EU Battery Passport 2027: Requirements & Compliance Guide

From 18 February 2027, certain batteries placed on the EU market will require a digital battery passport under Regulation (EU) 2023/1542.

The requirement represents a major change in how battery information is recorded, maintained and shared throughout a battery's lifecycle.

Electric vehicle batteries, light means of transport (LMT) batteries and industrial batteries with a capacity greater than 2 kWh will need an electronic battery passport linked to the physical battery through a QR code.

For manufacturers, importers and other economic operators placing these batteries on the European Union market, preparation should start well before February 2027. Compliance involves considerably more than generating a QR code. Businesses need to identify and collect the required data, determine which information applies to their battery category, establish responsibility for maintaining the information and ensure that their digital system meets the EU's interoperability, accessibility and data integrity requirements.

This article explains the requirements and the practical steps businesses should consider.

What is the EU Battery Passport?

The battery passport is an electronic record associated with an individual battery.

It was introduced by Regulation (EU) 2023/1542 concerning batteries and waste batteries, commonly referred to as the EU Batteries Regulation.

Article 77 of the Regulation establishes that, from 18 February 2027, the following batteries placed on the market or put into service must have a battery passport:

• electric vehicle (EV) batteries;
• light means of transport (LMT) batteries; and
• industrial batteries with a capacity greater than 2 kWh.

The passport contains information relating to the battery model as well as information relating to the individual battery.

This distinction is important.

Some information is relatively static and applies to an entire battery model, while other information can relate specifically to the individual battery and may evolve throughout its operating life.

The European Commission describes the system as decentralised. Detailed battery information is maintained by the responsible economic operator rather than simply being stored in a single central EU database.

At the same time, the EU has established a Digital Product Passport Registry for registration of identifiers and associated information.

Which batteries require a battery passport?

The obligation does not apply to every battery sold in the European Union.

Article 77 specifically covers three categories.

1. Electric vehicle batteries

Electric vehicle batteries are covered by the battery passport requirement.

Under the Batteries Regulation, an electric vehicle battery is broadly a battery specifically designed to provide electric power for traction in hybrid or electric vehicles, including certain road vehicles covered by the Regulation.

Manufacturers and importers of EV battery systems therefore need to prepare for individual battery identification and digital passport management.

2. LMT batteries

LMT means light means of transport.

This category is particularly relevant to the rapidly expanding micromobility sector.

It includes batteries used for the traction of wheeled vehicles that can be powered by an electric motor alone or by a combination of motor and human power, including batteries used in products such as:

• e-bikes;
• electric scooters;
• e-mopeds; and
• similar light electric vehicles.

The battery passport requirement applies to LMT batteries regardless of the 2 kWh threshold that applies to industrial batteries.

3. Industrial batteries above 2 kWh

Industrial batteries with a capacity greater than 2 kWh also require a battery passport.

This category can include, depending on the product and classification:

• stationary energy storage batteries;
• commercial energy storage systems;
• certain backup power systems;
• batteries used in industrial machinery and equipment; and
• other batteries classified as industrial batteries under the Regulation.

Businesses should not determine applicability simply from how a battery is marketed. The definitions in Regulation (EU) 2023/1542 should be used to establish the correct battery category.

Does a normal portable battery need a battery passport?

Not necessarily.

The February 2027 battery passport obligation does not automatically mean that every portable battery, button cell, consumer electronics battery or small rechargeable battery requires a battery passport.

The Article 77 passport requirement specifically applies to:

• EV batteries;
• LMT batteries; and
• industrial batteries above 2 kWh.

Other battery categories remain subject to numerous requirements under the Batteries Regulation, including applicable labelling, conformity, producer responsibility, substance and waste-management requirements, but they are not automatically within the Article 77 battery passport requirement.

This distinction is important for manufacturers of ordinary consumer products containing batteries.

When does the requirement start?

The key date is:

18 February 2027

From that date, each battery falling within the Article 77 scope that is placed on the EU market or put into service must have a battery passport.

Businesses introducing affected batteries into the European Union should therefore not treat February 2027 as the date to start developing their system.

By that point, the required product and supply-chain data should already have been collected and structured, responsibilities allocated, unique identifiers generated, QR codes implemented and the digital infrastructure tested.

The battery passport is more than a QR code

One of the most common misunderstandings about Digital Product Passports is that compliance simply requires placing a QR code on the product.

The QR code is the data carrier that provides access to the battery passport. It is not the passport itself.

Under Article 77(3), the battery passport must be accessible through the QR code required by Article 13(6). The QR code links to a unique identifier attributed to the battery by the economic operator placing it on the market.

The QR code and unique identifier must comply with the relevant ISO/IEC 15459 standards identified by the Regulation, or equivalent standards as permitted under the applicable legal framework.

The underlying passport must then contain the required information and meet the EU's technical requirements concerning interoperability, accessibility, security, data integrity and machine readability.

All batteries will receive QR codes from February 2027

There is an important distinction between the QR code requirement and the battery passport requirement.

Article 13(6) of the Batteries Regulation establishes that, from 18 February 2027, batteries must be marked with a QR code.

For batteries covered by Article 77, including EV batteries, LMT batteries and industrial batteries above 2 kWh, that QR code provides access to the battery passport.

For other batteries, the QR code provides access to other information required by the Batteries Regulation rather than an Article 77 battery passport.

Businesses should therefore avoid interpreting "battery does not require a battery passport" as "battery does not require a QR code."

These are separate questions.

Where must the QR code appear?

The Batteries Regulation requires the applicable labels and QR code to be printed or engraved on the battery in a manner that is:

• visible;
• legible; and
• indelible.

Where this is not possible or is not warranted because of the nature or size of the battery, the Regulation allows the labels and QR code to be placed on the packaging and accompanying documents.

Manufacturers should therefore consider the physical marking requirement during label and product design rather than adding it only after production artwork has been finalised.

Who is responsible for the battery passport?

The legal responsibility does not simply sit with the company providing the software platform.

Article 77 places responsibility on the economic operator placing the battery on the market.

That economic operator must ensure that the information contained in the battery passport is:

• accurate;
• complete; and
• up to date.

The Regulation allows the responsible economic operator to give written authorisation to another operator to act on its behalf.

This makes it possible to use specialised battery passport or Digital Product Passport service providers.

However, outsourcing the technical platform should not be confused with transferring the underlying regulatory responsibility.

The responsible business therefore needs appropriate controls over the information provided by manufacturers, suppliers, laboratories and other parties in the battery supply chain.

What information must the battery passport contain?

The detailed requirements are primarily established in Annex XIII of Regulation (EU) 2023/1542.

The European Commission's August 2026 guidance brings together 71 data points relevant to the battery passport and explains their applicability across EV, LMT and industrial battery categories.

Not every data point necessarily applies identically to every battery.

The Commission guidance identifies whether individual data points are mandatory, optional, conditionally applicable or not required to be completed or displayed as of February 2027 for the relevant battery category.

For compliance planning, the required information can broadly be divided into several groups.

Public battery model information

Annex XIII requires a substantial amount of battery model information to be publicly accessible.

This includes, where applicable, information concerning:

Battery identification

The passport can contain fundamental identification information such as:

• manufacturer identification;
• battery category;
• battery model;
• place of manufacture;
• manufacturing date;
• battery weight; and
• relevant identification information required under the Batteries Regulation.

The exact applicable fields should be determined against Annex XIII, Annex VI and the current Commission data-point guidance.

Battery chemistry and material composition

The passport must provide relevant information about the battery's material composition.

Annex XIII includes information concerning:

• battery chemistry;
• hazardous substances present in the battery;
• critical raw materials present in the battery; and
• other applicable material composition information.

For manufacturers, this means that battery passport preparation can extend well beyond information normally contained on a product specification sheet.

Supplier and material data may need to be collected from further upstream in the supply chain. Where chemical composition and restricted substances are relevant, manufacturers should also review the available chemical testing documentation for EU compliance and applicable Safety Data Sheets (SDS).

Carbon footprint information

Where the corresponding requirements of Article 7 apply, the battery passport incorporates relevant carbon footprint information.

The Batteries Regulation progressively introduces carbon footprint requirements for EV batteries, rechargeable industrial batteries above 2 kWh and LMT batteries.

Depending on the battery category and applicable date, these requirements can include:

• carbon footprint declarations;
• lifecycle carbon footprint values;
• carbon footprint performance classes; and
• eventually maximum lifecycle carbon footprint thresholds.

Businesses should therefore consider the battery passport together with the wider sustainability obligations of the Batteries Regulation rather than treating it as an isolated IT requirement.

Responsible sourcing information

Where applicable, information concerning responsible sourcing and battery due diligence can also form part of the passport information.

The Batteries Regulation establishes supply-chain due diligence obligations concerning certain battery raw materials.

Battery passport compliance can therefore depend on information originating considerably further upstream than the final battery assembly facility.

Recycled content

Relevant recycled content information required under the Batteries Regulation may also need to be made available.

This is particularly significant because the Regulation progressively establishes recycled-content documentation and minimum recycled-content requirements for certain batteries containing cobalt, lead, lithium and nickel.

Performance and durability

Annex XIII includes numerous technical characteristics relating to battery performance and durability.

Depending on applicability, these can include:

• rated capacity;
• minimum, nominal and maximum voltage;
• original power capability;
• expected battery lifetime expressed in cycles;
• capacity threshold for exhaustion for EV batteries;
• relevant temperature ranges;
• commercial warranty information;
• round-trip energy efficiency;
• internal battery cell and pack resistance; and
• the C-rate used for relevant cycle-life testing.

These data requirements demonstrate why battery passport preparation should involve technical and engineering teams rather than being treated only as a labelling project.

EU Declaration of Conformity

Annex XIII also connects the battery passport with the battery's regulatory conformity documentation.

Publicly accessible passport information includes the EU Declaration of Conformity referred to in Article 18.

This makes the passport part of the wider conformity architecture established by the Batteries Regulation.

Manufacturers should therefore ensure that the battery passport, EU Declaration of Conformity, technical documentation, product identification and physical markings all refer consistently to the correct battery model.

Waste and end-of-life information

Battery passports also support the EU's circular-economy objectives.

Relevant information concerning prevention and management of waste batteries must be available as required by the Regulation.

This can support:

• collection;
• safe handling;
• preparation for reuse;
• repurposing;
• remanufacturing; and
• recycling.

The passport is therefore intended to remain relevant well beyond the initial sale of the battery.

Not all battery passport information is public

One of the most important aspects of the EU system is its tiered access model.

The battery passport does not mean that every piece of technical information about a battery becomes publicly accessible.

Annex XIII separates information according to who is permitted to access it.

Broadly, there are several access levels.

Public information

Certain battery model information is available to the general public.

This includes much of the identification, sustainability, conformity and performance information described above.

Information for persons with a legitimate interest

More commercially or technically sensitive information can be restricted to persons with a legitimate interest.

This can include detailed information concerning:

• battery composition;
• cathode, anode and electrolyte materials;
• replacement components;
• sources for replacement spare parts;
• dismantling instructions;
• exploded diagrams;
• disassembly sequences;
• fastening techniques;
• required disassembly tools; and
• safety measures.

This information is particularly relevant to repairers, remanufacturers, second-life operators and recyclers.

Information for authorities and notified bodies

Certain information is restricted further.

Annex XIII provides for access by notified bodies, market surveillance authorities and the European Commission to information such as relevant test reports demonstrating compliance with the Batteries Regulation and its delegated or implementing acts.

Individual battery information

Certain information relates not merely to the battery model but to the individual battery during its operating life.

Depending on the applicable requirements and access rights, this can include:

• performance and durability information;
• state of health;
• battery status;
• charging and discharging cycles;
• negative events such as accidents;
• operating environmental conditions;
• temperature information; and
• state-of-charge information.

This is one of the major differences between a traditional static compliance document and a battery passport.

The passport can become a living digital record associated with an individual physical battery.

Battery state of health

For relevant batteries, state-of-health information is particularly important.

The Batteries Regulation requires certain battery management systems to contain up-to-date data concerning parameters used to determine the battery's state of health and expected lifetime.

These data can become important when assessing whether a battery should continue in its original application or move into reuse, repurposing, remanufacturing or recycling.

The battery passport therefore supports the development of second-life battery markets by improving access to reliable information about remaining battery performance.

What happens when a battery is repurposed or remanufactured?

The passport is intended to follow the battery through its lifecycle.

Where a battery undergoes:

• preparation for reuse;
• preparation for repurposing;
• repurposing; or
• remanufacturing,

the responsibility for maintaining the applicable passport obligations transfers to the economic operator placing that battery on the market or putting it into service after the relevant operation.

A new battery passport must then be created and linked to the passport or passports of the original battery or batteries.

This creates digital traceability between the original product and its subsequent lifecycle.

Where the battery becomes waste, responsibility changes again in accordance with Article 77.

The battery passport ultimately ceases to exist after the battery has been recycled.

Technical requirements for the battery passport

Article 78 establishes essential technical requirements for the system.

The battery passport must not simply be a normal webpage containing product information.

Among other requirements, the system must support:

• interoperability with other EU Digital Product Passports;
• appropriate access rights;
• open standards;
• machine-readable information;
• structured and searchable data;
• reliable data authentication;
• data integrity;
• security;
• privacy; and
• protection against fraud.

Article 77 additionally requires information to be in an interoperable format and transferable through an open interoperable data exchange network without vendor lock-in.

This requirement is particularly important when selecting a battery passport service provider.

Manufacturers should consider whether their data can be transferred if they later change providers.

Can a third-party platform host the battery passport?

Yes.

The Regulation expressly anticipates that operators authorised by the responsible economic operator may store or process battery passport information on its behalf.

This creates a role for specialised Digital Product Passport platforms and service providers.

However, Article 78 places restrictions on these service providers.

Where passport data is stored or processed by an authorised operator, that operator cannot sell, reuse or otherwise process the data beyond what is necessary to provide the relevant storage or processing service.

Businesses evaluating a battery passport provider should therefore assess not only the user interface and cost but also:

• EU regulatory compatibility;
• interoperability;
• data portability;
• access controls;
• data ownership;
• security;
• API capabilities;
• availability guarantees;
• long-term data retention;
• contingency arrangements; and
• restrictions on secondary use of data.

A low-cost QR-code hosting service is not automatically a compliant battery passport solution.

What happens if the manufacturer or economic operator ceases trading?

The EU Regulation specifically addresses continuity.

Article 78 requires the battery passport to remain available even after the economic operator responsible for the passport:

• ceases to exist; or
• ceases its activities in the European Union.

This requirement has practical consequences for platform selection and contractual arrangements.

Businesses should establish how passport data will remain accessible if either the economic operator or its service provider disappears, becomes insolvent or terminates the service.

Long-term availability is particularly important because industrial and EV batteries can remain in use for many years.

The EU Digital Product Passport Registry

The battery passport is part of the European Union's broader Digital Product Passport infrastructure.

The European Commission launched the Digital Product Passport Registry on 20 July 2026, together with a testing environment.

The Registry provides infrastructure for registering Digital Product Passports, unique identifiers and associated metadata.

The European Commission describes the broader DPP process as involving several stages:

1. the economic operator collects the information required by the applicable EU legislation;
2. the Digital Product Passport is created and registered;
3. the Registry generates the relevant registration identifier;
4. the physical product is connected to the digital record through a data carrier such as a QR code; and
5. users access information according to their permitted access rights.

For battery passports, the Batteries Regulation now also requires the economic operator placing the battery on the market or putting it into service to upload the unique identifier to the relevant EU registry.

The Registry therefore creates an EU-level registration layer while the detailed product data itself remains decentralised.

Why the EU introduced the battery passport

The battery passport is not simply a product-information requirement.

It forms part of a much broader EU policy covering the entire battery lifecycle.

Regulation (EU) 2023/1542 introduces requirements addressing areas including:

• restricted substances;
• carbon footprint;
• recycled content;
• performance and durability;
• removability and replaceability;
• conformity assessment;
• CE marking;
• labelling;
• supply-chain due diligence;
• producer responsibility;
• collection;
• recycling;
• material recovery; and
• end-of-life management.

The passport provides a digital mechanism through which many of these data points can remain connected to the battery.

For regulators, it can improve market surveillance.

For consumers and professional purchasers, it can improve transparency.

For repairers and second-life operators, it can provide technical information necessary to evaluate and work with used batteries.

For recyclers, it can provide information about composition, dismantling and materials.

Battery passport and CE marking are separate requirements

A battery passport should not be confused with CE marking.

Under the Batteries Regulation, batteries subject to the Regulation must undergo the applicable conformity assessment and meet the relevant regulatory requirements before being placed on the EU market.

The battery passport is an additional information and traceability requirement for the battery categories covered by Article 77.

A battery can therefore require:

• conformity assessment;
• technical documentation;
• an EU Declaration of Conformity;
• CE marking;
• regulatory labels;
• a QR code;
• and, where Article 77 applies, a battery passport.

Businesses should manage these requirements as one integrated compliance process.

Battery passport and EU Responsible Person or Authorised Representative requirements

Non-EU manufacturers should also consider who is acting as their EU economic operator.

The battery passport does not replace existing requirements concerning manufacturers, importers, authorised representatives or other economic operators.

For companies manufacturing batteries outside the European Union, the supply-chain structure should be reviewed carefully to establish:

• who is the manufacturer under EU law;
• who imports the battery into the European Union;
• whether an authorised representative has been appointed;
• which economic operator is responsible for the applicable regulatory obligations; and
• which entity is placing the finished battery on the market and responsible for the battery passport.

This should be resolved before the passport is created because economic-operator identification forms part of the wider regulatory documentation.

For a broader overview of EU market-access obligations, see EaseCert's EU compliance guide for selling consumer products.

Battery passport and Extended Producer Responsibility

The battery passport should also not be confused with Extended Producer Responsibility (EPR).

Battery EPR obligations operate separately.

Businesses selling batteries in EU Member States may have producer-registration, reporting, collection and financing obligations under the Batteries Regulation.

Depending on the sales structure, registration can be required in individual Member States where batteries are made available on the market.

A battery passport does not replace those registrations.

For non-EU sellers, authorised representation for EPR can also be required in relevant circumstances.

Companies entering the European market should therefore assess battery passport compliance and battery EPR compliance separately. Similar producer-responsibility principles also apply to other waste streams, as explained in EaseCert's EU Packaging EPR Compliance in 2026 guide.

What manufacturers should do now

For businesses that will place covered batteries on the EU market after 18 February 2027, preparation should already be underway.

A practical compliance programme should include the following steps.

1. Classify the battery

Determine whether the product is:

• an EV battery;
• an LMT battery;
• an industrial battery;
• a portable battery;
• an SLI battery; or
• another battery category under Regulation (EU) 2023/1542.

For industrial batteries, determine whether capacity exceeds 2 kWh.

2. Identify the responsible economic operator

Document which legal entity is placing the battery on the EU market or putting it into service and which entity will assume responsibility for the passport.

For non-EU manufacturers, review the importer and authorised-representative structure.

3. Perform a battery passport data-gap assessment

Compare the information currently available against:

• Article 77;
• Article 78;
• Annex XIII;
• applicable Annex VI information;
• related provisions of the Batteries Regulation; and
• the European Commission's current Digital Batteries Passport data-point guidance.

The Commission's August 2026 guidance consolidates 71 relevant data points, making it a useful starting point for this exercise.

4. Map every data point to a source

Identify where each required item originates.

Possible sources include:

• battery manufacturer;
• cell manufacturer;
• component suppliers;
• bill of materials;
• laboratory reports;
• lifecycle assessments;
• battery management system;
• ERP systems;
• product lifecycle management systems;
• manufacturing records;
• quality-management systems; and
• supply-chain due diligence records.

5. Identify missing supplier information

This step should be completed early.

Information such as detailed battery composition, critical raw materials, recycled content and certain sustainability data may not currently be available in a manufacturer's normal product documentation.

Supplier agreements and data-request procedures may therefore need to be updated.

6. Review technical documentation

Ensure that the battery's technical documentation supports the information being placed into the passport.

Passport information should not conflict with:

• test reports;
• product specifications;
• technical files;
• the EU Declaration of Conformity;
• labels;
• manuals; or
• other regulatory documentation.

7. Select a suitable DPP platform

Evaluate whether the proposed system supports the technical requirements of Articles 77 and 78 and the applicable EU Digital Product Passport architecture.

Avoid evaluating providers solely on the ability to create a QR code.

8. Establish unique identification

Determine how unique battery identifiers will be generated and linked to individual physical batteries.

The system must support the applicable identification standards and EU registration requirements.

9. Integrate the QR code into the product

Plan sufficient physical space and appropriate marking technology so that the QR code remains visible, legible and indelible during the relevant product lifecycle.

10. Define access rights

Separate information into the appropriate access categories:

• public;
• legitimate-interest access;
• authority/notified-body access; and
• individual battery information.

Commercially sensitive information should not simply be published publicly.

11. Establish update procedures

Identify which information remains static and which information must change throughout the battery's life.

For relevant batteries, this can include operating information, state of health and lifecycle status.

12. Test before February 2027

Validate:

• QR-code scanning;
• identifier resolution;
• data accuracy;
• access permissions;
• EU Registry interaction;
• data portability;
• API connections;
• security;
• long-term availability; and
• consistency with the physical battery and technical documentation.

For companies preparing a wider EU product launch, EaseCert's checklist for launching a new product in the EU provides an additional market-access overview.

A practical example

Consider a manufacturer in China producing a 5 kWh lithium-ion battery for residential energy storage and selling it into Germany through an EU importer.

Because the battery is an industrial battery above 2 kWh, it falls within the Article 77 battery passport scope.

Before placing batteries on the EU market after 18 February 2027, the responsible economic operator would need to ensure that the applicable battery passport has been created.

The compliance process could involve:

1. confirming classification as an industrial battery;
2. completing the applicable EU Batteries Regulation conformity assessment;
3. preparing technical documentation;
4. preparing the EU Declaration of Conformity;
5. applying the required CE marking and battery labelling;
6. identifying the EU economic operator;
7. collecting applicable Annex XIII data;
8. creating the battery's unique identifier;
9. creating and registering the digital passport;
10. connecting the physical battery to the passport through its QR code;
11. implementing appropriate access controls; and
12. maintaining the passport information after the battery enters service.

Separately, the producer would need to address the applicable battery EPR obligations in the Member States where the battery is made available.

The passport is therefore one part of a broader EU market-access system.

The biggest challenge may be data, not software

The technical creation of a QR code is relatively straightforward.

Obtaining reliable regulatory data can be considerably more difficult.

Many manufacturers currently receive batteries or cells from suppliers with little more than:

• specification sheets;
• SDS documents;
• UN 38.3 reports;
• IEC test reports; and
• basic declarations.

That may not provide all information required for a compliant battery passport.

Manufacturers should therefore begin discussing the requirements with their battery and cell suppliers now.

Waiting until January or February 2027 could leave insufficient time to obtain missing composition, sustainability, performance or supply-chain information.

Do existing batteries need to be retrospectively given passports?

Article 77 frames the requirement around batteries placed on the market or put into service from 18 February 2027.

The relevant compliance assessment should therefore focus on when the individual battery is placed on the market or put into service under the definitions and rules of the Batteries Regulation.

Companies holding inventory around the transition date should carefully document when products were placed on the EU market rather than assuming that manufacturing date alone determines applicability.

Where there is uncertainty around transitional stock, the placing-on-the-market analysis should be documented before the February 2027 deadline.

The battery passport is the beginning of a much larger EU DPP system

Batteries are the first major product group for which the EU Digital Product Passport becomes mandatory.

They will not be the last.

The EU is progressively developing Digital Product Passport requirements for additional product sectors through the Ecodesign for Sustainable Products Regulation and other sector-specific legislation.

The broader system is expected to cover or interact with product groups and legislation concerning areas such as:

• iron and steel;
• textiles;
• tyres;
• aluminium;
• furniture;
• ICT products;
• construction products;
• toys;
• detergents; and
• other regulated products.

For manufacturers selling multiple product categories into Europe, the battery passport should therefore be viewed as part of a broader shift toward structured digital compliance information and product-level traceability.

How EaseCert can support battery compliance

EaseCert supports manufacturers, importers and online sellers with European product compliance and market-access requirements.

For businesses affected by the EU Batteries Regulation, the compliance process should begin with determining the applicable legal obligations rather than simply purchasing a QR-code or Digital Product Passport service.

Depending on the product and supply chain, the compliance review may include:

• battery classification;
• EU Batteries Regulation applicability assessment;
• economic-operator assessment;
• technical documentation review;
• EU Declaration of Conformity;
• labelling and QR-code review;
• CE-marking requirements;
• battery passport data-gap analysis;
• review of available test reports and supplier documentation;
• coordination of missing compliance information;
• EU authorised representation where applicable;
• battery EPR considerations; and
• coordination with an appropriate Digital Product Passport platform.

Where a third-party technical platform is used to create and host the battery passport, the regulatory documentation and digital passport should be aligned so that the same battery model, manufacturer, economic operator and technical information are used throughout the compliance system.

Businesses that need broader support with EU product compliance can also review EaseCert's GPSR compliance and EU market access services.

Conclusion

18 February 2027 is an important compliance deadline for the European battery industry.

From that date, EV batteries, LMT batteries and industrial batteries with a capacity greater than 2 kWh placed on the EU market or put into service must have a battery passport.

The requirement is much broader than adding a QR code.

A compliant system requires manufacturers and economic operators to establish a structured digital record containing regulatory, technical, sustainability and lifecycle information, manage different access levels, maintain accurate data, provide individual battery identification and connect the physical battery to its digital record.

The European Commission's Digital Product Passport infrastructure is now moving from legislation into practical implementation. The EU DPP Registry became operational in July 2026, and the Commission has now published detailed guidance consolidating the battery passport data requirements.

Companies expecting to sell affected batteries in Europe after February 2027 should therefore use the remaining implementation period to classify their batteries, identify missing data, engage suppliers, review technical documentation and establish their Digital Product Passport infrastructure.

Starting with the data is generally the most effective approach.

A passport platform can host and structure information, but it cannot create regulatory evidence that the manufacturer has never collected.

Official EU References

The following official European Union sources should be used as the primary references when preparing for battery passport compliance.

Regulation (EU) 2023/1542 concerning batteries and waste batteries

EUR-Lex: Regulation (EU) 2023/1542. In particular, see Article 13 (labelling and QR code), Articles 17-20 (conformity assessment and EU Declaration of Conformity), Articles 77-78 (battery passport) and Annex XIII (information contained in the battery passport).

European Commission: Digital Product Passport for Batteries

European Commission: Digital Product Passport for Batteries (Battery Passport). European Commission information specifically addressing implementation of Digital Product Passports for batteries, including affected battery categories, implementation dates and current guidance.

European Commission: Digital Batteries Passport, Data Points by Category

European Commission: Digital Batteries Passport guidance and data points by category. Updated Commission guidance published in August 2026 consolidating 71 data points and their applicability to EV, LMT and industrial battery categories. The Commission notes that this guidance should be read together with Regulation (EU) 2023/1542 and relevant delegated and implementing acts.

European Commission: Digital Product Passport

European Commission: Digital Product Passport. The Commission's central Digital Product Passport portal covering the DPP architecture, Registry, implementation timeline, technical documentation and sector-specific requirements.

European Commission: Digital Product Passport Registry

European Commission: Digital Product Passport resources and Registry. The EU DPP Registry became operational on 20 July 2026. The Commission provides information concerning registration, unique identifiers, APIs, access management and the Registry's role within the decentralised DPP architecture.

European Commission: Batteries and Waste Batteries

European Commission: Batteries. The European Commission's environmental policy and legislation portal for Regulation (EU) 2023/1542 and related implementing and delegated legislation.

Because delegated acts, implementing acts, technical guidance and DPP standards continue to develop, businesses preparing for February 2027 should verify the latest European Commission material before final implementation.