Do I need a battery passport?

1. Is your battery one of the three covered types?

The EU Batteries Regulation (EU) 2023/1542 sorts batteries into categories. Only three of them need a passport:

A few kinds of equipment are outside the regulation entirely, such as military equipment and equipment designed to be sent into space.

The passport applies to the finished battery: the working unit, which for a traction battery normally includes its battery management system (BMS). Loose cells and modules imported for assembly normally don't need one; the finished battery made from them does. If several packs share one BMS and work as one battery, they need one passport; packs that work independently are separate batteries.

2. Is it placed on the market from 18 February 2027?

The passport isn't retroactive. Batteries that were already placed on the EU market before 18 February 2027 don't need one added later.

"Placed on the market" means the first time a battery is supplied in the EU, for example when a manufacturer or importer first sells it on, not when a shop finally sells it to a customer. Every battery placed on the market from 18 February 2027 onwards needs a passport, even if the same model was sold before. The same applies to a battery a company puts into service for its own use without selling it.

Second-life batteries have their own rule: a battery that is repurposed or remanufactured after that date gets a new passport, linked to the original one where one exists. A simple repair doesn't need a new passport.

3. Who is responsible for it?

The economic operator that places the battery on the EU market must make sure the passport exists and that its data is accurate, complete and up to date. In practice:

• You make finished batteries in the EU: you, as the manufacturer.
• You import finished batteries, or products with a finished battery inside (like complete e-bikes), from outside the EU: you, as the importer.
• You assemble imported cells or modules into batteries in the EU: you become the manufacturer.
• You buy batteries from an EU manufacturer or importer and resell them: not you; the passport should already exist. Read our guide for importers and distributors for the edge cases.

You can authorise another company in writing, such as your supplier or a service like PackPass, to create and update the passport for you. The legal responsibility still stays with you.

4. What a battery passport actually is

A battery passport is an online record for each individual battery, with its own unique identifier, that people open by scanning a QR code on the battery. Most of the data is the same for every battery of a model (chemistry, capacity, manufacturer); some is specific to the individual battery (serial number, manufacture date, state of health). See a sample passport or every field it contains.

• Public part: general information anyone can see, such as manufacturer, battery type, chemistry, capacity, weight and how to return it at end of life.
• Restricted part: detailed information only for people with a legitimate interest (such as repairers and recyclers), and some test results only for authorities and the Commission. The exact access rules will be set by an implementing act; the Commission expects to publish a draft in late 2026.

Not every field is needed on day one. According to the Commission, carbon footprint and recycled content data aren't required yet in February 2027, because the rules behind them are still being adopted; the supply chain due diligence report follows from August 2027, and only for companies with a net turnover of €40 million or more, or that belong to a larger group.

5. The EU registry

Each passport's identifier must also be registered in the EU's central Digital Product Passport registry, which opened in July 2026. Registration has to be done by the company that places the battery on the market, after it verifies its identity in the registry, for example with a qualified electronic seal. The registry stores the passport's identifiers and registration details, not the passport itself; the passport is hosted by you or your provider. Before battery passports can be registered, the Commission is publishing the technical data models the registry uses to check them; a test environment is already open. More in our guide to the EU registry.

6. What to do now

1. List your battery models and sort them using the table above.
2. Work out who places each one on the EU market: you, your supplier or someone in between.
3. Ask your suppliers for the data now: datasheets, test reports, chemistry and materials, capacity, voltage, cycle life, operating temperatures, weight and safety information. Collecting it takes weeks.
4. Plan the QR labels so they can go on batteries before shipment.
5. Arrange a way to verify your company in the EU registry, such as a qualified electronic seal (sole traders can use a qualified electronic signature).

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