights. The standards bodies are running behind on security. EUROBAT is asking for four more years on the passport itself, and given the track record above, they may well get some of it.
The counterfeit cell is not in the negotiation. Nobody is lobbying on its behalf for a delay, because it doesn’t need one. It ships on its own schedule, into e-bikes and scooters and power tools, missing the current interrupt device that stops an overcharge becoming a fire, and, per UL’s researchers, indistinguishable from a genuine cell without a CT scan.
A stop-the-clock to 2030 does not pause that. It pauses the paperwork that was supposed to describe it.
The sentence that costs us money
We sell chips, so here is the part a vendor is not supposed to write, and it is even less convenient than usual this time.
If the clock stops, the compliance argument for buying anything gets weaker, not stronger. No mandate requires a chip today. The Batteries Regulation names a QR code, a laser etcher satisfies it, and if February 2027 slides to 2030 then even that obligation recedes. Any vendor, us included, who tells a battery importer that this regulatory mess is a reason to purchase hardware is arguing backwards.
So we will make the other argument, the one that survives a stop-the-clock.
The reason to bind a pack to its own identity has never been the mandate. It is that the pack is going to come back. It comes back as a warranty claim you have to honour or refuse. It comes back on a recycler’s bench, as a cell chemistry that does not match the passport. It comes back in an incident report, as a fire in a garage, with your wordmark on the enclosure and no way for you to say whether the cells inside were ever yours. That happens in 2027 whether or not the regulation applies in 2027, and it happens in 2030 either way.
Article 16 made the technical case: a printed code is a claim about a surface, and after February 2027 a copied one will resolve to a genuine passport describing a different battery. This is the scheduling case, and it is simpler. The regulation’s dates are negotiable, and are being negotiated. The date on which somebody hands you a burned pack and asks whose it was is not on the Commission’s work programme.
The Aeroz Angle
Aeroz puts a secure NFC tag on the unit that answers a cryptographic challenge tied to that individual item when tapped with an ordinary phone. A photograph of a chip is a photograph. A recording of what it said does not reproduce the key that said it.
For a battery, that gives you three things the regulatory calendar cannot give you at any date.
You can answer the warranty question without a lab. You can let a recycler or a second-life operator confirm the pack is the pack before the access-rights implementing act tells them how to log in, because a tap does not need a legitimate-interest tier. And when a pack turns up in an incident, you can say whether it was yours, which is the only version of that conversation a brand ever wants to be in.
None of that replaces the QR code. The regulation requires the QR and the QR should be there. What a chip does is make the answer independent of Brussels’ timetable, which is the one variable in this entire file that nobody in industry controls.
The clock may stop. It has stopped for nearly everything else in this regulation.
Build for the deadline that can’t.
Aeroz, Making Authenticity Checkable. Visit aeroz.io to learn more & get in contact with our team via [email protected].
2026 Aeroz all rights reserved.