The EU battery passport: requirements explained
The battery passport is the first Digital Product Passport to carry a hard date under EU law. From 18 February 2027, certain batteries cannot be placed on the EU market without one. If you make, import or distribute batteries above the size thresholds, the obligation already affects how you collect data today, because the passport has to be populated and accurate on the day the battery is sold. This article explains what the battery passport is, which batteries it covers, the data fields it must hold, the deadline, and who carries the legal responsibility.
What is the EU battery passport?
The EU battery passport is an electronic record, required under Regulation (EU) 2023/1542, that holds defined information about a specific battery across its life. Each covered battery gets its own passport, accessed through a QR code on the battery, with the content set out in Annex XIII of the regulation. It is the first Digital Product Passport to go live under the EU framework.
The passport is not a single document. It is a structured data record tied to a unique identifier for each individual battery placed on the market. Some fields are open to anyone who scans the code. Others are restricted to repairers, recyclers, regulators and authorised bodies.
The same regulation also requires labelling, separate collection rules and recycled-content targets, so the passport sits inside a broader set of obligations rather than standing alone. For the wider context, see our guide to what a Digital Product Passport is.
Which batteries need a passport?
The passport applies to three categories: electric vehicle batteries, light means of transport (LMT) batteries, and industrial batteries with a capacity greater than 2 kWh. Portable batteries and smaller industrial batteries are out of scope for the passport, though they remain subject to other parts of the regulation such as labelling and collection.
LMT batteries power vehicles such as e-bikes and e-scooters. Industrial batteries cover stationary storage, including the large battery packs used for grid and commercial energy storage, where the 2 kWh threshold draws the line. Electric vehicle batteries are covered regardless of capacity.
The scope is defined by the battery, not the brand, so an importer placing covered batteries on the EU market carries the same obligation as a domestic manufacturer. This product-by-category approach is the same logic the EU uses across its passport programme, which we cover in which products need a DPP.
What data must the battery passport contain?
Annex XIII of Regulation (EU) 2023/1542 sets the required fields. They group into identity and origin, performance and durability, sustainability, and supply chain. The sustainability fields are the heaviest, covering the carbon footprint declared per kWh, recycled-content shares for cobalt, lithium, nickel and lead, and the results of supply chain due diligence.
In practice, the data spans the whole production chain. Identity and origin fields cover the manufacturer, manufacturing place and date, battery model and a unique battery identifier. Performance fields cover rated capacity, voltage, expected lifetime and state of health.
The sustainability and supply chain fields are where most of the work sits, because the carbon footprint figure and recycled-content percentages have to be calculated, documented and kept current, and the due diligence record has to show how risks tied to raw materials such as cobalt and lithium were identified and managed.
None of this is information a brand can assemble at the last minute. It comes from procurement, manufacturing and supplier records that need to be captured long before the battery reaches the market. The battery passport is built on the same Ecodesign for Sustainable Products Regulation framework as the rest of the EU programme, explained in our guide to the EU ESPR.
When does the battery passport deadline hit, and who is responsible?
The battery passport obligation applies from 18 February 2027. From that date, covered batteries placed on the EU market must carry a passport accessible by QR code. The economic operator that places the battery on the market is responsible for setting up the passport, and for keeping the data accurate and available.
That responsibility is specific. It is not enough for the data to exist somewhere in the supply chain. The operator placing the battery on the market has to make sure the passport is populated, correct and reachable through the unique identifier, and that it stays that way.
Because each battery needs its own record, the obligation scales with volume, and the data has to be collected continuously rather than compiled once. A manufacturer running thousands of units a month is maintaining thousands of individual records, each one auditable. The earlier the underlying data is structured and linked to a unique identifier, the less of a scramble 2027 becomes.
What does the battery passport signal for other categories?
The battery passport is the template. The same structure of unique identifiers, QR access and tiered data is the model the EU is rolling out across other product categories. It enters through sustainability, but operationally it is a product and supply chain data system, which changes who inside a business needs to own the work.
That distinction matters. A sustainability team can interpret the rules. It cannot generate a bill of materials or a supplier due diligence record. That sits with product and procurement. This is the view James Williamson, co-founder of Orijin Plus, takes on the battery passport, and it is the reason he treats it as the clearest signal of where the wider EU programme is heading.
The directional read for any brand outside batteries is simple. Getting comfortable with structured product data now is the practical preparation. If you place batteries on the EU market, the data you will need in the passport is data you can start structuring today. See how this works in Digital Product Passports on Orijin Plus.
FAQ
What is the EU battery passport?
The EU battery passport is an electronic record required under Regulation (EU) 2023/1542. It holds defined information about an individual battery, accessed through a QR code, with the content set in Annex XIII. It is the first Digital Product Passport to go live under the EU framework, covering identity, performance, sustainability and supply chain data.
When does the battery passport become mandatory?
The battery passport obligation applies from 18 February 2027. From that date, covered batteries placed on the EU market must carry a passport accessible by QR code. The data must be populated and accurate at the point the battery is placed on the market, so the practical preparation work starts well before the deadline.
Which batteries need a battery passport?
Three categories need a passport: electric vehicle batteries, light means of transport batteries such as those in e-bikes and e-scooters, and industrial batteries with a capacity above 2 kWh. Portable batteries and industrial batteries at or below 2 kWh are outside the passport scope, though other parts of the regulation still apply to them.
What information does the battery passport have to contain?
Annex XIII sets the fields. They cover identity and origin, performance and durability, sustainability, and supply chain. The sustainability fields include the carbon footprint per kWh, recycled-content shares for cobalt, lithium, nickel and lead, and supply chain due diligence results. Each battery also carries a unique identifier.
Who is responsible for the battery passport?
The economic operator that places the battery on the EU market is responsible. That operator sets up the passport, links it to the battery's unique identifier, and keeps the data accurate and available. The duty applies equally to a domestic manufacturer and to an importer placing covered batteries on the market.
Is the battery passport the same as a Digital Product Passport?
Yes. The battery passport is a Digital Product Passport, and the first one to carry a binding date under the EU framework. The EU plans to extend the same model, using unique identifiers, QR access and tiered data, to other product categories, which makes the battery passport a useful template for what is coming.
What happens if a battery does not have a passport?
A covered battery placed on the EU market from 18 February 2027 without a compliant passport does not meet the requirements of Regulation (EU) 2023/1542. That exposes the responsible operator to enforcement and to losing access to the EU market, in the same way any non-conforming product placed on the market would.
