United Kingdom

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.

63%
of 80 UK battery-chain organisations surveyed were unaware of the EU regulation; 73% among those exporting to the EU
Loughborough University, January 2026
76%
had yet to consider changes for the digital requirements; 54% cited financial constraints
Same study, 2023 fieldwork
473,348
battery-electric cars registered in the UK in 2025, a 23.4% share and up 23.9%
SMMT, January 2026
~146,000
e-bikes sold in the UK in 2024, with volumes up 2% in 2025
Derived from Bicycle Association reporting
Northern Ireland

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 2024
    Regulation (EU) 2023/1542 applies in Northern Ireland
  • 18 Aug 2026
    Labelling milestone in gov.uk guidance
    Separate-collection symbol required on all batteries since 18 August 2025
  • 18 Feb 2027
    QR code, removability and the digital battery passport
    Article 77 for LMT, EV and industrial batteries above 2 kWh
  • 18 Aug 2027
    Supply-chain due diligence
    Postponed from 2025 by Regulation (EU) 2025/1561
  • 18 Aug 2031
    Minimum recycled content
    Documentation of recycled content from 18 August 2028
Great Britain

What applies now, and what is coming.

Today

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.

SI 2024/696

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.

8 July 2026 · Hansard

"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.

PRM Act 2025, s.2(7)

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.

15 June 2026 · DBT

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.

27 July 2026 · DBT

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.

What this means

Dual compliance, in the right order.

  • 1
    Selling 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.
  • 2
    Selling 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.
  • 3
    Importing 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.
How CellHash handles it

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.
UK market context

The demand side keeps growing while the rules catch up.

SignalFigureSource
Battery-electric cars, 2025473,348 registered, 23.4% share, against a 28% ZEV-mandate headline targetSMMT, 6 January 2026
Battery-electric cars, January to July 2026327,683 registered, 25.3% share; July 2026 a record 27.5%SMMT, 5 August 2026
ZEV mandate headline targets33% (2026), 38% (2027), 52% (2028), 66% (2029), 80% (2030); under review since 14 August 2026 with 50 to 70% options for 2030DfT consultation, August 2026
Cell manufacturingAESC Sunderland opened 17 December 2025 at 15.8 GWh; Agratas 40 GWh in Somerset not before 2027electrive; The Guardian
E-bikesAbout 146,000 units in 2024; volumes up 2% and value up 10% in 2025Bicycle 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.