EU Battery Passport under Regulation (EU) 2023/1542

From 18 February 2027, every electric vehicle (EV) battery, light means of transport (LMT) battery and industrial battery above 2 kWh placed on the EU market or put into service must have an electronic battery passport under Article 77 of Regulation (EU) 2023/1542.

The battery passport is the EU’s first mandatory Digital Product Passport regime for a specific product group. It combines a battery-specific electronic record, a unique identifier, a QR-code entry point and differentiated access to regulated information across the battery lifecycle.

For teams preparing for 2027, the practical task is no longer simply to understand what a battery passport is. It is to determine which batteries are in scope, which data points apply, where the evidence comes from, who can access each field and how the passport will remain available and updateable after the battery enters the market.

What is the EU Battery Passport?

The EU Battery Passport is an electronic record required by Article 77 of Regulation (EU) 2023/1542 on batteries and waste batteries.

For every covered battery, the passport links information about the battery model with information specific to the individual battery. Depending on the legal requirement and access level, that can include identity, manufacturing, sustainability, composition, performance, durability and lifecycle information.

Article 77 defines the legal passport requirement and access structure. Annex XIII specifies the information categories to be included. Article 78 sets technical and operational requirements for the passport, including interoperability, data access, availability and technical design.

This is why the battery passport should not be treated as a static web page or PDF. A compliant implementation is a regulated data system attached to an individual battery.

For the wider legal framework, see our guide to EU Battery Regulation 2023/1542.

Battery Passport deadline: 18 February 2027

The legal application date is 18 February 2027.

From that date, each battery falling within Article 77(1) that is placed on the market or put into service must have a battery passport.

That makes February 2027 the go-live date, not the date on which a manufacturer should begin implementation. Before then, operators may need to complete battery classification, data mapping, supplier onboarding, identifier design, QR implementation, access-control logic, integration testing and operational ownership.

A practical implementation plan should therefore work backwards from the first production batches expected to be placed on the EU market on or after 18 February 2027.

Which batteries need an EU Battery Passport?

Article 77 covers three battery categories:

The greater-than-2-kWh threshold applies to industrial batteries. It should not be incorrectly applied to EV or LMT batteries.

Scope analysis should start from the definitions in Regulation (EU) 2023/1542 and the actual product configuration. Chemistry, physical size or marketing terminology alone are not reliable tests.

Battery Passport requirements under Article 77

At a high level, Article 77 requires a covered battery to have an electronic battery passport that:

• is associated with the individual battery;
• contains model-level and battery-specific information required by Annex XIII;
• provides different information to different user groups according to the Regulation’s access rules;
• is accessible through the battery’s required data carrier;
• uses a unique identifier that is registered through the EU Digital Product Passport infrastructure where required;
• remains capable of supporting battery information throughout the relevant lifecycle.

The passport therefore has both a content problem and an infrastructure problem. Compliance depends not only on collecting fields but also on identity, access, persistence, updateability and governance.

Battery Passport data requirements: 71 data points

The European Commission’s August 2026 Digital Batteries Passport guidance brings together 71 data points, showing their legal sources and their applicability across EV, LMT and industrial batteries above 2 kWh.

The guidance is especially useful because the required information is not presented as one simple 71-row list in the Regulation itself. The Commission mapping consolidates requirements drawn from the Battery Regulation and makes the preparation work more operational.

However, 71 does not mean that every covered battery must display the same 71 populated fields on 18 February 2027. Applicability depends on battery category and on the underlying legal requirement. Some data points are conditional, have separate application dates or are not required to be filled in the same way at the initial passport deadline.

The Commission also states that the guidance does not create additional legal requirements and should be read together with Regulation (EU) 2023/1542 and relevant delegated or implementing acts.

Need the field-level mapping? See our Battery Passport Data Requirements: 71 Data Points for 2027 guide for the data-point-by-data-point view, including battery category, access level, legal source and status.

What information is stored in a Battery Passport?

Annex XIII organises battery-passport information across several groups. Depending on applicability and access rights, the passport can include information such as:

• battery and manufacturer identity;
• battery category, model and individual identifier information;
• place and date of manufacture;
• labels, conformity and certification information;
• carbon-footprint information;
• battery composition and material information;
• critical raw materials and hazardous-substance information where applicable;
• recycled-content information;
• supply-chain due-diligence information where applicable;
• rated capacity, energy and power information;
• expected lifetime and performance parameters;
• state-of-health and other battery-specific lifecycle information;
• dismantling, safety, repair, repurposing and recycling information.

The implementation mistake to avoid is treating this as one flat content form. Different fields can have different sources, owners, update frequencies, evidence requirements and access permissions.

A robust data map should therefore track at least legal source, applicability, access level, source system, responsible owner, evidence, validation rule and update trigger for every required field.

Who can access Battery Passport data?

Battery-passport information is not all public.

Article 77 divides information into access categories. Some information is available to the general public, while other information is reserved for authorities, notified bodies or persons with a legitimate interest for specified purposes.

That means a compliant passport may need to render different views of the same battery depending on who is requesting the data and on what legal basis.

Access control should therefore be designed into the data model and API architecture rather than added at the end as a simple page-level permission setting.

Battery Passport QR code requirements

The QR code is the physical access point to battery information; it is not the passport itself.

Under the Battery Regulation, batteries are subject to QR-code requirements from 18 February 2027. For batteries covered by Article 77, the QR code provides access to the battery passport.

Implementation teams should consider:

• where the QR code will be placed on the battery or accompanying documentation where legally permitted;
• whether it remains readable throughout expected operating conditions;
• how the code resolves to the correct individual battery identity;
• what happens when infrastructure, vendors or domains change;
• how redirects, identifiers and URLs are governed over the battery lifecycle;
• how duplicate, damaged or incorrectly associated codes are handled in production.

Avoid making the battery’s long-term identity dependent on a temporary marketing URL or a software vendor’s domain if that dependency cannot be controlled after the contract ends.

Article 78: technical design and operation

Article 78 is the technical counterpart to Article 77. It requires the battery passport to operate within the broader EU Digital Product Passport framework and sets requirements around technical design and access.

For implementation teams, this means the target architecture should be evaluated against more than front-end presentation. Relevant questions include:

• Can the passport interoperate with the EU DPP technical framework?
• Can access rights be enforced without duplicating uncontrolled copies of sensitive data?
• Can data be retrieved reliably over the required lifetime?
• Can the passport survive a change of service provider?
• Can individual-battery information be updated without destroying the historical evidence?
• Can data be exchanged in machine-readable form where required?

A vendor demo that only shows a polished QR landing page does not answer these questions.

Who is responsible for the Battery Passport?

The Battery Regulation places key passport obligations on the economic operator placing the battery on the market or putting it into service.

In practice, many organisations may contribute to one passport:

• cell and material suppliers provide upstream data;
• the battery manufacturer controls manufacturing and product records;
• an OEM may control the final battery integration and market placement process;
• importers can have regulatory responsibilities for batteries entering the EU;
• software providers may host, transform or expose passport data;
• repair, repurposing and lifecycle actors may generate information after the initial sale.

Using a specialist DPP provider does not by itself transfer the operator’s regulatory accountability. Contracts should define who supplies each field, who validates it, who may correct it, who owns the identifier namespace, how lifecycle data is updated and what happens if the software relationship ends.

Battery Passport software requirements

Battery-passport software should be evaluated as compliance infrastructure rather than as a QR-code generator.

A serious implementation may need to support:

1. Individual battery identity — one passport associated with the correct covered battery.
2. Data ingestion — from PLM, ERP, MES, supplier systems, laboratory records and manual evidence where unavoidable.
3. Field-level validation — requiredness, formats, dates, units and category-specific logic.
4. Access control — public and restricted data views based on the legal access model.
5. Versioning and updates — especially for information that changes during use.
6. Evidence and auditability — a traceable basis for values rather than unexplained copied fields.
7. QR and resolver management — persistent identity independent of a fragile page URL.
8. EU DPP infrastructure compatibility — including the registry and applicable technical standards.
9. Portability and service continuity — so passports do not disappear when a supplier changes.

See our overview of Digital Product Passport software and DPP providers for the broader vendor landscape.

How to prepare for Battery Passport compliance

A useful 2026–2027 implementation sequence is:

1. Classify the battery. Confirm whether it is EV, LMT, industrial or another category under Regulation (EU) 2023/1542.
2. Confirm Article 77 scope. Document why the battery is or is not passport-covered.
3. Map the 71 guidance data points. Determine which points apply to the category and which have separate legal triggers.
4. Map each field to its legal source. Do not rely on a vendor template as the legal source of truth.
5. Assign data ownership. Identify the source system, supplier, evidence and accountable owner for every applicable field.
6. Design battery identity. Establish serialisation, unique identifiers and the relationship between the identifier, QR code and electronic record.
7. Design access rights. Separate public information from restricted information at the data-model level.
8. Plan lifecycle updates. Define how post-manufacture data can be added or changed without overwriting source evidence.
9. Test the physical QR implementation. Validate placement, readability, durability and association with the correct battery.
10. Test technical infrastructure. Include registry interaction, authentication, data retrieval, failure modes and provider portability.
11. Run a production-volume pilot. Test exceptions, rework, replacements, duplicate identifiers and supplier-data gaps.
12. Create an evidence pack. Keep the scope decision, data mapping, responsibilities, technical design and test results auditable.

Common Battery Passport mistakes

Treating 18 February 2027 as a project start date

It is the legal application date. Data collection and technical implementation need to be ready for affected batteries entering the market from that date.

Applying the 2 kWh threshold to every battery category

The threshold in Article 77 applies to industrial batteries. EV and LMT batteries are separately named categories.

Assuming all 71 data points are identical for every battery

The Commission guidance maps applicability by battery category. Some requirements are conditional or tied to separate legal dates.

Making every passport field public

Article 77 provides differentiated access rights. Restricted information needs an appropriate access-control model.

Treating a QR landing page as the complete compliance solution

The visible page is only one layer. Identity, data provenance, permissions, updates, interoperability and long-term availability matter as well.

Locking the passport to one vendor

A battery can remain in use far longer than a normal SaaS contract. Portability, identifiers and service-continuity arrangements should be decided before launch.

Battery Passport compliance checklist

Use this as a high-level readiness check before moving into the field-level data work:

• Battery category confirmed under Regulation (EU) 2023/1542
• Article 77 passport scope documented
• 18 February 2027 production/market cutover identified
• Applicable data points mapped to legal sources
• Field owners and source systems assigned
• Evidence gaps escalated to suppliers or internal teams
• Unique battery identity and serialisation defined
• QR-code production and durability tested
• Public and restricted access views designed
• Lifecycle update rules documented
• EU DPP registry/infrastructure requirements tested
• Vendor exit and passport portability plan agreed
• Production-volume pilot completed