EU Battery Regulation 2023/1542: The HS 8507.60 Compliance Calendar

Since 18 August 2024, the Regulation's economic-operator chapter has been in force, and Article 41(2) is the clause that reaches the Indian factory: before placing a battery on the EU market, the importer must verify that the manufacturer has carried out the conformity assessment (Art. 17), drawn up the EU declaration of conformity (Art. 18, Annex IX model) and the technical documentation of Annex VIII; that the battery bears the CE marking (Art. 19) and is marked and labelled per Article 13; and that it is accompanied by required documents and safety information. An importer that cannot evidence these does not have a compliant import — which makes each item a line in the Indian exporter's shipment packet, not a European formality.

Two practical notes sit inside that list. Conformity assessment for most current requirements runs under internal production control (Module A) or unit verification (Module G); once the carbon-footprint and recycled-content articles bite, Module D1 with notified-body involvement becomes the required route (Art. 17(2)) — a structural step up in audit exposure for the manufacturer. And the substantive product requirements (safety, substances, performance) have applied since 18 February 2024 (Art. 96), so "the Regulation hasn't started" has been wrong for over two years.

Two headline obligations carry fixed dates an exporter can plan against. From 18 February 2027, every EV battery, LMT (light means of transport) battery and industrial battery above 2 kWh placed on the market or put into service must have a battery passport (Art. 77(1)) — an electronic record, addressed by the QR code that Article 13(6) requires on all batteries from the same date, carrying the Annex XIII data set: identity, composition, carbon-footprint information as applicable, performance and durability data. The passport is a data-supply obligation in practice: the importer or manufacturer publishes it, but the content originates in the Indian plant's records, which means the 2026 build-out work is data plumbing, not labels.

From 18 August 2027, the supply-chain due-diligence chapter (Arts. 47–53) applies — policies over the raw-material chain (cobalt, lithium, nickel, natural graphite), third-party verification, and annual reporting — for economic operators above the €40 million turnover threshold of Article 47. The date itself is the story: originally 18 August 2025, it was postponed two years by Regulation (EU) 2025/1561 (18 July 2025), with the Commission's guidelines due 26 July 2026. An Indian exporter whose EU customers demanded due-diligence packages "for August 2025" is entitled to the corrected date — and should expect the demand to return, contractually, well before 2027.

The EV carbon-footprint declaration (Article 7) is not yet in force, and its start date is floating by design. Article 7(1) applies from "18 February 2025 or 12 months after the entry into force of the delegated act (methodology) or the implementing act (declaration format), whichever is the latest" — and as of July 2026 neither act is adopted: the draft methodology has sat in the Commission's process since its April 2024 feedback round (initiative 13877), the format act (13878) likewise, and the Commission's own JRC states it is awaiting the final calculation rules. The practical reading: the earliest the declaration can bind is a year after adoption day, whenever that comes, and the recycled-content declaration (Art. 8) floats the same way toward 2028.

The floating clock cuts both ways commercially. Exporters should not certify to a methodology that does not exist — a "carbon-footprint declaration" produced today is a marketing document, not an Article 7 instrument. But the battery passport's data fields and EU buyers' procurement questionnaires are already pulling the same numbers, so the plant-level energy and material accounting that Article 7 will formalise is worth building now, once, to serve passport, buyer and — when it lands — the delegated act. The cross-regime pattern is the one CBAM already demonstrates for metals: EU importer obligations cascade upstream as data demands on the Indian producer.

The compliance calendar collapses into a per-shipment checklist with three tiers: now (CE marking, declaration of conformity, Annex VIII file, Article 13 labelling as applicable, the Article 41 document set for the importer), dated (passport data readiness and QR implementation before 18.02.2027; due-diligence policy and chain mapping before 18.08.2027 where the threshold bites), and floating (Article 7/8 declarations — tracked against adoption of the delegated acts, not against rumour). Each tier is checkable against the Regulation's text, which is what makes the calendar auditable rather than aspirational.

TradeWatch carries this calendar inside its readiness packets for the EV lane: the Article 41 document set validated per shipment, the fixed dates tracked as approaching obligations, and the floating dates monitored against the Official Journal — each item cited to its article. Kanan Labs prepares evidence and readiness; conformity assessment and EU market placement remain the manufacturer's and importer's own legal acts.