Direct answer: The battery inside an emergency luminaire is now a regulated product in its own right. Regulation (EU) 2023/1542, the EU Battery Regulation, entered into force on 17 August 2023 and repealed the old Battery Directive 2006/66/EC on 18 August 2025. Its obligations land in waves: battery CE marking and the 0.01% lead limit for portable batteries from August 2024, carbon footprint declarations for large industrial packs from February 2026, battery passports and end-user battery removability from February 2027. Which wave reaches your product depends first on one decision: whether the battery is classified as portable or industrial.
Why a battery law reaches into your luminaire bill of materials
Batteries incorporated into a luminaire are treated as placed on the market together with it, so the manufacturer, the importer and in some roles the distributor all carry battery obligations, not just the cell vendor. And because IEC 60598-2-22 expects the battery of a self-contained emergency luminaire to be designed for at least four years of normal operation, batteries are consumables: every replacement pack shipped into the EU is a fresh placing on the market with its own duties. A fixture you certified once generates a continuous stream of battery compliance events for a decade.
First, classify the battery correctly
The whole regulation keys off the battery category, and the boundary runs straight through the emergency lighting product range.
| Question | Portable battery | Industrial battery |
|---|---|---|
| Definition | Sealed, 5 kg or less, not designed specifically for industrial use, and not an EV, LMT or SLI battery | Designed for industrial uses, including stationary battery systems, repurposed for industrial use, or over 5 kg and not another category |
| Removability (Article 11, from 18 Feb 2027) | End-user removable and replaceable, unless a derogation applies | Article 11 does not target industrial batteries |
| Carbon footprint and battery passport | Not required | Required above 2 kWh on the dates below |
| Cadmium restriction (0.002%) | Applies, with a carve-out for emergency and alarm systems | No portable-battery cadmium restriction |
| Lead restriction (0.01%, from 18 Aug 2024) | Applies | Does not apply |
A 1 to 2 kg sealed nickel-cadmium or LiFePO4 pack inside a professional building-services product sits close to the portable/industrial boundary, and the classification is made case by case, not by habit. Get a written legal opinion per battery model before 2027; the Commission published application guidance on removability in January 2025, and that document is the reference your test house and your customers’ importers will read.
The compliance clock: dates that move your product
| Date | What applies | Who it hits hardest |
|---|---|---|
| 18 Feb 2024 | Core obligations and substance restrictions begin under 2023/1542 | All batteries placed on the EU market |
| 18 Aug 2024 | Batteries must be CE marked under the Regulation’s conformity assessment; lead limit of 0.01% for portable batteries | Battery manufacturers, and luminaire makers shipping incorporated packs |
| 18 Aug 2025 | Battery Directive 2006/66/EC repealed; producer registration and extended producer responsibility minimums apply | Importers and brand owners |
| 18 Feb 2026 | Carbon footprint declaration for rechargeable industrial batteries above 2 kWh (except exclusively external storage) | Central battery systems and large industrial packs |
| 18 Feb 2027 | Battery passport with QR code for industrial above 2 kWh, EV and LMT batteries; portable batteries in products must be end-user removable and replaceable | Product design teams |
| 18 Aug 2027 | Carbon footprint performance class label for industrial batteries above 2 kWh; due-diligence checkpoints for large operators (turnover above EUR 40 million) after later amendments shifted the timeline | Labelling and supply-chain teams |
| From 2031 | Recycled-content minimums for industrial batteries: 16% cobalt, 85% lead, 6% lithium, 6% nickel in the first period | Cell sourcing |
Waste-side duties stack on top: producer registration per member state since August 2025 – the same EPR logic we compared for WEEE registration in Germany and France – and portable waste battery collection targets of 63% by the end of 2027 and 73% by the end of 2030.
Cadmium and lead: the emergency-lighting carve-out still stands
The substance limits come from Annex I. Mercury is capped at 0.0005% for all batteries. Cadmium is capped at 0.002% for portable batteries, but that restriction does not apply to batteries destined for emergency and alarm systems, including emergency lighting – a carve-out carried over from Directive 2006/66/EC as amended in 2013. NiCd emergency packs therefore remain legal to place on the EU market, which matters because NiCd still handles high temperature and deep cycling better than most chemistries in unconditioned ceilings.
Lead is the sharper edge. From 18 August 2024 a portable battery may contain no more than 0.01% lead. A small sealed lead-acid pack is mostly lead; if it were classified as a portable battery, the limit would exclude it outright. Whether your VRLA pack is “designed specifically for industrial use” is therefore not a semantic question – it decides whether the product line exists. Settle the classification in writing, per model, before the next order.
CE marking and the battery’s own declaration of conformity
Since August 2024, a battery placed on the EU market carries CE marking under the Battery Regulation, backed by its own declaration of conformity and conformity assessment per the Regulation’s modules. That file is separate from the luminaire’s LVD and EMC file. An EN 60598-2-22 test report on the fixture does not satisfy the battery regulation, and a battery CE mark does not prove the fixture works in emergency mode.
The product standard still governs the pairing. IEC/EN 60598-2-22:2014 with its 2020 amendment requires, in clause 22.6.8, that a self-contained emergency luminaire incorporate a battery designed for at least four years of normal operation, used only for emergency-related functions; chargers must comply with IEC 61347-2-7. Central battery systems covered by EN 50171 call for a ten-year battery design life. Those battery tests are chemistry-specific: a pack swapped from NiCd to lithium without re-test invalidates the fixture certificate, because lithium needs a protection circuit that the tested charge regime may not provide. Our article on emergency lighting testing and battery replacement covers the maintenance side, and the integral versus central system trade-off shows where each design carries its compliance weight.
Removability in 2027 and the continuity-of-supply exception
From 18 February 2027, products incorporating portable batteries must let end users remove and replace the battery with commercially available tools – no specialised or proprietary tools, no heat, no solvents. EN 45554:2020 categorises the tools, and instructions must ship with the product.
Article 11(3) then provides the exception the emergency sector depends on: the removability requirement does not apply where continuity of power supply is necessary and a permanent connection between the product and the battery is required to ensure safety. Emergency lighting is close to the textbook case, and IEC 60598-2-22 already forbids any switch between battery and emergency lamps. But the exception is conditional, and many self-contained products are designed with non-replaceable packs and marked for whole-unit replacement at end of life. Decide the route – end-user removable pack, professional-only pack under a derogation, or sealed fixture with whole-unit replacement – with your notified body, and put it in the instructions.
Carbon footprint and battery passport: where the 2 kWh line falls
The carbon footprint declaration applies from 18 February 2026 to rechargeable industrial batteries above 2 kWh, except those with exclusively external storage, whose dates come later in the decade. The performance class label follows on 18 August 2027, and the battery passport – a QR-linked digital record per battery – applies to industrial batteries above 2 kWh from 18 February 2027.
Run the arithmetic on your range. A self-contained pack for a 3-hour emergency luminaire is typically tens to a few hundred watt-hours, an order of magnitude below the threshold. A central battery system serving a whole floor can genuinely exceed 2 kWh, and its battery is squarely in scope: a verified declaration per battery model and per manufacturing plant, then a performance class, then a passport. Suppliers of those systems should already be able to show a carbon footprint data plan, because the declaration takes the longest to prepare – most of the data sits with cell and material suppliers.
What to put in the RFQ this quarter
- A written classification opinion: portable or industrial, per battery model, with the reasoning.
- The battery’s own CE evidence and declaration of conformity, dated after August 2024, naming the conformity module.
- Confirmation that the cell chemistry matches the EN 60598-2-22 test file, and a commitment that no chemistry change ships without re-test.
- The four-year design life statement per IEC 60598-2-22, or ten years for central systems per EN 50171.
- The supplier’s position on Article 11(3) for permanently connected packs, and the replacement route at end of life.
- For industrial packs above 2 kWh: a carbon footprint roadmap to February 2026 and passport readiness to February 2027.
- Producer registration status per member state for the batteries themselves, since August 2025.
Frequently asked questions
Does the Battery Regulation apply to the luminaire or only to the battery?
Both. The battery is placed on the market as part of the luminaire, so the economic operators in the chain carry the battery duties, and each replacement pack is a separate placing on the market with its own CE marking, declaration and labelling.
Can we still ship NiCd emergency luminaires to the EU?
Yes, for now. The 0.002% cadmium restriction on portable batteries does not apply to batteries for emergency and alarm systems, including emergency lighting, and that carve-out was carried into Regulation 2023/1542. Watch the Annex I amendment process, because derogations of this kind are periodically reviewed.
Our packs are far below 2 kWh – is there anything to do?
Yes. The 2 kWh line only gates the carbon footprint declaration, the performance label and the passport. CE marking of the battery, the declaration of conformity, labelling, producer registration and – if the pack is classified portable – the 2027 removability rules all still apply.
Can we add a user-replaceable battery door to a self-contained emergency luminaire?
Only if emergency-mode integrity survives. IEC 60598-2-22 forbids switches between the battery and the emergency lamps, and end-user access interacts with ingress and tamper requirements. Where continuity of supply is genuinely required for safety, Article 11(3) can exempt the permanent connection – but that is a documented design decision, not a label.
What happens when the four-year battery design life expires?
The battery does not retire on a date; it must still achieve its rated duration under the testing regime. When it no longer can, replace it with an identical specification – same chemistry, capacity, voltage and charge characteristics – or, where the fixture is marked as non-replaceable, replace the whole luminaire. Never swap a NiCd pack for lithium without a new protection circuit and a re-test.
This article is a procurement guide, not legal advice. Confirm requirements for your specific product and market with a qualified compliance provider.
