EU product rules 2026 to 2030

Battery passport, packaging rules and the forced labour ban: your 2027 timeline as importer or brand

A battery passport with a QR code from 18 February 2027, packaging registrations in every country of sale since 12 August 2026, and a ban on products made with forced labour from 14 December 2027. Three EU rules, three roles, and the Dutch BV that can take them.

The dates Want our team to have a look?

Home›EU market entry›Battery passport, packaging and forced labour 2027

By Robert Jeffrey, Holdwise B.V., Hoofddorp. Published and checked against the official sources on 20 October 2026.

Summary

18 February 2027: every electric vehicle battery, e-bike, e-moped and e-scooter battery, home storage battery and industrial battery placed on the EU market gets a digital battery passport. The economic operator that places the battery on the market creates and maintains it; your importing BV is that operator. Since 12 August 2026: the packaging regulation (PPWR) asks for a producer registration in each country of sale and, for sales into another member state, an authorised representative there; the Commission has proposed to suspend that representative duty for small businesses. 14 December 2027: products made with forced labour may neither be sold in nor exported from the EU, and the importer is the company the authorities address.

All three rules point to the same company: the one that places the product on the EU market. A Dutch BV that imports in its own name holds the passport, the packaging registration for the Netherlands and the supplier file, and works with representatives in the other countries of sale through partners.

Want our team to have a look? →

The dates, with their status

Date	Rule	What applies	Status
30 June 2026	Forced labour	Preparedness package and single portal available; implementation starts for companies and authorities	In force (preparation)
20 July 2026	Digital product passport	The Digital Product Passport registry is operational; economic operators register each passport in it	In force
12 August 2026	Packaging (PPWR)	Regulation (EU) 2025/40 applies: producer responsibility and registration per country of sale, authorised representative for sales into another member state, ban on PFAS above the limits in food-contact packaging	In force
18 February 2027	Batteries	Battery passport mandatory for electric vehicle batteries, batteries for e-bikes, e-mopeds and e-scooters, home storage batteries and industrial batteries placed on the market (Regulation (EU) 2023/1542)	Law
14 December 2027	Forced labour	Regulation (EU) 2024/3015 applies: products made with forced labour may neither be sold in nor exported from the EU; enforcement begins	Law
12 August 2028	Packaging (PPWR)	Harmonised EU labelling of packaging for waste sorting	Law
2030	Packaging (PPWR)	All packaging recyclable, mandatory recycled plastic in new plastic packaging, limits on empty space, reuse targets and restrictions on certain single-use plastic packaging	Law
Open	Packaging (PPWR)	Commission proposal to suspend the authorised representative duty for small businesses; new uniform EU rules for registration and reporting, after which member states have 18 months to adapt their registers	Proposal

18 February 2027: the battery passport

The Batteries Regulation (EU) 2023/1542 gives each battery of the covered categories a digital passport from 18 February 2027: electric vehicle batteries, batteries for e-bikes, e-mopeds and e-scooters, home storage batteries and industrial batteries. The passport is linked to the battery through a QR code. Its content depends on the category and covers the identification and technical characteristics of the battery, the manufacturer and the economic operator, performance and durability, information that supports repair, reuse and recycling, and sustainability data. The system is decentralised: the responsible operator keeps the detailed data, and the Digital Product Passport registry of the Commission, operational since 20 July 2026, holds the unique identifier and the metadata. Every passport is registered there.

The duty to create and maintain the passport lies with the economic operator that places the finished battery on the market, so a supplier of cells or modules is outside it. For a brand or importer with a Dutch BV, that is the BV itself when it imports e-bikes, storage systems or industrial batteries and sells them in the EU. The manufacturer supplies the data; the BV publishes and maintains the passport. Put the data delivery, the format and the update duty in the supplier contract before the first shipment of 2027. The battery producer registration per country, which already applies, is described on EU representative requirements.

The registry also lists textiles, steel and aluminium, tyres, furniture, ICT products and energy-related products as product groups. Their dates follow in separate acts and were still open on 20 October 2026.

Since 12 August 2026: packaging and the representative per country

The Packaging and Packaging Waste Regulation (EU) 2025/40 has applied across the EU since 12 August 2026. Producer responsibility works per country: the producer registers and pays in the country where the packaging is likely to become waste, under the existing national registers until the new uniform EU rules for registration and reporting are in place. After those rules, member states have 18 months to adapt their registers. A producer that sells packaged products into another member state appoints an authorised representative there. The regulation made that duty EU-wide in August 2026; several countries had it before under national law. Food-contact packaging with PFAS above the limits has been banned from the same date.

The Commission has proposed to suspend the representative duty for small businesses. While Parliament and the Council examine the proposal, the Commission asks member states to apply the rule in a constructive and pragmatic way and to abstain from sanctions. The existing national registration rules continue to apply, and marketplaces ask for the registration per country of sale. Two more dates follow: a harmonised EU label for waste sorting on all packaging from 12 August 2028, and from 2030 the requirement that all packaging is recyclable, mandatory recycled plastic in new plastic packaging, limits on empty space, reuse targets and restrictions on certain single-use plastic packaging.

For your Dutch BV: the BV is the producer for the Netherlands and registers there itself. For the other countries of sale, a representative established in that country takes the registration, through partners that do this for many brands. The practical steps since August 2026 are on packaging compliance after 12 August 2026.

14 December 2027: the forced labour ban

Regulation (EU) 2024/3015, adopted on 19 November 2024, applies from 14 December 2027. From that date, products made with forced labour may neither be sold in nor exported from the EU, whatever their origin. The competent authorities of the member states investigate suspected cases, together with customs and the market surveillance authorities. The Commission has published guidelines on the duties, the powers of the authorities and the investigation process, and a risk database that names geographical areas and products with a higher risk. A preparedness package and a single portal have been available since 30 June 2026.

The regulation leaves the method to the company: it must make sure that the products it sells were made free of forced labour. During an investigation the authority may ask how the company handles that risk in its supply chain, and when forced labour is confirmed, the product is withdrawn and the decision is followed. Importers are the main focus of the checks. Your Dutch BV as importer is the company the authority writes to, so the supplier file belongs in the BV: the chain down to the raw materials for products with a higher risk, the check against the risk database, supplier declarations and audits, and the audit rights in the contracts.

Who takes which role

Rule	Who is responsible	Your Dutch BV	Through partners
Battery passport	The economic operator that places the battery on the EU market	Creates, registers and maintains the passport as importer	Data from the manufacturer; passport software; the producer registration for batteries in other countries
Packaging (PPWR)	The producer in each country where the packaging becomes waste; an authorised representative for sales into another member state	Producer registration for the Netherlands	Representatives established in the other countries of sale
Forced labour ban	Every company that sells or exports the product; importers are the main focus of the checks	Holds the supplier file and answers the authority as importer	Supplier audits, origin checks, chain mapping for products with a higher risk

The same BV holds the VAT number, the customs number (EORI) and the Article 23 licence for import VAT, and can be the responsible operator for product safety. How importing and distributing through the Netherlands works: importing and distributing through the Netherlands.

What an importer or brand with a Dutch BV arranges, in order

Decide which company places the goods on the EU market. That company holds the passport, the packaging registration and the supplier file. A Dutch BV that imports in its own name keeps all three in one place. See company formation in the Netherlands.
Batteries: fix the data delivery with the manufacturer. Agree the passport data, the format and the update duty in the supplier contract, choose the passport software, and register the first passports in the registry before the first shipment after 18 February 2027.
Packaging: register per country. The BV registers in the Netherlands; representatives take the other countries of sale. Collect the packaging data per country and per material, and follow the suspension proposal for small businesses.
Forced labour: build the supplier file now. Map the chain for products from areas or sectors in the risk database, collect supplier declarations and audit reports, add audit rights to the contracts and write the procedure for an authority request.
Labels and artwork. Plan the QR code on batteries and the harmonised packaging label of 2028 into the artwork cycle, together with the name and address of the EU operator that the product safety rules already require.
One file per product. Operator details, declarations, the passport link, the packaging registration numbers per country and the forced labour evidence, kept in the BV and ready for a customs or authority request.

Questions founders ask

Who creates the battery passport for the e-bikes I import from China? +

The economic operator that places the battery on the EU market creates and maintains the passport. When your Dutch BV imports the e-bikes and sells them in the EU, that is your BV. The manufacturer in China supplies the data: identification and technical characteristics, performance and durability, information for repair, reuse and recycling, and sustainability data. Put that data delivery in the supplier contract. The passport is linked to the battery through a QR code and is registered in the Digital Product Passport registry, which has been operational since 20 July 2026. The duty applies to batteries placed on the market from 18 February 2027.

Does a small webshop need a packaging representative in every EU country where it sells? +

Under the PPWR, a producer that sells packaged products into another member state appoints an authorised representative there. This has applied in all member states since 12 August 2026; some countries required it before under national law. The Commission has proposed to suspend this duty for small businesses. While Parliament and Council examine that proposal, the Commission asks member states to apply the rule in a pragmatic way and to abstain from sanctions. The existing national registration rules continue to apply in the meantime, so check the rules of each country of sale. In the Netherlands your Dutch BV registers itself as producer.

What must my BV be able to show from 14 December 2027? +

The regulation bans products made with forced labour from the EU market and leaves the method of compliance to the company. During an investigation the competent authority may ask how your company handles the risk of forced labour in its supply chain. A workable file holds: the chain of suppliers down to the raw materials for products with a higher risk, a check of each origin against the EU risk database, supplier declarations and audit reports, audit rights in supplier contracts, and a procedure for answering an authority within the set time. When forced labour is confirmed, the product is withdrawn and the decision is followed. Your Dutch BV as importer is the company the authorities address.

Which batteries get a passport? +

Electric vehicle batteries, batteries for e-bikes, e-mopeds and e-scooters, home storage batteries and industrial batteries, when placed on the EU market from 18 February 2027. The passport works through a decentralised system: the responsible economic operator keeps the detailed data, the registry holds the unique identifier and the metadata. The content depends on the battery category.

Which other products get a digital product passport? +

The Commission names textiles, steel and aluminium, tyres, furniture, ICT products and energy-related products as product groups covered by the registry. Their dates follow in separate acts and were still open on 20 October 2026. The new Toy Regulation, in force since 1 January 2026, adds a passport for toys when it applies in 2030; the exact date is still to be confirmed.

Sources

European Commission, Digital Product Passport for batteries: single-market-economy.ec.europa.eu; Digital Product Passport Registry now live (20 July 2026): single-market-economy.ec.europa.eu
Regulation (EU) 2025/40 on packaging and packaging waste (PPWR): eur-lex.europa.eu; European Commission, New EU rules on packaging enter into application (11 August 2026): environment.ec.europa.eu; Extended producer responsibility for packaging: small businesses: environment.ec.europa.eu
Regulation (EU) 2024/3015 on prohibiting products made with forced labour on the Union market: eur-lex.europa.eu; European Commission, Forced Labour Regulation: single-market-economy.ec.europa.eu
European Commission, Stronger toy safety rules enter into force (23 December 2025): single-market-economy.ec.europa.eu

What do you import, and in which packaging?

Tell us the product, the country of production and the EU countries where you sell. You get a written answer on your situation: which of the three rules apply to you, the dates that count, and what your Dutch BV registers first.

Want our team to have a look?

Free advice

Want our team to have a look?

We help you with import and export: VAT, customs numbers and licences. Tell us where you stand or what you are planning. You get free advice on your next step.