Which identifier level ESPR and the Battery Passport require
ESPR Article 10 connects the data carrier to a persistent unique product identifier. Whether passport data is managed at model, batch or item level is determined by the delegated act for the relevant product group.
The Battery Regulation 2023/1542 goes further: for LMT batteries, electric-vehicle batteries and industrial batteries over 2 kWh capacity, a battery passport with a unique battery identifier is required from 18 February 2027. The QR code on the battery leads — depending on the access role — to the data categories under Article 77 and Annex XIII.
What serial and batch data enables
Serial numbers and batches matter operationally for recalls, service, quality checks, spare parts and second-life processes. In a DPP context, they become the bridge between product identity, evidence and lifecycle.
- Model level: Shared passport data for all units of a product model or variant — possible where the delegated act uses this level.
- Batch level: Material, supplier or production information for a manufacturing group — relevant for quality assurance and recalls.
- Item level: Serial number, service events, condition data and individual documents — relevant for affected battery categories through the Battery Passport from 18 February 2027.
- EPCIS events: GS1 EPCIS 2.0 describes lifecycle events (production, shipping, inspection, recycling) with GS1 identifiers — machine-readable and passport-compatible.
Not an isolated traceability system
Nulara does not replace MES, WMS or ERP. The platform structures the compliance and product-passport view of serial and batch data and can use operational systems as sources.
The result is a consistent machine-readable entity across passport, evidence, QR-code access and internal workflows — at the granularity level the delegated act prescribes for that product group.
Sources and next steps
Identifier and data-carrier standards are the technical basis for serial numbers, batches and product-passport access.
Read next in Nulara
- GTIN - Global trade item numbers as stable product identity.
- GS1 Digital Link - Web-enabled connection between identifier and product information.
- Battery Passport - Unique Battery Identifier, data fields and 18 February 2027 deadline.
Primary sources
- EUR-Lex: Regulation (EU) 2024/1781, Articles 9-11 and Annex III - Legal basis for product-passport data, data carriers, unique product identifiers, granularity, access and open data.
- EUR-Lex: Regulation (EU) 2023/1542, Article 77 - Battery passport obligation from 18 February 2027, Unique Battery Identifier and Annex XIII data categories.
- GS1 Global Traceability Standard - Context for model, batch/lot and serial number granularity in traceability processes.
- GS1 EPCIS and CBV 2.0 - Event standard for what, when, where, why and how in supply-chain processes.
Frequently asked questions
- Does every product passport need item-level serial numbers?
- That depends on the product group and delegated act. ESPR allows model, batch or item level. For batteries, the Battery Regulation mandates the Unique Battery Identifier at item level from 18 February 2027.
- What is the Unique Battery Identifier and when is it mandatory?
- The unique battery identifier links the QR code on each affected LMT, electric-vehicle or industrial battery to the battery-passport data under Article 77 and Annex XIII. Deadline for these categories: 18 February 2027.
- Can Nulara use existing serial numbers from ERP or production?
- Yes. Nulara is designed as a compliance and product-passport layer and can reference existing identifiers from operational systems and embed them in the product passport.