Why this matters even though you are outside the EU
Regulation (EU) 2023/1542 places the obligation to create and maintain the passport on the economic operator that places the finished battery on the EU market. For a Chinese manufacturer that is usually an EU importer, a distributor selling under its own brand, or the manufacturer's own EU entity.
That operator cannot build a credible passport alone. The carbon footprint, material composition, recycled content and supply chain records sit with you and your suppliers. A supplier that can hand over complete, verified data quickly is easier for an EU customer to work with than one that cannot.
What is in scope
The passport applies to three battery categories from 18 February 2027:
| Battery type | Passport from 18 February 2027 | Typical Chinese export |
|---|---|---|
| Electric vehicle batteries | Yes | Traction packs, cells for EU vehicle plants |
| Light means of transport batteries | Yes | E-bike, e-scooter and swappable two wheeler packs |
| Industrial batteries with a capacity greater than 2 kWh | Yes | BESS containers and racks, forklift, telecom backup, UPS |
| Portable batteries and SLI batteries | Not in this scope | Consumer and starter batteries |
For more detail by segment, see our guides:
Who is responsible: the operator, the importer or you?
Responsibility depends on what you ship and who completes the battery.
The economic operator placing the finished battery on the EU market. This operator is responsible for the passport and must register it. For a finished battery you export, that is typically your EU importer or your EU entity.
If you export cells or modules only. When an EU company assembles them into a finished battery, the EU entity completing the battery becomes the manufacturer and is responsible. Imported cells or modules that are only components are not treated as the finished battery.
A non EU manufacturer can help create and update the passport. This works under written authorisation from the responsible operator. Authorisation does not transfer legal responsibility, and acting this way does not make you the EU manufacturer or importer.
Producer responsibility is a separate track. Registration and authorised representative requirements for extended producer responsibility depend on your role, your sales route and national rules in each Member State. They are not a blanket passport requirement, so check each market.
Agree early with your EU customer who acts as the operator, who creates the passport data and who answers a regulator. Put it in writing.
What the passport contains
A passport is a structured record linked to one battery through a unique identifier. The Commission's data points guidance lists 71 data points, not 71 universally mandatory fields. For each battery category it shows whether a point is mandatory, optional, conditional or not required to be completed in February 2027. The guidance is updated over time, so always use the latest version.
The German DIN DKE SPEC 99100 defines the data attributes in more detail. Broadly the passport covers:
| Area | Examples |
|---|---|
| Identification | Manufacturer, model, place and date of manufacture, unique identifier |
| Composition | Chemistry, critical raw materials, hazardous substances |
| Carbon footprint | Lifecycle footprint and the calculation behind it |
| Recycled content | Share of recovered cobalt, lithium, nickel and lead |
| Performance and durability | Capacity, voltage, expected life |
| Due diligence | Responsible sourcing information for raw materials |
| End of life | Dismantling, safety and recycling information |
Part of the passport is public. Another part can only be accessed by notified bodies, market surveillance authorities and the Commission. A forthcoming implementing act will clarify which other users have a legitimate interest and what they may do with restricted data, so this area is not fully settled. Not everything you share becomes public.
What is different for industrial batteries and BESS
Industrial exporters often assume the EV playbook applies. It does not entirely.
The passport applies to the finished battery. It does not apply automatically to every cell, module or rack. A battery is a finished, safely working product that can deliver electrical energy. If several packs depend on a common battery management system and together form one working battery, the whole system is treated as one battery with one passport. If packs are complete and work independently, each is a separate battery. The Commission says this is assessed case by case, including for the 2 kWh threshold, so work out the answer for each product configuration with your customer.
Cell data still flows into the passport. Whichever unit carries the passport, the data behind it comes from cell and module suppliers across several production sites.
Category details matter. Some carbon footprint rules treat batteries with external storage, such as flow batteries, differently from other rechargeable industrial batteries.
Dates depend on secondary acts. Several obligations, including carbon footprint declarations and performance classes, depend on delegated and implementing acts from the Commission. Sources disagree on the exact dates, so check the latest status before you set internal deadlines.
The China specific challenge: data leaving China
China already has its own battery traceability system. GB/T 34014 defines a coding rule for automotive traction batteries, and producers report data to a national traceability platform. This is useful groundwork, because you already track identification and lifecycle data. But it does not by itself show that your records satisfy the EU passport, so map your existing records to the EU data points and identify what is missing.
The harder question is which data can be sent abroad. China's Data Security Law and Cybersecurity Law can require security assessments for the outbound transfer of data classed as important data. Whether a given battery data field is caught depends on the data and the rules that apply, and the catalogue for the battery sector is still developing.
What to do about it:
- Split your data into what can be shared, what needs approval, and what must stay restricted.
- Agree with each EU customer which fields are public in the passport and which are restricted to authorities.
- Use an access controlled channel for sensitive documents, not general email.
- Take legal advice on outbound data transfer for your specific data.
The hardest data to collect
Carbon footprint. It will not be required in battery passports from February 2027, because its requirements have separate application dates that depend on further EU acts. It is still the slowest data to build. It must follow the EU methodology and rely on real energy and material data per production line, so start collecting electricity use, material inputs and process data now.
Recycled content and composition. Recycled content is also not required in the passport from February 2027, again with separate dates. Composition and the evidence behind it come from your material and cell suppliers. You need a way to request, receive and verify their documents.
Due diligence. Due diligence information is not required in battery passports from February 2027. The supply chain due diligence obligations were postponed to 18 August 2027 by Regulation (EU) 2025/1561, and the due diligence report is required from then. Cobalt, lithium, nickel and natural graphite sources need documented origin and processor records, so start mapping them now.
Change control. Every change to a material, supplier or factory can change the passport. You need a controlled process so the passport matches the battery actually shipped.
Collecting and verifying supplier documents is where most exporters lose time. See how the battery passport platform organises supplier evidence.
Not yet required versus not yet existing
The Commission's FAQ separates data that is not yet required from data that does not yet exist.
Not yet required. Carbon footprint, recycled content and due diligence information will not be required in battery passports from February 2027. Their requirements have separate application dates.
Not yet existing. For a new battery, information generated through use may be blank at first. Battery status and performance and durability values are the exception and have to be provided.
That gives exporters breathing room on some data, but not on identification, composition, performance and durability, which need to be ready.
A practical plan for exporters
| Step | Action |
|---|---|
| 1 | List which battery models are in scope, and whether each ships as a finished battery or as components for EU assembly. |
| 2 | Agree with your EU customer who the economic operator is, who creates the passport data, and what written authorisation you need. |
| 3 | Build a data map: each passport field, the system or supplier that holds it, and whether it can leave China. |
| 4 | Start carbon footprint data collection per production line. |
| 5 | Request composition, recycled content and sourcing documents from sub suppliers, with review dates. |
| 6 | Pilot one passport on a single model, then scale. |
Common mistakes
- Waiting for the customer to ask, then trying to build records in weeks
- Sending PDFs by email and calling it data
- Assuming a Chinese traceability code satisfies the EU passport
- Treating the passport as the importer's problem
- Ignoring outbound data rules until the first shipment is blocked
- Forgetting that holidays such as Lunar New Year slow supplier responses
Chinese manufacturer FAQ
Does the battery passport apply to batteries made in China?
Yes, if they are placed on the EU market. The rules follow the product, not the factory location.
Who is legally responsible, the factory or the importer?
The economic operator placing the finished battery on the EU market is responsible and registers the passport. You can be authorised in writing to create and update it, but that does not transfer legal responsibility. Contracts will push data obligations back to you.
We only export cells or modules. Do we need a passport?
Imported cells or modules that are only components are not treated as the finished battery. The EU entity that completes the battery becomes the manufacturer and is responsible, and will still need your data.
Does it apply to BESS and other industrial batteries?
Yes. Industrial batteries with a capacity greater than 2 kWh need a passport from 18 February 2027. The passport applies to the finished battery, and whether a whole energy storage system counts as one battery depends on how it is built.
Will our trade secrets become public?
Only part of the passport is public. Another part is limited to notified bodies, market surveillance authorities and the Commission, and a forthcoming implementing act will clarify access for other users with a legitimate interest.
Is our Chinese traceability code enough?
It is useful groundwork, but not the same as the EU passport. Map your existing records to the EU data points and identify what is missing.
When should we start?
Now. Carbon footprint and sub supplier data take months to collect.
A note on this guide
This guide is general information, not legal advice. Check the current text of Regulation (EU) 2023/1542 and Commission guidance before making compliance decisions. For an article by article breakdown, see our EU Battery Regulation 2023/1542 explained, and for the fields themselves, our EU battery passport data points guide.