Which batteries need a battery passport?
The battery passport applies from 18 February 2027 to LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries placed on the EU market or put into service.
From that date, batteries must also be marked with a QR code. For affected battery types, this QR code gives access to the battery passport; for other batteries, it gives access to the required labelling and conformity information.
Which data fields matter?
The battery passport contains information about the battery model and the individual battery. Not all data is visible to all users; public information, authority information and data for legitimate-interest actors are separated by access levels.
Core data clusters include manufacturer and model information, battery category, carbon footprint, recycled content, performance and durability parameters, state of health, composition, dismantling instructions and safety measures.
- Public layer: model information, labels and general sustainability data.
- Legitimate-interest actors: detailed composition, dismantling information and replacement parts.
- Authorities and notified bodies: test reports and conformity evidence.
- Individual battery: status, use, charging cycles, state of health and relevant events.
How is the battery passport different from the ESPR DPP?
The battery passport is the first major mandatory product passport with a fixed date. It is anchored in the EU Battery Regulation, but its technical design must remain interoperable with future ESPR Digital Product Passports.
For manufacturers, this is useful: a clean battery data model now creates the basis for future product passport obligations in adjacent product groups such as automotive, electronics and energy storage.
How should manufacturers prepare?
Preparation starts with a reliable link between battery model, physical unit and evidence. Without unique identifiers, the battery passport cannot later be updated or served to authorised users in an auditable way.
A practical four-step plan is: identify affected battery types, map required fields against existing systems, define QR code and GS1 Digital Link strategy, and set approval workflows for model-level and unit-level data.
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