EU Battery Passport for Korean 21700 NMC Cells: 2027 Deadline Checklist for EU Importers

From 18 February 2027, industrial batteries over 2 kWh and EV batteries placed on the EU market must carry a digital battery passport — accessible by QR code — under Regulation (EU) 2023/1542. For EU buyers sourcing Korean 21700 NMC cylindrical cells, the key question is not whether the passport rule covers the individual cell: it is whether the finished battery assembled from those cells crosses the scope threshold. This checklist covers which batteries fall in scope, the four obligation dates every importer should track, the document package the Korean cell maker must supply, and two obligations — due diligence and the carbon footprint declaration — that are not yet in force.

Does Your Battery Assembly Need an EU Battery Passport?

According to EUR-Lex, from 18 February 2027, batteries for light means of transport (LMT), industrial batteries with a capacity greater than 2 kWh, and electric-vehicle (EV) batteries placed on the EU market must each have a digital battery passport accessible via the QR code. The economic operator placing the battery on the market is responsible for ensuring the passport is accurate, up to date and complete.

The 21700 NMC cell is a component; the passport scope is determined by the finished battery. Cells assembled into an industrial energy storage system over 2 kWh, an EV battery pack, or a light electric vehicle battery bring the finished product into scope. Power tools and smaller portable electronics are not listed in these scope categories. The EU importer or assembler that places the finished battery on the EU market carries the passport obligation. The Korean cell maker — outside the EU — is responsible for supplying the underlying data and test results that the EU operator needs to build and maintain the passport.

Does the finished battery need an EU battery passport?

What type of finished battery is assembled from the Korean 21700 NMC cells?

• Light means of transport (LMT) battery — e-bikes, e-scooters, light electric vehicles→ Battery passport required from 18 February 2027. The EU operator placing the finished battery on the market is responsible for passport accuracy and completeness.
• Industrial battery with a capacity greater than 2 kWh — e.g., ESS, stationary storage→ Battery passport required from 18 February 2027. The EU operator placing the finished battery on the market is responsible for passport accuracy and completeness.
• Electric vehicle (EV) battery→ Battery passport required from 18 February 2027. The EU operator placing the finished battery on the market is responsible for passport accuracy and completeness.
• Other application — e.g., power tools, portable electronics not in the above categories→ Battery passport not required under these categories as of 18 February 2027. Standard EU Batteries Regulation labelling and conformity obligations still apply.

Four Dates Every Korean 21700 Cell Exporter Should Track

Regulation (EU) 2023/1542 phases in its obligations on separate, fixed dates. According to EUR-Lex, the Regulation entered into force on 17 August 2023 and has applied since 18 February 2024. Several of its requirements apply later, and two are not yet on fixed dates at all.

The separate-collection symbol marking has applied since 18 August 2025, per Article 13(4). The general label carrying the information in Annex VI Part A applies from 18 August 2026, per Article 13(1). From 18 February 2027, all batteries must carry a QR code as described in Annex VI Part C, per Article 13(6), and the digital battery passport becomes mandatory for in-scope batteries. Supply-chain due diligence — covering the responsible sourcing of cobalt, natural graphite, lithium and nickel — was postponed from 18 August 2025 to 18 August 2027 by Regulation (EU) 2025/1561. The EV-battery carbon footprint declaration has no fixed start date; its trigger depends on delegated and implementing acts that were not finalised as of late 2025.

Key obligation dates for Korean 21700 NMC cell exporters targeting the EU

	Obligation	Effective date
Separate-collection symbol on batteries (Art. 13(4))	In force	18 August 2025
General label, Annex VI Part A information (Art. 13(1))	Upcoming	18 August 2026
QR code on all batteries (Art. 13(6)) + battery passport for LMT, industrial >2 kWh, EV	Upcoming	18 February 2027
Supply-chain due diligence for cobalt, graphite, lithium, nickel (postponed by Reg. (EU) 2025/1561)	Upcoming	18 August 2027
EV-battery carbon footprint declaration (Art. 7) — conditional on delegated and implementing acts	Conditional	12 months after the relevant delegated act and implementing act enter into force

The Document Package the Korean Cell Maker Must Supply

An EU importer or pack assembler sourcing 21700 NMC cells needs a complete document set from the Korean maker before placing the finished battery on the EU market. The package covers three areas: transport safety, product safety, and EU conformity evidence.

For transport, according to Battery University, the UN 38.3 Lithium Battery Test Summary has been mandatory since 2020. It documents the full eight-test series for the lithium-ion cell classified as dangerous goods. According to GWP Group, lithium-ion batteries are Class 9 (miscellaneous) dangerous goods: UN3480 applies to cells shipped on their own; UN3481 applies to cells packed with or contained in equipment. A dangerous-goods declaration is required for every shipment. For air freight of standalone UN3480 cells, the IATA Dangerous Goods Regulations require a maximum state of charge of 30% of rated capacity.

For product safety, according to the International Electrotechnical Commission (IEC), IEC 62133-2:2017 specifies safety requirements for portable sealed secondary lithium cells and batteries under intended use and reasonably foreseeable misuse. The test report from this standard is a direct input to the EU technical documentation file that the conformity assessment is based on.

For EU conformity, the operator placing the finished battery on the EU market draws up the EU Declaration of Conformity and affixes CE marking under Articles 17-20 of Regulation (EU) 2023/1542. The Korean cell maker is not the placing-on-market operator, but must provide the underlying test results and technical data so the EU operator can complete this step. A safety data sheet is commonly requested by freight forwarders and importers for dangerous-goods handling; it is not a statutory EU requirement for the battery itself.

EU market preparation checklist for Korean 21700 NMC cell makers

• ✓ UN 38.3 Lithium Battery Test Summary — current and cell-model-specificMandatory for transport of lithium-ion cells classified as Class 9 dangerous goods; required since 2020. Covers the full eight-test series (T1–T8) for UN3480 and UN3481.
• ✓ UN3480 / UN3481 classification and dangerous-goods declarationUN3480 for cells shipped on their own; UN3481 for cells packed with or in equipment. Air freight of standalone UN3480 cells: maximum 30% state of charge per IATA DGR.
• ✓ IEC 62133-2:2017 test report for the 21700 NMC cellProduct-safety standard for portable sealed secondary lithium cells; feeds the EU technical documentation file that underpins the conformity assessment.
• ✓ Cell technical data sheet — specifications, chemistry, capacity, voltageInput for the EU importer's technical documentation file and, from 2027, the battery passport data fields for in-scope finished batteries assembled from the cells.
• ✓ Annex VI label data — ready for EU importer to apply from 18 August 2026The EU placing-on-market operator applies the label; the Korean cell maker supplies the underlying data inputs (capacity, chemistry, separate-collection symbol compliance).
• ✓ Sourcing chain records for cobalt, natural graphite, lithium and nickelRequired for supply-chain due diligence from 18 August 2027, postponed by Regulation (EU) 2025/1561. Begin supplier mapping now so evidence is ready before the deadline.
• ✓ Battery passport data feed plan — for in-scope finished batteries by 18 February 2027The EU placing-on-market operator builds and maintains the passport; the Korean cell maker supplies cell-level technical data, test results and sourcing records as inputs.

How Battery Data Flows from the Korean Maker to the EU Passport

The EU battery passport is a data record, not a paper certificate. It is linked to the QR code on the battery and must be kept accurate and up to date by the EU economic operator that places the battery on the market. Understanding the data chain helps both the Korean cell maker and the EU importer plan what to collect, when to hand it over, and who is accountable for each part.

The Korean cell maker generates the primary technical evidence: the UN 38.3 Lithium Battery Test Summary, the IEC 62133-2:2017 safety test report, cell technical specifications, and sourcing records for cobalt, natural graphite, lithium and nickel — the four materials named in the due-diligence rules. The EU importer or assembler uses this evidence to run the conformity assessment, draw up the EU Declaration of Conformity, and then build and maintain the battery passport. From 18 February 2027, for in-scope batteries, the QR code must link to a passport that is complete and accurate at the time of placing on the market. The EU economic operator placing the battery on the market is legally responsible for that accuracy.

How battery data flows from the Korean cell maker to the EU battery passport

1. 1

   Korean cell maker runs tests and gathers sourcing data

   UN 38.3 Lithium Battery Test Summary, IEC 62133-2:2017 safety test report, cell technical specifications, and sourcing records for cobalt, natural graphite, lithium and nickel.

2. 2

   Cell maker hands the complete evidence package to the EU importer

   Transport documents (UN3480/UN3481 classification, dangerous-goods declaration), product-safety test reports, and technical data sheet. A safety data sheet is supplied if the freight forwarder requests it — it is not a statutory EU battery requirement.

3. 3

   EU operator assembles the finished battery and runs conformity assessment

   The EU importer or pack assembler uses the cell maker's evidence to build the EU technical documentation file, run the conformity assessment under Articles 17-20 of Regulation (EU) 2023/1542, and draw up the EU Declaration of Conformity.

4. 4

   EU operator affixes CE marking and Annex VI label

   CE marking applies now; general Annex VI Part A label from 18 August 2026; QR code (Annex VI Part C) from 18 February 2027.

5. 5

   EU operator creates and maintains the digital battery passport (from 18 Feb 2027, in-scope batteries)

   The QR code on the battery links to the passport. The EU economic operator placing the battery on the market is legally responsible for keeping it accurate, up to date and complete.

Carbon Footprint and Due Diligence: What Is and Is Not Yet in Force

Two areas of Regulation (EU) 2023/1542 are often stated incorrectly in secondary sources. Getting the status of each right matters before building a compliance timeline.

The carbon footprint declaration is not yet enforceable for EV batteries. According to EUR-Lex, Article 7(1) states the EV-battery carbon footprint declaration applies from 18 February 2025 or 12 months after the relevant delegated act and implementing act enter into force, whichever is the latest. Because those acts were not finalised as of late 2025, the obligation is deferred to 12 months after they enter into force. Many blogs quote the nominal 2025 date as if it were live — it is not. The practical step now is to begin building carbon-accounting data for NMC cell chemistry, without treating the declaration as an active requirement.

Supply-chain due diligence was genuinely postponed. According to EUR-Lex, Regulation (EU) 2025/1561 moved the due-diligence obligation for responsible sourcing of cobalt, natural graphite, lithium and nickel from 18 August 2025 to 18 August 2027. According to the Council of the European Union, this stop-the-clock amendment entered into force on 30 July 2025. For Korean NMC cell makers, all four named materials are central to the cell chemistry. The additional time should be used to map sourcing chains and gather supplier records so that the evidence base is in place well before August 2027.

Carbon footprint declaration status: still conditional

The EV-battery carbon footprint declaration is not yet enforceable

Article 7(1) of Regulation (EU) 2023/1542 sets the EV-battery carbon footprint declaration trigger as 18 February 2025 or 12 months after the relevant delegated act and implementing act enter into force, whichever is the latest. Those acts were not finalised as of late 2025. The obligation begins 12 months after they enter into force — not on the nominal 2025 date that many secondary sources quote as live. Track both acts via the European Commission environment pages before building any carbon-footprint declaration timeline.

Last updated: 2026-06. This article is for general informational purposes only. Requirements under Regulation (EU) 2023/1542 and related regulations change; several obligations depend on delegated or implementing acts not yet in force, and others phase in on future dates. Confirm current requirements with EUR-Lex, the European Commission, a notified body, your testing laboratory, and a qualified regulatory or customs professional before shipping or placing Korean lithium-ion battery cells or finished batteries on the EU market.

Frequently Asked Questions

Do individual 21700 NMC cells need an EU battery passport, or only the finished battery?

Only the finished battery triggers the passport requirement — not the individual cell component. According to EUR-Lex, from 18 February 2027, batteries for light means of transport, industrial batteries over 2 kWh, and EV batteries placed on the EU market need a digital battery passport. A 21700 NMC cell sold as a component to a pack assembler is not itself a battery placed on the EU market for passport purposes; the assembled, placed finished product determines the obligation.

Which finished batteries built from 21700 NMC cells fall within the 2027 passport scope?

Any LMT battery — e-bikes, e-scooters, light electric vehicles — any industrial battery with a capacity above 2 kWh, and any EV battery falls in scope from 18 February 2027 under Regulation (EU) 2023/1542. Power tools and small portable electronics are not listed in these scope categories. For 21700 NMC cells, the most likely in-scope applications are ESS assemblies over 2 kWh, LEV and e-bike packs, and EV battery modules and packs.

What must the QR code on a battery link to from 18 February 2027?

According to EUR-Lex, from 18 February 2027, all batteries must carry a QR code as described in Annex VI Part C of Regulation (EU) 2023/1542. For in-scope batteries — LMT, industrial over 2 kWh, and EV — the QR code is the entry point to the digital battery passport. The EU economic operator placing the battery on the market is responsible for ensuring the passport is accurate, up to date and complete, both at the time of placing on the market and throughout the battery's useful life.

Has the supply-chain due-diligence requirement for cobalt and lithium been delayed?

Yes. According to EUR-Lex, Regulation (EU) 2025/1561 postponed the battery supply-chain due-diligence obligations — covering cobalt, natural graphite, lithium and nickel — from 18 August 2025 to 18 August 2027. The Council of the European Union confirmed the stop-the-clock amendment entered into force on 30 July 2025. Korean NMC cell makers should use the additional time to map sourcing chains and collect supplier records so that the full evidence base is in place before the 2027 obligation applies.

Is the carbon footprint declaration already in force for EV batteries?

No, not yet. According to EUR-Lex, Article 7(1) of Regulation (EU) 2023/1542 sets the trigger as 18 February 2025 or 12 months after the relevant delegated and implementing acts enter into force, whichever is the latest. Those acts were not finalised as of late 2025, so the obligation is currently deferred. Track the status of both acts via the European Commission environment pages, and build carbon-accounting data for your NMC cell production, but do not treat the declaration as an active regulatory requirement today.

References

• EUR-Lex — consolidated text of Regulation (EU) 2023/1542 (labelling Art. 13, conformity Arts. 17-20, carbon footprint Art. 7, battery passport Arts. 77-79): https://eur-lex.europa.eu/eli/reg/2023/1542/2024-07-18/eng
• EUR-Lex — Regulation (EU) 2025/1561, postponing battery due-diligence obligations to 18 August 2027: https://eur-lex.europa.eu/eli/reg/2025/1561/oj/eng
• Council of the European Union — press release on the stop-the-clock due-diligence amendment: consilium.europa.eu
• Battery University — UN 38.3 test series for lithium cells and batteries: https://batteryuniversity.eu/en/standards/un-38.3
• GWP Group — UN3480 and UN3481 lithium battery transport classification guide: https://www.gwp.co.uk/guides/un3480-regulations/
• International Electrotechnical Commission (IEC) — IEC 62133-2:2017, safety requirements for portable sealed secondary lithium cells: https://webstore.iec.ch/en/publication/32662

Sourcing Korean 21700 NMC lithium-ion battery cells for EU-market applications? Korea Industry Insights connects EU importers and pack assemblers with Korean cell makers that hold current UN 38.3 documentation, IEC 62133-2:2017 test reports, and IATF 16949 / ISO 9001 certification — and supports the technical data inputs needed for EU conformity assessment, the EU Declaration of Conformity, and battery passport data readiness ahead of the 18 February 2027 deadline. Submit your sourcing requirements at exportservice.cloud/inquiry.