Batteries, machinery, appliances and electronics · Checklist

Battery Regulation Regulation (EU) 2023/1542 In force Key date:2027-02-18

• Carbon footprint declaration Calculate and declare the carbon footprint under the delegated act methodology; verification is required and green certificate offsetting is restricted. Trigger:Placing batteries on the EU market (by category and timetable) · Evidence:Carbon footprint declaration, verification report · Timing:EV 2025-02-18 / industrial >2 kWh 2026-02-18 / LMT 2028-08-18
• Battery passport and QR marking Provide composition, carbon footprint, recycled content and other data via a unique identifier and QR code. Trigger:Batteries placed on the EU market · Evidence:Battery passport data, QR marking · Timing:2027-02-18
• Disclose recycled content Disclose the recycled share of cobalt, lead, lithium, nickel and others, increasing in stages. Trigger:Batteries placed on the EU market · Evidence:Recycled content documents, verification report · Timing:From 2031-08-18 (second stage 2036-08-18)
• Supply chain due diligence Carry out due diligence for cobalt, natural graphite, lithium and nickel in accordance with OECD guidance. Trigger:Battery producers with annual turnover above €40 million · Evidence:Due diligence policy and report · Timing:2027-08-18 (deferred by 2025/1561)

Ecodesign for Sustainable Products ESPR Regulation (EU) 2024/1781 In force Key date:2024

• Digital product passport (DPP) and ecodesign Covered products must provide a DPP and meet the ecodesign requirements of delegated acts. Trigger:Covered product groups (as delegated acts are adopted successively) · Evidence:DPP, declaration of conformity, technical documentation · Timing:First working plan 2025–2030

CBAM Downstream Extension COM(2025) 989 final In progress Key date:proposed 2028-01

• Prepare supply chain emissions data for downstream products Around 180 steel- and aluminium-intensive downstream products are planned for inclusion; upstream emissions data must be obtained in advance. Trigger:Exporting fasteners, steel wire, springs, household appliances, machinery parts, etc. to the EU · Evidence:Supplier carbon footprint data, bill of materials (BOM) · Timing:Planned from 2028 [under review]

Fluorinated Gases Regulation Regulation (EU) 2024/573 In force Key date:2024

• Comply with F-gas quotas and leak checks Production, import and use are subject to quotas, with leak checks and reporting. Trigger:Production/import of fluorinated greenhouse gases or operation of equipment containing them · Evidence:Quota records, leak check reports, operator certification · Timing:Phased after 2024/573 enters into force

Net-Zero Industry Act NZIA Regulation (EU) 2024/1735 In force Key date:2024

• Net-zero technology projects benefit from fast-track permitting and auction criteria Manufacturing projects for solar, batteries, electrolysers, etc. may use fast-track permitting and non-price criteria. Trigger:Investing in net-zero technology manufacturing in the EU · Evidence:Project application documents, sustainability/resilience evidence · Timing:After 2024/1735 enters into force

Critical Raw Materials Act CRMA Regulation (EU) 2024/1252 In force Key date:2024

• Due diligence and certification in critical raw material supply chains Carry out risk management and certification for critical raw material supply chains. Trigger:Companies using/processing critical raw materials · Evidence:Supply chain audits, certification evidence · Timing:Phased after 2024/1252 enters into force

Industrial Emissions Directive IED 2.0 Directive (EU) 2024/1785 In force Key date:2026-07-01 transposition

• Obtain an IED integrated permit and comply with BAT Operate in accordance with best available techniques (BAT/BREF) and apply an environmental management system. Trigger:Industrial activities listed in Annex I to the IED · Evidence:IED permit, BAT compliance assessment, environmental management system · Timing:After transposition of 2024/1785
• Submit a transformation plan The new IED requires high-emission installations to provide a decarbonisation transformation plan. Trigger:Energy-intensive installations subject to the IED · Evidence:Decarbonisation transformation plan · Timing:After transposition of 2024/1785

Waste Framework Directive Directive 2008/98/EC In force Key date:2008 (as amended by 2018/851)

• Apply the waste hierarchy, prioritising prevention, reuse and recycling Waste prevention and management legislation must follow the priority order of prevention, preparing for reuse, recycling, other recovery and disposal. Trigger:Generating or managing waste · Evidence:Waste management plans, disposal and recovery records · Timing:Ongoing
• Meet reuse and recycling targets Household waste and construction and demolition waste must meet the prescribed reuse and recycling rates. Trigger:Management of household waste and construction and demolition waste · Evidence:Recycling rate statistics and reports · Timing:Phased from 2020
• Meet producer responsibility (EPR) Within the scope of extended producer responsibility, organisational and cost obligations for take-back and disposal apply. Trigger:Product falls within the scope of extended producer responsibility · Evidence:EPR registration, records of fulfilment of take-back obligations · Timing:According to Member State transposition rules

Waste Electrical and Electronic Equipment Directive Directive 2012/19/EU In force Key date:2012

• EEE producers register and finance take-back Producers must register in the Member State of sale, finance the collection and treatment of waste equipment and meet recovery targets. Trigger:Placing equipment covered by the WEEE Directive on the market in a Member State · Evidence:Producer registration number, take-back contracts and declarations · Timing:Registration before placing on the market
• Foreign producers generally must appoint an authorised representative The Directive requires Member States to organise take-back. Registration numbers such as German EAR and French IDU are national market access procedures, not a uniform number in the Directive itself. Trigger:Producers not established in the Member State of sale · Evidence:Appointment of an authorised representative and national registration evidence · Timing:Before first placing on the market