Today is not the battery-labelling deadline — what Article 13 actually says

No. Article 13(1) of Regulation (EU) 2023/1542 requires the general information set out in Part A of Annex VI to appear on batteries "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". Article 13(2) (capacity label for rechargeable portable, LMT and SLI batteries) and Article 13(3) (minimum average duration and the 'non-rechargeable' label) carry the same conditional date.

The condition is not academic. The Article 13(10) implementing act — which sets the harmonised specifications for those labels — was itself due by 18 August 2025. It was released only in draft in December 2025, with adoption expected in Q2 2026. Because the regulation says "whichever is the latest", the operative date moves out to roughly 18 months after that act enters into force, which is later than today.

So a headline calling today the deadline is describing the earlier of two triggers as though the later one did not exist. The correct reading for a compliance plan: the obligation is certain, the date is not yet fixed, and it will be confirmed by the publication date of the implementing act — not by a calendar you set in 2024.

• Article 13(1)–(3): 18 August 2026 or 18 months after the Article 13(10) implementing act enters into force, whichever is the latest — expected, not fixed.
• Article 13(10) implementing act: due 18 August 2025, draft published December 2025, adoption expected Q2 2026.
• Practical effect: the real trigger for general-information and capacity labels falls after today.

Two obligations carry no implementing-act clause at all, and those are the ones to hold your programme to.

The separate-collection symbol under Article 13(4) has applied since 18 August 2025 — sized at least 3 % of the largest side (1,5 % for cylindrical cells), capped at 5 × 5 cm, and moved to the packaging at a minimum 1 × 1 cm where the battery is too small. Where the cadmium threshold of 0,002 % or the lead threshold of 0,004 % is exceeded, Article 13(5) requires Cd or Pb beneath that symbol. If those markings are not on packs today, that is a live non-conformity, not a future date.

The QR code under Article 13(6) applies from 18 February 2027, and the battery passport under Article 77 applies from the same day. Both dates are stated outright in the regulation with no "whichever is the latest" wording, which makes them the hard edges of the plan. Our earlier issue on the 18 August labelling package sets out the Annex VI Part A content item by item, and the battery-passport hub covers the data side of February 2027.

• 18 August 2025 — separate-collection symbol (Art 13(4)) and Cd/Pb marking (Art 13(5)): already applying.
• 18 February 2027 — QR code (Art 13(6)) and battery passport (Art 77): fixed, no implementing-act condition.
• Article 13(1)–(3) general information and capacity label: conditional, expected after today.

Manufacturers should not slow down. The content of Annex VI Part A is already known, and the implementing act governs specifications and format rather than whether the information is required. Freezing artwork now buys you the option of shipping compliant packs early; waiting for the act converts an 18-month runway into a print-capacity scramble, because every competitor's converter slot request lands in the same quarter.

Importers carry the sharper risk from the myth in both directions. Believing today is the deadline can trigger an unnecessary relabelling programme on stock that is already lawful; believing nothing applies until 2027 leaves the Article 13(4) collection symbol — which has applied for a year — unchecked on incoming shipments. Verify the incoming label against Article 13(4) and (5) today, and against Annex VI Part A before the act's transition ends.

Certifiers, notified bodies and market-surveillance authorities work from the regulation, not the trade press. Expect a check today to focus on the collection symbol, the Cd/Pb marking, and the Annex VIII technical file, and expect capacity or minimum-average-duration values to be traced to test reports once the Article 13(1)–(3) labels bite.

• Manufacturers: keep the artwork-freeze date, treat the implementing act as a specification input rather than a start signal.
• Importers: audit the collection symbol and Cd/Pb marking now; do not relabel compliant stock on the strength of a press date.
• Certifiers and authorities: today's evidence set is Article 13(4)–(5) plus the Annex VIII label specimen.

Plan to a monitored date rather than a fixed one. Record two entries in the compliance calendar: the publication of the Article 13(10) implementing act as a watch item, and a derived label-application date of that publication plus 18 months, recalculated the day the act appears in the Official Journal.

Then work backwards from the derived date by your converter's real lead time — typically eight to sixteen weeks for consumer and industrial packaging — and hold that artwork-freeze date even while the legal date is unconfirmed. The asymmetry is what matters: being early costs a print run, being late costs market access.