From 18 February 2027, every light means of transport battery, electric vehicle battery and industrial battery above 2 kWh placed on the EU market or put into service must have an electronic battery passport. The passport is linked through a QR code and contains regulated identity, sustainability, performance, composition and lifecycle information with differentiated access rights.
What is the EU Battery Passport?
The battery passport is an electronic record established by Article 77 of the EU Battery Regulation. It gives a covered battery a unique identity and makes prescribed information available across its lifecycle.
It is a product-specific DPP regime with an adopted date and detailed data annex. That makes it more concrete than ESPR product groups whose delegated acts are still under development.
Who needs a battery passport?
The obligation applies to each:
- LMT battery used in a light means of transport, such as certain e-bikes and e-scooters;
- electric vehicle battery;
- industrial battery with a capacity greater than 2 kWh.
The relevant economic operator must assess the legal definitions, product configuration and act of placing on the market. This scope should not be shortened to “all batteries.”
Battery passport deadline
The requirement applies from 18 February 2027. A covered battery placed on the market or put into service from that date must have its electronic record.
Implementation plans should account for production and inventory cutovers, carrier application, data availability and contractual responsibilities well before the deadline. Confirm the treatment of specific stock and supply-chain scenarios with legal counsel.
Which batteries are covered?
Capacity is only one part of scope. EV and LMT batteries are named categories, while the greater-than-2-kWh threshold applies to industrial batteries. Product teams should document classification and evidence rather than infer scope from chemistry or physical size.
Other obligations under the Battery Regulation can apply even when a battery does not require a passport.
Battery passport data requirements
Annex XIII structures the passport information. Depending on the field and access right, it covers areas such as:
- battery and manufacturer identity;
- place and date of manufacture;
- battery category, model and characteristics;
- conformity, labels and certifications;
- carbon-footprint information;
- responsible sourcing and supply-chain due diligence;
- material composition, including critical raw materials;
- recycled content and renewable-content information where applicable;
- performance, durability and state information;
- dismantling, safety and end-of-life information.
Use the consolidated regulation and applicable secondary acts as the field-level source of truth. A commercial template is not a substitute for legal mapping.
QR code requirements
The Battery Regulation requires a QR code for batteries from 18 February 2027, with the code providing access to applicable information and, for passport batteries, the electronic record. Carrier planning needs to address location, size, contrast, durability and production control.
The QR should resolve through an identity architecture that can survive website changes. Avoid links tied to a temporary vendor domain if the identifier needs to remain available beyond that contract.
Who is responsible?
Responsibility rests with the economic operator placing the battery on the market. In complex value chains, the cell manufacturer, battery manufacturer, vehicle OEM, importer and software provider may each supply parts of the data or process, but their commercial roles do not erase the statutory responsibility.
Contracts should define field ownership, evidence, correction rights, lifecycle updates, service continuity and handover.
Battery passport software
Software must do more than render a public page. A battery implementation can require item-level identity, manufacturing and supplier integrations, access-controlled evidence, performance updates, data portability and reliable registry interaction.
Evaluate platforms with a representative battery record and at least one change after manufacture. Check whether the architecture can support state-of-health or lifecycle information without overwriting original evidence.
Implementation checklist
- Confirm battery category and passport scope.
- Map every Annex XIII field to its access class and legal source.
- Assign a system, supplier, evidence type and owner to each field.
- Establish unique battery identity and serialisation.
- Test QR placement and durability in real operating conditions.
- Design public, notified-body and other authorised views as required.
- Implement validation, versioning and lifecycle updates.
- Test registry registration and error handling.
- Run a production-volume pilot and exception process.
- Document accountability and service continuity.
Frequently asked questions
When does the EU battery passport become mandatory?
The passport requirement applies from 18 February 2027 to each covered battery placed on the EU market or put into service.
Which batteries need a passport?
Each light means of transport battery, each electric vehicle battery and each industrial battery with a capacity greater than 2 kWh is in scope under Article 77.
Does every portable battery need a battery passport?
No. The passport scope in Article 77 does not cover every portable battery. Other Battery Regulation labelling and information requirements may still apply.
Who creates the battery passport?
The economic operator placing the battery on the market must ensure that the required passport is assigned and compliant, even if a technology or service provider operates it.
Is the QR code itself the battery passport?
No. The QR code links to the passport. The electronic record, underlying data, access rights and lifecycle processes make up the operating passport.