Selling batteries into the UK: what changed in October, and what did not

Three markets, three different answers

If you place EV, LMT or industrial batteries on the EU market and also sell into the United Kingdom, October changed your picture in two places. Northern Ireland now has UK enforcement behind the EU Battery Regulation. Great Britain has said, on the parliamentary record, that a mandatory QR code and a digital battery passport are under consideration. Neither moves the date your EU passports are due: 18 February 2027.

This is for importers, authorised representatives and manufacturers outside the EU who need to know what applies where.

Northern Ireland: the EU rules, now with UK enforcement behind them

Regulation (EU) 2023/1542 has applied in Northern Ireland since 18 February 2024 under the Windsor Framework. What was missing was the UK machinery to enforce it. The Batteries (Placing on the Market) (Northern Ireland) Regulations 2026, SI 2026/1053, were made on 25 September 2026 and came into force on 17 October. They also revoke the old 2008 UK battery regulations in relation to Northern Ireland, keeping only the capacity-labelling and removability rules until their EU replacements apply.

Who enforces. The regulations make the Secretary of State responsible for enforcing them and the EU Regulation in Northern Ireland, and add them to the Market Surveillance (Northern Ireland) Regulations 2021. The government's guidance names the Office for Product Safety and Standards as the contact for compliance questions.

What is covered. The regulations set penalties for breaches of a listed set of articles. The list reaches the obligations of manufacturers, cell and module suppliers, authorised representatives (Article 40), importers, distributors and fulfilment service providers, the identification of economic operators (Article 46), removability and replaceability (Article 11) and the due diligence provisions. Through the manufacturer, importer and distributor duties, it also reaches the labelling requirements of Article 13, which include the QR code.

What is not listed. The passport provisions, Articles 77 and 78, are not among the listed articles. That does not remove the obligation. The government's guidance confirms that from 18 February 2027 each LMT battery, each industrial battery above 2 kWh and each electric vehicle battery placed on the market needs a battery passport, because the EU Regulation applies there.

Batteries already on the market. The enforcement provisions do not apply to a battery placed on the market or made available before 17 October, unless an importer or distributor later modifies it or changes its purpose, or it goes through re-use, repurposing or remanufacturing.

A defence for those who check. For the core duties of manufacturers, importers and distributors, and of those placing re-used or remanufactured batteries on the market, it is a defence to show that all reasonable steps and all due diligence were taken. Relying on information from someone else only counts where it was reasonable to rely on it, having regard to what was done to verify it.

The UK(NI) mark. Where a battery's conformity has been assessed by a UK notified body, the CE marking must be accompanied by the UK(NI) indication. An authorised representative affixes it instead of the manufacturer only if its mandate says so.

Moving on to Great Britain. A battery that meets the EU Regulation and the UK(NI) rule and is a qualifying Northern Ireland good may be placed on the market in Great Britain as if it met the GB regulations.

For a non-EU manufacturer selling into Northern Ireland, the practical point is the mandate. With those duties now enforceable there, both sides will want the mandate to say precisely what the representative does and what it holds.

What else is due in Northern Ireland, and when

The government's guidance for Northern Ireland sets out the rest of the EU timetable. Dates it marks as depending on further EU acts are the earliest possible dates.

• Labels with general information, capacity labels for rechargeable portable, LMT and SLI batteries, and the non-rechargeable label: on or after 18 August 2026, subject to EU implementing acts.
• Removability and replaceability of portable and LMT batteries: 18 February 2027.
• A QR code on every battery: 18 February 2027, subject to EU implementing acts.
• The battery passport for LMT, EV and industrial batteries above 2 kWh: 18 February 2027.
• Due diligence policies: 18 August 2027, two years later than originally set.
• Minimum performance and durability values: from 18 August 2027 for rechargeable industrial batteries above 2 kWh, and from 18 August 2028 for LMT batteries, at the earliest.
• Carbon footprint declarations and classes: the supporting EU acts are delayed, so no firm date yet.

Waste battery management and producer responsibility sit outside that guidance; queries go to the Department of Agriculture, Environment and Rural Affairs.

Great Britain: a passport is on the table, not in law

In Great Britain the Batteries and Accumulators (Placing on the Market) Regulations 2008 still apply, implementing the old 2006 Directive. There is no battery passport requirement in Great Britain today.

On 19 October 2026 two departments answered written questions on the subject. The Department for Business, Innovation, Science and Trade said: "The Government intends to consult this autumn on proposal for an aligned UK-wide batteries regime. This will include consideration of strengthened labelling requirements and a mandatory QR code providing access to a digital battery passport alongside other measures." Defra said it "intends to consult in due course on consistency with the EU's 2023 Batteries Regulation, including requirements for digital battery passports, targets for recovery of certain materials, and limits on lead in portable batteries."

That is the clearest statement yet, and it is still a statement of intent. As of 26 October the consultation has not opened. Nothing yet says what a Great Britain passport would contain, when it would apply, or whether a passport issued for the EU market would satisfy it. Anyone telling you one passport will cover the EU, Northern Ireland and Great Britain is ahead of the text.

How it would become law. The Product Regulation and Metrology Act 2025 lets the Secretary of State make regulations for products marketed or used in the United Kingdom that correspond, or are similar, to EU product law, for the purpose of reducing their environmental impact. Those regulations can set requirements on marking, information, documents and the appointment of authorised representatives. Batteries are not among the products the Act excludes. A Great Britain passport could therefore be introduced by regulations under that Act after the consultation, rather than by a new Act of Parliament.

The EU headline that is not about your passport

You may see reports that the EU is suspending authorised-representative rules for batteries. The proposal behind them, COM(2025) 982, suspends Article 56(3) of the Battery Regulation until January 2035. That is the authorised representative for extended producer responsibility: the person a producer appoints to meet collection and recycling obligations in a Member State where it is not established. The proposal is aimed at producers established in the Union and selling into other Member States. The European Parliament adopted its position on 20 October 2026 and the file has gone to negotiation with the Council, so the final text is not settled.

It does not touch Article 40, the authorised representative a non-EU manufacturer appoints for product compliance, and it does not touch the battery passport.

One product line, three markets

Take a single battery model sold into the EU, Northern Ireland and Great Britain.

A battery placed on the EU or Northern Ireland market follows one rulebook: CE marking, the Article 13 labels and QR code, and from 18 February 2027 a passport built against Annex XIII if it is an EV, LMT or industrial battery above 2 kWh. If a UK notified body assessed it, the UK(NI) mark goes beside the CE marking.

A battery sold only in Great Britain follows the 2008 regulations: no passport and no QR code requirement today.

Stock does not always stay where it was planned. A battery shipped to Great Britain and later first made available in Northern Ireland has to meet the EU rules at that point. Going the other way, a qualifying Northern Ireland good that meets the EU rules can be sold in Great Britain on that basis. Building the passport for every in-scope battery, whatever its first destination, is one way to avoid tracking which units might cross the Irish Sea.

On EU Digital Passport Processor a passport is built once per battery against Annex XIII and is the same record whether the battery is sold in the EU or in Northern Ireland. Requests for its restricted data accept Northern Ireland VAT numbers, with the XI prefix, alongside EU ones.

What to do with this

If you place batteries on the EU market, your passport work is unchanged: EV batteries, LMT batteries and industrial batteries above 2 kWh need a passport from 18 February 2027 under Article 77.

If you also sell into Northern Ireland, it is the same obligation under the same Regulation, now with UK enforcement behind the operator and authorised-representative duties. A passport built against Annex XIII is the same passport whether the battery goes to Dublin or Belfast. Check your mandate.

If you sell into Great Britain, there is nothing to comply with yet, but the direction is now on the record. When the consultation opens, it will be the first chance to see whether Great Britain proposes to recognise passports issued for the EU or to require its own. If you have a view, that is the place to give it.

If you sell from outside the EU and need a representative for Article 40, see how our authorised-representative service works.

Sources: SI 2026/1053, https://www.legislation.gov.uk/uksi/2026/1053/made; GOV.UK, EU Batteries Regulations in Northern Ireland (updated 17 October 2026), https://www.gov.uk/guidance/eu-batteries-regulations-in-northern-ireland; Product Regulation and Metrology Act 2025, sections 1 and 2 and Schedule, https://www.legislation.gov.uk/ukpga/2025/20/contents; written answers UIN 31813 (BIST) and UIN 33479 (Defra), 19 October 2026, https://questions-statements.parliament.uk; COM(2025) 982 and procedure 2025/0395(COD), https://oeil.secure.europarl.europa.eu/oeil/en/procedure-file?reference=2025/0395(COD)