If a battery is to be sold in the EU after 18 February 2027, it will in many cases need a digital battery passport. The date is fixed, but several details about how the passport will work have still not been settled. In this post, we go through what a battery passport is, which batteries are covered, what it must contain and how you can prepare while the rules are still being finalised.
The short version:
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The battery passport is a digital record linked to each battery via a QR code. It applies to EV batteries, light means of transport (LMT) batteries and industrial batteries above 2 kWh.
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Responsibility lies with whoever places the finished battery on the market, not with the component suppliers.
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A battery without a valid passport may not be placed on the EU market after 18 February 2027, even if some of the detailed rules are still missing.
What is a battery passport?
The battery passport is electronic documentation for an individual battery. It brings together information about the battery’s identity, composition, performance and history, and you access it by scanning a QR code on the battery. The passport is the first application of the EU’s digital product passport, and the Commission plans to use the same model for more product groups, such as textiles and electronics.
The purpose is to make information about batteries available to those who need it: buyers, repairers, recyclers and authorities. The information should make it easier to compare batteries, repair them, reuse them and, ultimately, recycle them.
Which batteries are covered?
The requirement applies to every EV battery, every LMT battery and every industrial battery above 2 kWh that is placed on the EU market or put into service from 18 February 2027. In practice, this means batteries in electric cars, e-bikes, electric mopeds, e-scooters, home energy storage and larger industrial applications.
Portable batteries and SLI batteries are therefore not covered by the battery passport requirement. They must still carry a QR code with basic information, though.
Who is responsible for the passport?
The party that places the finished battery on the market is responsible. The obligation to create and maintain the passport lies with the economic operator placing the finished battery on the market, not with suppliers of individual components or modules.
That sounds simple, but in practice it means that, as a manufacturer, you need data from across the entire supply chain. If you build in a battery from a supplier, you need to know what the supplier can provide, and in what format.
What must the passport contain?
The content varies depending on the battery category, but according to the European Commission, the information may include data on performance and durability, among other things. In general, it covers:
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Identity: a unique ID, manufacturer, battery type and date of manufacture.
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Composition: materials and chemistry.
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Performance and durability: capacity, expected lifetime and test results.
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Carbon footprint and share of recycled content.
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Supply chain information (due diligence).
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Information for repairers and recyclers: how the battery is dismantled and handled at end of life.
Not all of this information needs to be in place from day one. The carbon footprint and recycled content are still waiting for supplementary legal acts, and the due diligence information only applies from August 2027, when the supply chain requirements are introduced. The Commission has published guidance showing which data points apply to each battery category in February 2027.
Who gets to see what?
Just because a piece of information is mandatory doesn’t mean it’s public. The information is divided into different access levels:
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Public information: can be seen by anyone who scans the QR code.
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Restricted information: available to authorities and notified bodies, among others.
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Information for parties with a legitimate interest: for example, recyclers and repairers, who get access to certain more sensitive data.
The rules for the last group are not finished. The legal act that was to specify who has a legitimate interest should have been adopted by 18 August 2026, but has not yet been adopted, and the Commission has moved the timetable to the fourth quarter of 2026. This doesn’t change the obligation itself, though: the requirement applies from 18 February regardless of whether the access rules are ready by then.
How does the system work technically?
The passport is not stored in a central database. The system is decentralised, and the detailed information is held by the responsible economic operator. This means that you, or a service provider you hire, must be able to store, update and provide the passport throughout the battery’s lifetime. The QR code on the battery points there, and an EU registry keeps track of the unique ID numbers.
How to prepare
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Map which of your batteries are covered. Go through category and capacity.
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Identify what data you need and where it is. What do you have yourselves, and what must come from suppliers?
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Talk to your suppliers now. Ask what data they can provide, in what format, and when.
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Decide how the passport will be managed. Will you build your own solution or use a service? How will you handle access levels and updates?
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Follow developments. Several legal acts are still on the way, so build in room to adapt.
There is also a commercial angle. A supplier’s ability to produce a passport is becoming a purchasing criterion in its own right. Those who can show that the data is in place therefore have an advantage.
Common mistakes
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Waiting for everything to be finalised. The date applies regardless of which details are missing, and data work takes time.
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Assuming the supplier will sort out the passport for you. Responsibility lies with whoever places the battery on the market.
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Confusing the QR code on all batteries with the battery passport. The passport only applies to certain categories.
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Treating it as an IT project. It is just as much a matter of processes, responsibilities and supplier relationships.
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Forgetting that the passport must be kept up to date throughout the battery’s lifetime.
Where to go from here
Start by finding out whether your batteries are covered and which data you’re missing. This is work you can begin right now, even though some details have yet to be settled.