The UK is aligning, not diverging. Northern Ireland is already in.
Regulation (EU) 2023/1542 has applied in Northern Ireland since 18 February 2024 under the Windsor Framework. Great Britain has no passport regime yet, and the government has said it will consult on one consistent with the EU rules. A UK company selling into the EU or Northern Ireland faces Article 77 on 18 February 2027 like any EU company.
Inside the EU regime today, with the same dates.
The Regulation is listed in Annex 2 of the Windsor Framework, so it applies in Northern Ireland without transposition. CE marking and conformity assessment already apply. Gov.uk guidance from 17 July 2026 lists the milestones; draft enforcement regulations laid on 4 June 2026 add the UK(NI) indication beside the CE mark and offences carrying up to 12 months' imprisonment.
- 18 Feb 2024Regulation (EU) 2023/1542 applies in Northern Ireland
- 18 Aug 2026Labelling milestone in gov.uk guidanceSeparate-collection symbol required on all batteries since 18 August 2025
- 18 Feb 2027QR code, removability and the digital battery passportArticle 77 for LMT, EV and industrial batteries above 2 kWh
- 18 Aug 2027Supply-chain due diligencePostponed from 2025 by Regulation (EU) 2025/1561
- 18 Aug 2031Minimum recycled contentDocumentation of recycled content from 18 August 2028
What applies now, and what is coming.
No GB passport regime
The Batteries and Accumulators (Placing on the Market) Regulations 2008 and the Waste Batteries and Accumulators Regulations 2009 still apply. Neither requires a passport, a QR code or a registry entry.
CE marking recognised indefinitely
Since 1 October 2024 Great Britain recognises CE marking alongside UKCA with no end date. An EU-compliant battery is a GB-compliant battery, so building to the EU rules covers both markets.
"An aligned regime in Great Britain"
Defra minister Mary Creagh told the Commons committee the government "will consult in the autumn on an aligned regime in Great Britain that is consistent with the EU's 2023 batteries regulation", UK-wide, covering placing on the market and producer responsibility.
EU requirements can be treated as met
The Product Regulation and Metrology Act 2025 lets product regulations provide that a GB requirement is met where a specified EU requirement is met. It is the legal route for alignment.
EU passport requirements survey
The Department for Business and Trade surveyed UK manufacturers and exporters on the EU passport ahead of February 2027. Information-gathering only, by its own description, but a signal of where attention sits.
Digital product record call for evidence
A call for evidence on a UK "digital product record" ran to 21 September 2026. It references the EU passport applying in Northern Ireland and asks about costs, readiness and interoperability. Batteries are not singled out.
As of 3 September 2026 no GB consultation document had been published. The Hansard statement is the only official, dated commitment on GB batteries reform.
Dual compliance, in the right order.
- 1Selling into the EU or Northern Ireland? You need the EU passport, QR, identifier, registry entry and EU-hosted record on 18 February 2027. Where the battery is made does not matter.
- 2Selling only in Great Britain? Nothing is required yet. Building the EU record now means the GB regime, when it is published, is an addition rather than a second project.
- 3Importing into the UK from outside? The GB regime is expected to follow the EU text, including the duty on whoever places the battery on the market. Collect the same data from your suppliers now.
The UK is a delta pack.
Regulations are configuration on one battery data model. The EU pack produces the passport Northern Ireland and the EU need today. When the Great Britain regime is published, the GB pack adds its identifiers and reporting to the same record, on the roadmap for within a month of publication.
- ✓EU-resident hosting as authorised operator, which a UK company cannot provide for itself after leaving the Union.
- ✓Registration in the EU DPP Registry on your behalf, so eIDAS onboarding is handled.
- ✓Guides aligned to gov.uk wording and sessions with the Bicycle Association and SMMT when the GB consultation opens.
The demand side keeps growing while the rules catch up.
| Signal | Figure | Source |
|---|---|---|
| Battery-electric cars, 2025 | 473,348 registered, 23.4% share, against a 28% ZEV-mandate headline target | SMMT, 6 January 2026 |
| Battery-electric cars, January to July 2026 | 327,683 registered, 25.3% share; July 2026 a record 27.5% | SMMT, 5 August 2026 |
| ZEV mandate headline targets | 33% (2026), 38% (2027), 52% (2028), 66% (2029), 80% (2030); under review since 14 August 2026 with 50 to 70% options for 2030 | DfT consultation, August 2026 |
| Cell manufacturing | AESC Sunderland opened 17 December 2025 at 15.8 GWh; Agratas 40 GWh in Somerset not before 2027 | electrive; The Guardian |
| E-bikes | About 146,000 units in 2024; volumes up 2% and value up 10% in 2025 | Bicycle Association, March 2026 (derived) |
Exporting to the EU or Northern Ireland? Check where you stand.
Fourteen questions across the data-point categories and the operational duties. Nothing is sent unless you choose to email the result.