Guide · Updated 2026-10-23 · Basis: Regulation (EU) 2023/1542; Implementing Regulation (EU) 2026/1778; Commission Digital Batteries Passport guidance v2.0 (21 Aug 2026)

The battery passport: scope, duties and checklist

Until the battery passport becomes mandatory
2027-02-18
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Batteries are the first mandatory category in the EU Digital Product Passport system: from 18 February 2027, electric vehicle batteries, light means of transport (LMT) batteries and industrial batteries above 2 kWh must carry a digital battery passport when placed on the EU market or put into service, with their unique identifier uploaded to the EU registry. This is a statutory date (Art 77(1)), not an industry forecast.

1. Scope first

Battery categoryIn scope?Notes
Electric vehicle (EV) batteriesMandatoryFrom 18 Feb 2027 at placing on the market
Light means of transport (LMT)MandatoryE-bikes, scooters and similar
Industrial > 2 kWhMandatoryStorage, backup power, telecom, etc.
Industrial ≤ 2 kWhNot this passportExactly 2 kWh counts as “not greater”
Portable and other categoriesNot this passportLabelling, CE and substance duties still apply

Two boundary notes: ① the duty attaches at the time of placing / putting into service — batteries lawfully placed before 18 Feb 2027 are not retroactively covered; stock placed later is. ② The duty follows the battery, not the finished product — with batteries inside equipment, confirm who places the battery on the EU market.

2. Who does what

RoleStatutory dutyTypical EU buyer position
ManufacturerSupply accurate Annex XIII data, configure QR carrier and unique identifierYour Chinese supplier sits here
First placer / person putting into serviceCreate the passport, register in the EU registry, answer for data accuracyUsually you, your EU entity, or your importer
Importer / distributorVerify passport existence and registration identifier before placingYour inbound QC step
Mandated partyMay execute creation / maintenance / registration under written mandateA service provider — a mandate does not transfer statutory liability
One line to remember Whoever first places the battery on the EU market carries creation and registration duties; the manufacturer carries data accuracy. Put both in writing with the supplier. Use the triage tool when unsure.

3. What goes in: how the 71 data points tier out

Annex XIII carries roughly ninety attributes; the Commission guidance “Digital Batteries Passport — data point classification” v2.0 (21 Aug 2026) consolidates them into 71 data points with five applicability tiers. Mandatory counts differ by category (industry tallies: LMT the most, then EV, then industrial — verify against the official document):

TierMeaningExamples
MandatoryMust be complete on day one (18 Feb 2027)Manufacturer info, model & batch, chemistry, critical raw materials, rated capacity, safety, QR & unique identifier
ConditionalApplies when the scenario appliesCertified SOCE for EV (LMT exempt); real-time dynamic metrics for LMT (remaining capacity/power, resistance — not required for EV); substances of concern
DeferredNot in round one; mandatory laterRecycled-content declaration and due diligence (from 18 Aug 2027); carbon footprint class (awaiting delegated act)
VoluntaryFill if availableSome usage-history data (“where applicable”)
ExemptPermanently out for that categoryCheck item by item — never assume
Discipline Do not treat “71 points” or “90 fields” as one uniform must-fill list — mandatory sets differ per category. LMT real-time metrics (points 62-66) impose serious BMS data-upload requirements; check software capability against your BMS before buying.

4. Identifiers and carriers

5. Phased plan to 18 Feb 2027

PhaseWindowKey actions
Settle dutiesNowTriage roles; written create / maintain / register split with suppliers; identify the registering entity
Settle identifiersNow – 1 monthChoose an ISO/IEC 15459 issuing agency (GS1 or equivalent); apply for prefixes
Collect dataIn parallelGenerate the gap checklist; dispatch by owner function; prioritise the mandatory tier
Select services–3 monthsSoftware & hosting selection (guide); if you register, start organisation validation (QSeal) in parallel
Dry run–2 monthsWalk data → passport → QR → resolution with dummy data; verify tiered access
OperateAfter launchDynamic updates, versioning (registry requires full audit trail), persistence outliving the battery

6. What non-compliance costs

From 18 Feb 2027, batteries without a passport cannot lawfully be placed on the EU market. Member-state market surveillance and customs are wired into the registry (Implementing Regulation (EU) 2026/1778). Penalties are set by national law; the nearer-term risk is a market-access break — shipments stopped or recalled.

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Disclaimer This page supports preparation and is not legal advice. Applicability and obligations are governed by the official texts (EUR-Lex consolidated 2023/1542) and the registry’s official User Guide; carbon-footprint details await delegated acts and this page will be updated.