Does an aerospace battery need an EU battery passport?
It depends entirely on capacity, not on the fact that a battery flies. Conventional aircraft auxiliary power and engine start batteries, along with most ground support equipment batteries, are frequently well below the 2 kWh threshold that triggers the battery passport requirement, which means the majority of today's conventional aviation power systems sit outside its scope, though they remain subject to other parts of the regulation. eVTOL and electric aircraft propulsion packs are a different matter: their capacity is typically far above 2 kWh, placing them firmly within the industrial battery category that must carry a passport under Article 77 once placed on the EU market or put into service from 18 February 2027. Where a conventional aviation battery does exceed 2 kWh, whatever its role on the aircraft, it should be treated as an industrial battery and scoped for a passport on that basis rather than assumed exempt because it is a conventional component.
The distinction is set by capacity, not by airworthiness classification, so a battery's DO-311A or ETSO approval status has no bearing on whether it needs a passport. A low-capacity APU battery approved to DO-311A remains out of scope regardless of how rigorously it has been certified. Conversely, a propulsion pack above 2 kWh is in scope even before it holds full type certification, since the passport obligation attaches to the battery being placed on the market, not to the aircraft programme's certification stage.
This matters for programme planning. Manufacturers building both conventional and electric platforms need to track scope on a battery-by-battery basis rather than applying a single answer across their product range, and eVTOL developers in particular should treat passport readiness as a parallel workstream alongside airworthiness certification rather than something to address after type certification is secured.
How aviation certifications interact with the passport
Aerospace batteries already sit inside one of the most demanding certification regimes of any industry, and none of it is replaced by the battery passport. DO-311A sets airworthiness requirements for rechargeable lithium batteries, DO-160G defines the environmental conditions and test procedures airborne equipment must withstand, and both originate from RTCA (the Radio Technical Commission for Aeronautics), the source of the DO-series standards used across civil aviation.
ETSO (European Technical Standard Order) and EASA's ETSOA process, or the ADOA route for organisations approved to self-certify design changes, govern how a battery component is authorised for installation on an aircraft. These are safety and performance frameworks, and none of DO-311A, DO-160G, ETSO or EASA ADOA/ETSOA satisfy the battery passport obligation on their own. The passport is a separate, product-level information requirement introduced by Regulation (EU) 2023/1542, sitting alongside airworthiness approval rather than inside it.
In practice, the two regimes need to run together. Test data generated for DO-160G environmental qualification and materials declarations compiled for ETSOA overlap substantially with information the passport needs to disclose, so aerospace OEMs that structure their certification data capture with passport fields in mind avoid duplicating the work later.
Who is responsible for an aerospace battery passport?
Responsibility sits with the economic operator placing the finished battery on the EU market or putting it into service, which for propulsion packs above 2 kWh is typically the battery manufacturer or pack integrator supplying the eVTOL or electric aircraft programme, or the airframer itself where the battery is only ever placed on the market as part of the assembled aircraft.
For aerospace supply chains built around specialist cell and pack suppliers outside the EU, the importer bringing the battery into the EU market carries the legal obligation. Contractual terms between airframer, pack integrator and cell supplier can allocate who compiles which data, but the accountability for the passport itself stays with whichever party places the battery on the EU market.
Aircraft OEMs and eVTOL developers are not passive recipients of this obligation even when a supplier holds legal responsibility. Airworthiness certification already requires close visibility into battery design, materials and test history, so OEMs are well placed to specify passport data requirements in supplier contracts early, rather than discovering gaps once a propulsion pack is ready for market.
What data does the passport need to contain?
Under Article 77, the battery passport is an electronic record linked to the battery via a QR code, combining model-level information with data specific to the individual battery, including information generated through its use. It carries information across several categories: manufacturer and battery identification, materials composition, carbon footprint, performance and durability data, and information relevant to collection, dismantling and recycling at end of life.
For aerospace propulsion packs, much of this overlaps with data already generated for airworthiness certification, including cell chemistry, energy and power ratings, and results from environmental qualification testing. What is new is the requirement to make this information accessible through a QR code linked to the battery, structured for a regulatory audience rather than an aviation authority.
The full data model, including which fields apply to industrial batteries specifically, is set out in our EU battery passport regulation guide which covers the requirement in detail across battery categories
eVTOL and electric aircraft propulsion batteries
Propulsion batteries for eVTOL aircraft and other electric aircraft platforms are the clearest in-scope case in aerospace. Their capacity, driven by the power demand of vertical lift and sustained flight, sits far above the 2 kWh threshold, so passport obligations apply without the scope ambiguity that surrounds smaller conventional aviation batteries.
These programmes are also unusually early in their certification lifecycle compared with established aircraft types, which is an advantage for passport compliance rather than a complication. Because much of the design, materials and testing documentation is still being assembled to satisfy DO-311A and DO-160G requirements, eVTOL developers can build passport data capture into that process from the outset instead of retrofitting it onto a mature product line.
Battery swapping and refurbishment models under consideration for some eVTOL operating concepts add a further layer, since a passport needs to remain accurate as a battery pack is removed, serviced, redeployed or eventually replaced. Developers planning for high-cycle operational models should treat the passport as a data record that follows the physical battery through its operational life, not a one-off document produced at the point of sale.
Key dates for aerospace OEMs
The regulation's obligations phase in over several years. We cover the full sequence in our EU battery passport timeline, and the dates that matter most for aerospace propulsion battery programmes are:
Regulation applies
Regulation (EU) 2023/1542 starts applying from this date, replacing the previous Battery Directive in stages and establishing the scope categories, including the industrial battery category, that later determine which aerospace batteries need a passport.
Carbon footprint - rechargeable industrial batteries above 2 kWh
Carbon footprint declaration obligations for rechargeable industrial batteries above 2 kWh are scheduled from this date, or from 18 months after the Commission's carbon footprint methodology and format acts enter into force, whichever is later. For eVTOL and electric aircraft propulsion packs above 2 kWh, this is the first substantive reporting obligation to plan for, ahead of the passport itself.
Battery passport mandatory
Every industrial battery above 2 kWh placed on the EU market or put into service needs a QR-accessible battery passport under Article 77 from this date. This is the deadline that applies directly to eVTOL and electric aircraft propulsion packs, while most conventional aircraft auxiliary and ground support batteries remain out of scope on capacity grounds.
Supply chain due diligence
Supply chain due diligence obligations under Articles 48 to 50 apply from this date, following the two-year postponement under Omnibus IV. For aerospace propulsion battery supply chains, which often span specialist cell manufacturers and pack integrators outside the EU, this extends compliance obligations beyond the passport itself into sourcing and materials due diligence.
How aerospace OEMs can prepare
1. Establish scope on a battery-by-battery basis Map every battery type across your product range against the 2 kWh threshold rather than assuming a single answer for conventional aircraft, ground support equipment and eVTOL propulsion packs. This determines which programmes need passport compliance work and which do not.
2. Align certification and passport data capture Review what materials, performance and test data is already being generated for DO-311A airworthiness approval and DO-160G environmental qualification, and identify where it can feed directly into passport data fields rather than being recreated separately.
3. Clarify responsibility across the supply chain Confirm which party in the cell supplier, pack integrator and airframer chain is placing the finished battery on the EU market, and set contractual expectations for who compiles and maintains which passport data.
4. Build carbon footprint reporting ahead of the passport deadline Rechargeable industrial batteries above 2 kWh face carbon footprint obligations before the passport itself becomes mandatory, so propulsion pack manufacturers should start collecting the underlying data now rather than treating it as part of the 2027 deadline.
5. Plan for data that changes over the battery's operational life For eVTOL and electric aircraft platforms considering swap or refurbishment models, design passport data management so it can be updated as a battery is serviced, redeployed or replaced, rather than treating the passport as a static record.
Aerospace battery passport FAQ
Do conventional aircraft batteries need an EU battery passport?
Most do not. Auxiliary power, engine start and ground support equipment batteries are frequently below the 2 kWh threshold that triggers the battery passport requirement, so the majority of conventional aviation batteries fall outside its scope, though they remain subject to other parts of the regulation. Where a conventional aviation battery does exceed 2 kWh, it should be treated as an industrial battery and scoped for a passport on that basis.
Do eVTOL batteries need an EU battery passport?
Yes. eVTOL and electric aircraft propulsion packs typically sit far above the 2 kWh threshold, placing them within the industrial battery category that must carry a passport under Article 77 once placed on the EU market or put into service from 18 February 2027.
Does DO-311A certification satisfy the battery passport requirement?
No. DO-311A addresses airworthiness for rechargeable lithium batteries and is entirely separate from the battery passport, which is a product information requirement introduced by Regulation (EU) 2023/1542. A battery can hold DO-311A approval and still need a passport, or vice versa, depending on its capacity.
Who is responsible for the battery passport on an aerospace propulsion pack?
The economic operator placing the finished battery on the EU market or putting it into service carries the legal obligation - typically the battery manufacturer or pack integrator supplying the aircraft programme, or the airframer where the battery is only ever placed on the market as part of the assembled aircraft. Contracts can allocate specific data-compilation tasks to other parties in the supply chain, but the legal obligation stays with whichever party places the battery on the market.
When does the aerospace battery passport deadline apply?
In-scope batteries, meaning industrial batteries above 2 kWh such as eVTOL propulsion packs, need a passport from 18 February 2027, when they are placed on the EU market or put into service. Carbon footprint declaration obligations for the same battery category are scheduled from 18 February 2026, subject to supporting delegated acts.
A note on pending implementing acts
Some of the technical specifications behind the battery passport, including detailed data model and format requirements, are still being finalised through implementing and delegated acts. The obligations described on this page come from Regulation (EU) 2023/1542 itself; specific technical details may be refined as supporting legislation is adopted.