What is the EU Battery Passport Regulation?
The EU Battery Passport comes from Regulation (EU) 2023/1542, which sets out the EU rules for batteries and waste batteries.
The regulation addresses sustainability, safety, labelling, carbon footprint, recycled content, due diligence, and digital battery passports as part of a broader compliance framework. It sits alongside the EU’s wider work on Digital Product Passports.
The battery passport is a digital record that contains information at both model and individual battery level, depending on the data category. It helps different actors access relevant information when needed, including regulators and other authorised actors.
In practice, the passport supports traceability, compliance checks, clearer product information, recycling, second-life use, and supply chain transparency.
Where Battery Passport Requirements Sit in Regulation (EU) 2023/1542
The battery passport requirement is set out mainly in Article 77 of Regulation (EU) 2023/1542.
Article 77 establishes that certain batteries must have an electronic record, or battery passport, accessible via a data carrier such as a QR code, linked to a unique identifier, as further specified in the implementing technical standards.
The regulation also connects the passport to related information on labelling, carbon footprint, recycled content, due diligence, performance, durability, and end-of-life treatment.
That means the passport should be treated as a structured compliance record, not as a simple web page.
Which Batteries Are In Scope Under Article 77?
The main battery categories in scope are electric vehicle batteries, light means of transport batteries, and industrial batteries with a capacity greater than 2 kWh.
This makes the regulation especially relevant for companies involved in EVs, e-bikes, e-scooters, energy storage, industrial battery systems, and other in-scope battery products placed on the EU market.
Companies outside the EU may also be affected if their batteries are placed on the EU market or put into service there.
Who Must Comply When Batteries Are Placed on the EU Market?
The responsibility generally sits with the economic operator placing the battery on the EU market.
Depending on the supply chain, that may be the manufacturer, importer, or another responsible operator.
In practice, compliance often requires data from several parties across the supply chain. A battery company may need information from cell suppliers, module suppliers, raw material suppliers, component suppliers, testing providers, logistics partners, and recycling partners, as well as internal product, compliance, and sustainability teams. For a wider view of battery industry compliance, see our industry overview.
That is why many companies need to start preparing before the 2027 deadline. The data may not already exist in one place.
Battery Passport Timeline: 2025 to 2027
Battery passport preparation should be viewed as part of a wider internal readiness timeline, not as additional legal deadlines.
A practical approach is:
Early preparation and data mapping
Companies should identify which batteries may be in scope, where required data is stored, and which suppliers hold missing information.
This is also the right time to review internal systems, product records, carbon data, and supplier documentation.
System setup and supplier engagement
By 2026, companies should be moving from planning to implementation.
This may include building internal data models, testing passport records, creating supplier workflows, and checking whether required information can be updated over time.
Battery passport requirement begins
From 18 February 2027, in-scope batteries placed on the EU market or put into service must have a battery passport.
Companies should not leave implementation until the deadline.
What Information a Battery Passport May Need to Include
The passport must include information specified in Annex XIII and implementing technical standards. This is commonly grouped into categories such as battery identification, manufacturer details, battery category, place and date of manufacture, model information, carbon footprint, recycled content, performance and durability, material composition, due diligence, repair and reuse, dismantling and recycling, safety, and end-of-life treatment.
The list above is indicative, not exhaustive. The exact data set, minimum content, and format will be defined by Annex XIII together with the implementing technical acts adopted under the Regulation, and should be checked against those sources before implementation.
For companies, the important point is that the passport will likely depend on data that sits across many systems and suppliers, and is expected to be a living, updatable record over the battery lifecycle rather than a one-time upload.
Public, Restricted and Authorised Access to Battery Passport Data
Not every user should see every data point.
Battery passport information may need to be managed through different access levels, with some data public and other information available only to authorised actors or those with a legitimate interest, as further defined by the Regulation and its implementing acts.
This matters because battery passport implementation is not just about publishing information online. It also requires data governance.
Companies need to think about which data should be public, which should be restricted, who can access restricted data, and how information is controlled and updated.
How QR Codes, Unique Identifiers and Data Records Work Together
The regulation links the passport to a physical data carrier such as a QR code. The exact data carrier format will be specified in the implementing technical standards.
In practice, the data carrier acts as the access point, the unique identifier connects the physical battery to its digital record, and the digital record stores the structured information behind the passport.
These three parts work together across the battery lifecycle. A strong implementation should keep them connected and up to date.
Common Battery Passport Data Challenges for Manufacturers and Importers
Many companies underestimate the data work required for battery passport preparation.
The main challenge is not the final passport interface; it is collecting, structuring, checking, and maintaining the required information.
Common challenges include battery data spread across different systems, supplier information stored in PDFs or spreadsheets, missing bill of materials data, inconsistent product naming, limited carbon footprint data, no clear owner for passport data, restricted information needing access control, data changing after market placement, difficulty linking product data to compliance documents, and manual workflows that are hard to scale.
That is why companies should start with data readiness before choosing how the passport will be displayed.
How to Prepare for Battery Passport Compliance Under EU Regulation 2023/1542
Battery passport preparation should begin with a practical data review.
Companies can start with these steps:
Identify in-scope batteries
Review the product portfolio and confirm which batteries may fall under the passport requirement, especially EV batteries, LMT batteries, and industrial batteries above 2 kWh.
Map required data categories
Create a list of the data points that may be needed for each battery model or product line, grouped by topic such as identification, carbon, recycled content, performance, safety, composition, and end-of-life information.
Find where the data lives today
Check which systems currently store battery information, including ERP, PLM, PIM, supplier portals, spreadsheets, PDFs, test reports, sustainability reports, and compliance documents.
Identify supplier dependencies
Many required data points may sit outside your organisation, so suppliers should be engaged early to confirm what information they can provide, in what format, and how often it can be updated.
Define access levels
Decide which information is public, restricted, or available only to authorised actors, and align that decision across compliance, legal, product, sustainability, and commercial teams.
Test a pilot passport
Start with one battery model or product line, build a pilot record, test the data flow, identify gaps, and improve the process before scaling. Tools like a dedicated battery passport platform can help structure this process.
Create an update process
The passport should not be treated as a one-time upload. Companies need a process for maintaining records, updating information, managing documents, and tracking changes over time.
Battery Passport Readiness Checklist
Before starting implementation, ask:
- Do we know which battery models are in scope?
- Do we know who is legally responsible for placing them on the EU market?
- Do we know which suppliers hold required information?
- Do we have structured BOM data for each battery model?
- Do we have carbon footprint data available?
- Do we know which data should be public or restricted?
- Do we have a way to connect each battery to a unique digital record?
- Do we have internal owners for passport data?
- Do we have a process to keep the information updated?
- Have we tested a pilot passport before the 2027 deadline?
If the answer to several of these questions is no, the main risk is not the passport itself. The main risk is data readiness.
FAQ
- What is the EU Battery Passport?
- The EU Battery Passport is a digital record required for certain batteries under Regulation (EU) 2023/1542. It provides key information about the battery, including identification, sustainability, performance, and end-of-life data.
- When does the EU Battery Passport become mandatory?
- The battery passport requirement applies from 18 February 2027 for in-scope batteries placed on the EU market or put into service.
- Which batteries need a battery passport?
- The main in-scope categories include electric vehicle batteries, light means of transport batteries, and industrial batteries above 2 kWh.
- What is Article 77 of Regulation (EU) 2023/1542?
- Article 77 establishes the battery passport requirement. It provides that industrial batteries with a capacity above 2 kWh, light means of transport batteries, and electric vehicle batteries placed on the market or put into service shall have a battery passport, accessible via a data carrier and linked to a unique identifier.
- Is a QR code the same as a battery passport?
- No. The QR code is the access point. The battery passport is the digital record behind it.
- Who is responsible for the battery passport?
- Responsibility generally sits with the economic operator placing the battery on the EU market. Depending on the supply chain, that may be the manufacturer, importer, or another responsible operator.
- What data is needed for a battery passport?
- The passport may include data on battery identification, manufacturer details, carbon footprint, recycled content, performance, durability, material composition, due diligence, safety, repair, reuse, and recycling.
- Does all battery passport data need to be public?
- No. Some data may be public, while other information may be restricted to authorised actors, regulators, or specific value chain participants.
- Why should companies start before 2027?
- Because the hardest part is usually collecting and structuring the data. Many companies need time to engage suppliers, clean internal records, define access levels, and test pilot passports.