# The EU battery passport: a guide to obligations, content and deadlines > What the EU battery passport is, which batteries need one from 2027, who is responsible, what goes in it and what is still open. What the EU battery passport is, which batteries need one from 2027, who is responsible, what goes in it and what is still open. By [BatteryPass-Redaktion](https://kabin.sh/en/about#batterypass-team)Published: 25 October 2026Updated: 25 October 2026Facts checked: 25 October 202633 min read ## In short The battery passport is an electronic record for each battery. From 18 February 2027, every LMT battery, every electric vehicle battery and every industrial battery above 2 kWh placed on the EU market or put into service needs one. A QR code leads to public and restricted data. The economic operator placing it on the market is responsible. ## Key facts - Start of the passport obligation 18 February 2027, for batteries placed on the market or put into service from that day [Source](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_77) - Batteries covered LMT batteries, electric vehicle batteries and industrial batteries with a capacity greater than 2 kWh [Source](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_77) - Granularity One passport per individual battery, not per model [Source](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_77) - Responsibility The economic operator placing the battery on the market; a written authorisation does not change that [Source](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_77) - Access tiers Public; persons with a legitimate interest; notified bodies, market surveillance authorities and the Commission [Source](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#anx_XIII) - Data carrier QR code on the battery, linked to a unique identifier under ISO/IEC 15459 [Source](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_13) - Fine in Germany Up to EUR 10,000 if the passport information is not accurate, complete or up to date [Source](https://www.gesetze-im-internet.de/battdg/__60.html) The battery passport is an electronic record for an individual battery. From 18 February 2027, every LMT battery, every electric vehicle battery and every industrial battery with a capacity greater than 2 kWh that is placed on the EU market or put into service must have one (Article 77(1) of Regulation (EU) 2023/1542). A QR code on the battery leads to data on the battery model and on the individual battery, split into a public part and several restricted parts. The economic operator that places the battery on the market is responsible for keeping that information accurate, complete and up to date. This guide sets out what the Battery Regulation requires, how the Commission reads it and which acts are still missing. We checked every statement against the primary sources on 25 October 2026. The [glossary](https://kabin.sh/en/battery-passport/glossary) explains the terms; short answers are in the [battery passport FAQ](https://kabin.sh/en/battery-passport/faq). ## What is the battery passport, and which batteries need one? The Regulation calls the [battery passport](https://kabin.sh/en/battery-passport/glossary#battery-passport) an “electronic record”. It holds information on the battery model and information specific to the individual battery, “including resulting from the use of that battery” (Art. 77(2)). Part of it is public; the rest is open only to authorities or to persons with a legitimate interest. The data must be based on open standards, machine-readable, structured and searchable, and transferable through an open, interoperable data exchange network “without vendor lock-in” (Art. 77(5)). The passport is therefore not a PDF data sheet but a structured data set that stays with the battery for its whole life. ### Which battery categories are covered The Battery Regulation applies to five categories (Art. 1(3)). Three of them need a passport. Whether a battery belongs to one of those follows from the definitions in Article 3(1): | Category | Definition (Art. 3(1)) | Battery passport | | -------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------------------ | | LMT battery (light means of transport) | Sealed, 25 kg or less, specifically designed for the traction of wheeled vehicles powered by an electric motor alone or by motor and human power, including type-approved category L vehicles; not an electric vehicle battery (point 11) | Yes, every one | | Electric vehicle battery | Specifically designed for the traction of category L hybrid or electric vehicles and weighing more than 25 kg, or for the traction of vehicles of categories M, N or O (point 14) | Yes, every one | | Industrial battery | Specifically designed for industrial uses, intended for industrial uses after having been subject to preparation for repurposing or repurposing, or any other battery weighing more than 5 kg that is not an LMT, electric vehicle or SLI battery (point 13); stationary battery energy storage systems are included (point 15) | Yes, if the capacity is greater than 2 kWh | | SLI battery | Specifically designed for starting, lighting or ignition (point 12) | No, but a QR code | | Portable battery | Sealed, 5 kg or less, not designed specifically for industrial use, none of the other categories (point 9) | No, but a QR code | Battery categories under Art. 3(1) and the passport obligation under Art. 77(1) Two points deserve attention. First, every home storage battery is an [industrial battery](https://kabin.sh/en/battery-passport/glossary#industrial-battery): the Regulation defines a [stationary battery energy storage system](https://kabin.sh/en/battery-passport/glossary#stationary-battery-energy-storage-system) as an industrial battery with internal storage, “regardless of where and by whom the battery is being used” (Art. 3(1), point 15). Second, any battery above 5 kg that falls into no other category is an industrial battery, even if it is not meant for industry. Cells or modules made available for end use without further assembly count as batteries of the most similar category in their own right (Art. 1(4)). ### The threshold: greater than 2 kWh For industrial batteries, capacity decides. Article 77(1) speaks of a capacity “greater than 2 kWh”. An industrial battery of exactly 2 kWh therefore needs no passport, but from the same date it does need a QR code leading to the label information, the declaration of conformity, the due diligence report and the information on waste batteries (Art. 13(6), point (b)). There is no capacity threshold for LMT and electric vehicle batteries. Whether several small units together exceed the threshold depends on what the finished battery is. The Commission's answer: if each unit is a complete, independently functioning battery below 2 kWh, each is assessed on its own; if the units form one integrated system with common components, the whole system is the battery and the combined capacity counts (FAQ 3.3). The article [Industrial batteries over 2 kWh](https://kabin.sh/en/blog/industrial-batteries-over-2-kwh-battery-passport) works through examples from industry and commerce. ### From when does the obligation apply? From 18 February 2027. The obligation is tied to [placing on the market](https://kabin.sh/en/battery-passport/glossary#placing-on-the-market), the first making available on the Union market (Art. 3(1), point 16), or to putting into service, the first use in the Union without prior placing on the market (point 18). It is not retroactive: batteries placed on the market before the start date need no passport under Article 77(1). The exception follows from Article 77(7). If such a battery is repurposed or remanufactured after the start date and placed on the market again, it needs a passport; the Commission confirms this for remanufacturing (FAQ 9.4). The QR code obligation for all batteries, portable and SLI batteries included, starts on the same day (Art. 13(6)). ### One passport per battery, not per model Article 77(1) requires a passport for “each” battery. Placing 500 home storage units of one model on the market means 500 passports. The model data is the same for all of them: a [battery model](https://kabin.sh/en/battery-passport/glossary#battery-model) is a version whose units share the same relevant technical characteristics and the same model identifier (Art. 3(1), point 19). Each unit adds its unique identifier, details such as the date of manufacture, and the data from its use. ### What counts as the “finished battery”? The Regulation defines a battery broadly: one or more cells, modules or packs of them (Art. 3(1), point 1). A [battery module](https://kabin.sh/en/battery-passport/glossary#battery-module) is a set of connected cells meant to be used alone or with other modules (point 3); a [battery pack](https://kabin.sh/en/battery-passport/glossary#battery-pack) is a complete unit not meant to be split up or opened by the end-user (point 2). Article 77 does not say expressly which level gets the passport. The Commission's FAQ on the battery passport answers as follows: - The passport applies to the finished battery, a finished and (safely) working product that can deliver electrical energy. For a traction battery this normally includes the battery management system (FAQ 3.1). - If several packs share a common BMS or other common components and together form one working battery, the whole system is the battery and has one passport. If the packs are complete, independently functioning batteries, each needs its own. The Commission stresses that this is assessed case by case (FAQ 3.2). - Imported cells or modules that are only assembled into a finished battery in the EU are not the finished battery and need no passport on import; whoever completes the battery in the EU becomes its manufacturer. Kits that end-users assemble with commonly available tools are the exception (FAQ 3.4 and 4.3). - Where a battery is built into a machine, a vehicle or a building, the passport attaches to the battery, not to the larger product (FAQ 3.5). The FAQ is not legally binding, but it shows how the Commission applies the Regulation. Record your classification for each product in writing. How this carries over to modules, racks and containers is shown in [Module, pack or container](https://kabin.sh/en/blog/module-pack-or-container-battery-passport). ## Which deadlines apply around the battery passport? The passport is not the Battery Regulation's first obligation, and not all of its content applies from day one. The key dates: 1. 18 August 2024 Performance and durability documentation applies Rechargeable industrial batteries above 2 kWh, LMT batteries and EV batteries are accompanied by a document with the values of the parameters in Annex IV Part A. ([Art. 10(1)](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_10)) 2. 18 August 2024 Data in the battery management system applies The BMS of stationary battery energy storage systems, LMT batteries and EV batteries holds up-to-date data on state of health and expected lifetime as set out in Annex VII. The legal purchaser gets read-only access. ([Art. 14(1), (2)](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_14)) 3. 18 August 2026 Deadline: access rights for a legitimate interest delayed By this date the Commission was to specify who counts as a person with a legitimate interest and to what extent they may download, share, publish and re-use which parts of the passport. When we checked, a draft was open for feedback from 19 October to 16 November 2026; the act had not been adopted. ([Art. 77(9)](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_77)) 4. 18 August 2026 Label under Annex VI Part A pending act Batteries bear a label with the general information in Annex VI Part A and, depending on the type, capacity information, from this date or 18 months after the implementing act under Article 13(10) enters into force, whichever is later. When we checked, the act was missing, so the label obligation does not apply yet. ([Art. 13(1), (2), (3)](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_13)) 5. 18 February 2027 Battery passport and QR code applies Every LMT battery, every industrial battery above 2 kWh and every EV battery placed on the market or put into service needs a battery passport. All batteries bear a QR code; the removability and replaceability rules of Article 11 start on the same day. ([Art. 77(1), Art. 13(6)](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_77)) 6. 18 August 2027 Supply chain due diligence applies Economic operators placing batteries on the market meet the due diligence obligations for cobalt, natural graphite, lithium and nickel and have them verified by a notified body. Companies below EUR 40 million net turnover are exempt unless they belong to a group above that threshold. ([Art. 47, Art. 48(1)](https://eur-lex.europa.eu/eli/reg/2025/1561/oj/eng)) 7. 18 August 2027 Minimum values for rechargeable industrial batteries pending act Rechargeable industrial batteries above 2 kWh, except those with exclusively external storage, must meet the minimum performance and durability values from this date or 18 months after the delegated act enters into force, whichever is later. When we checked, the act was still a draft. ([Art. 10(2)](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_10)) 8. 18 August 2028 Recycled content documentation pending act Industrial batteries above 2 kWh (except exclusively external storage), EV batteries and SLI batteries with cobalt, lead, lithium or nickel in active materials are accompanied by recycled content documentation, from this date or 24 months after the delegated act enters into force, whichever is later. When we checked, the act was missing. ([Art. 8(1)](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_8)) 9. 18 August 2031 First minimum recycled content applies Industrial batteries above 2 kWh (except exclusively external storage), EV batteries and SLI batteries contain, per model, year and plant, at least 16 % recovered cobalt, 6 % lithium and 6 % nickel in active materials and 85 % lead, shown in the technical documentation. ([Art. 8(2)](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_8)) Two obligations already apply and later feed data into the passport. Rechargeable industrial batteries above 2 kWh, LMT and electric vehicle batteries come with a document stating the performance and durability values of Annex IV, Part A (Art. 10(1)), and the BMS of stationary storage systems, LMT and electric vehicle batteries holds the Annex VII data, such as remaining capacity, energy throughput and deep discharges (Art. 14(1)). Other dates depend on Commission acts and apply from the date shown or a set period after the act, whichever is later. The [battery passport timeline](https://kabin.sh/en/battery-passport/timeline) lists every date with its source and status. ## Who is responsible for the battery passport? The [economic operator](https://kabin.sh/en/battery-passport/glossary#economic-operator) that places the battery on the market. It ensures that the information in the passport is “accurate, complete and up to date” (Art. 77(4)). It also assigns the battery its unique identifier (Art. 77(3)) and uploads that identifier to the EU registry (Art. 77(10)). Who that is in a given case follows from the roles in Articles 38 to 44: | Role | Who it is | Link to the battery passport | | --------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------ | ------------------------------------------------------------------------------------------------------------------------------------------------------------------ | | Manufacturer (Art. 3(1), point 33; Art. 38) | Manufactures a battery or has it designed or manufactured, and markets it under its own name or trademark or puts it into service for its own purposes | Responsible when it places the battery on the EU market; labels it under Art. 13, which from the start date includes the QR code | | Importer (point 64; Art. 41) | Established in the EU, places a battery from a third country on the market | Responsible for imported batteries; first checks, among other things, the declaration of conformity, technical documentation, CE marking and Art. 13 labelling | | Authorised representative (point 63; Art. 40) | Established in the EU, holds a written mandate from the manufacturer | Carries out the tasks in the mandate; the obligations of Art. 38(1), due diligence (Art. 48 to 52) and drawing up the technical documentation cannot be part of it | | Distributor (point 65; Art. 42) | Makes a battery available on the market without being its manufacturer or importer | Checks CE marking and Art. 13 labelling; can become the manufacturer under Art. 44 | Roles under the Battery Regulation and how they relate to the battery passport Where the manufacturer is outside the EU, the importer usually places the battery on the market and so carries the Article 77(4) obligation; it also puts its own name and address on the battery (Art. 41(3)). An importer or distributor that markets a battery under its own name or trademark, modifies it so that compliance may be affected, or changes its intended purpose is treated as the manufacturer (Art. 44). More on the [importers](https://kabin.sh/en/solutions/importers) page. Manufacturer and producer are different roles In the Regulation, the “manufacturer” makes or markets the battery under its own name (Art. 3(1), point 33). The “producer” (point 47) is the extended producer responsibility role, which takes over responsibility for the passport once the battery becomes waste. The German text adds a twist: it calls the manufacturer “Erzeuger”, the producer “Hersteller” and the importer “Einführer”. ### Written authorisation does not shift responsibility Article 77(4) lets the operator authorise others in writing to act on its behalf, for example a service provider, a manufacturer outside the EU or a cell supplier. The Commission is clear: written authorisation does not transfer the ultimate legal responsibility, which stays with the economic operator placing the battery on the market (FAQ 2.1). A non-EU manufacturer maintaining the passport under such a mandate does not become the EU manufacturer or the importer (FAQ 2.4). According to the FAQ, registration in the EU registry is done by the economic operator that places the battery on the EU market (FAQ 2.2). Anyone storing or processing passport data on the operator's behalf may not sell it, re-use it or process it beyond the service (Art. 78(d)). There is no approval scheme or public register of battery passport software. The Regulation does not regulate such providers; whether to use one is the operator's decision alone, and the relationship is governed by contract (FAQ 10.3). ### Whoever completes the battery is responsible For assembled systems, what matters is who makes the finished battery. If an EU manufacturer supplies a finished battery to a vehicle manufacturer that merely installs it, the battery manufacturer remains responsible; if the vehicle manufacturer adds essential parts such as the BMS, it becomes responsible (FAQ 2.3). If imported packs are combined with a BMS in the EU, the company that completes the finished, safely functioning battery and places it on the market is responsible (FAQ 2.5). If a product is imported with a finished battery installed, the battery is normally placed on the market on import, and responsibility lies with the importer (FAQ 3.5). Suppliers of cells and modules have an obligation of their own: they give the manufacturer, free of charge, the information and documentation it needs to comply with the Regulation (Art. 39). The article [Supplier data for the battery passport](https://kabin.sh/en/blog/supplier-data-battery-passport-without-supplier-accounts) describes how to collect it without giving suppliers accounts. ## What happens on repurposing, remanufacturing and recycling? The battery gets a new passport, and responsibility moves. Under Article 77(7), for batteries that have been prepared for re-use or repurposing, repurposed or remanufactured, responsibility under paragraph 4 passes to the economic operator that places the battery on the market or puts it into service again. The battery gets “a new battery passport linked to the battery passport or passports of the original battery or batteries”. Operators that carry out these operations and then place the battery on the market or put it into service are considered manufacturers (Art. 38(11)). | Event | What happens to the passport | Who is responsible | | -------------------------------------------------- | ---------------------------------------------------------------- | ------------------------------------------------------------------------------------------------- | | Simple repair | No new passport (FAQ 9.2) | The existing economic operator | | Preparation for re-use or repurposing, repurposing | New passport linked to the previous one; new labels (Art. 13(9)) | Whoever places the battery on the market or puts it into service again (Art. 77(7)) | | Remanufacturing | New passport linked to the previous one | Whoever places the battery on the market or puts it into service again | | Battery becomes waste | Status “waste”; the passport remains | Producer, producer responsibility organisation or selected waste management operator (Art. 77(7)) | | Waste battery prepared for re-use or repurposing | New passport (FAQ 9.1) | Whoever places it on the market again | | Recycling | The passport ceases to exist (Art. 77(8)) | Not applicable | What happens to the battery passport over the battery's life The terms are narrowly defined. [Repurposing](https://kabin.sh/en/battery-passport/glossary#repurposing) means that a battery which is not waste is used, in whole or in part, for a purpose other than the original one, such as a vehicle battery used as home storage (Art. 3(1), point 31). [Remanufacturing](https://kabin.sh/en/battery-passport/glossary#remanufacturing) requires disassembling and evaluating all cells and modules, restoring capacity to at least 90 % of the original rated capacity, and a uniform state of health across cells with no more than 3 % deviation; the battery then serves the same purpose as before (point 32). The passport records the battery's status (“original”, “repurposed”, “re-used”, “remanufactured” or “waste”) in the data on the individual battery (Annex XIII, point 4(c)). In the new passport, the new operator updates whatever is no longer valid, such as its own identity and the performance and durability values (FAQ 9.5). Anyone offering used vehicle batteries as stationary storage is therefore responsible for the new passport. More on stationary applications in [Battery passport for stationary storage](https://kabin.sh/en/blog/battery-passport-stationary-storage). ## What is in the battery passport, and who may see it? Annex XIII sets out the content in four points. Three describe the battery model, one the individual battery. Each point has its own access rights (Art. 77(2)): | Annex XIII | Relates to | Content | Access | | ---------- | ------------------ | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------------------------------------------------------------------------- | | Point 1 | Model | Annex VI, Part A information (manufacturer, category, place and date of manufacture, weight, capacity, chemistry, hazardous substances, usable extinguishing agent, critical raw materials above 0.1 %); material composition; carbon footprint; responsible sourcing; recycled content; renewable content share; rated capacity; minimum, nominal and maximum voltage; power capability and limits; expected lifetime in cycles with reference test; capacity threshold for exhaustion (electric vehicle batteries only); temperature range when not in use; warranty period for calendar life; round trip efficiency initially and at 50 % of cycle life; internal resistance; C-rate; markings under Art. 13(4) and (5); EU declaration of conformity; waste prevention and waste battery information | Public | | Point 2 | Model | Detailed composition (cathode, anode, electrolyte); part numbers and contact details for replacement spares; dismantling information (exploded diagrams, disassembly sequence, fastening techniques, tools, warnings, number and layout of cells); safety measures | Persons with a legitimate interest, notified bodies, market surveillance authorities, the Commission | | Point 3 | Model | Results of test reports proving compliance with the requirements | Notified bodies, market surveillance authorities, the Commission | | Point 4 | Individual battery | Performance and durability values under Art. 10(1) when placed on the market and on status changes; state of health under Art. 14; status; usage data such as charge and discharge cycles, negative events such as accidents, operating temperature and state of charge | Persons with a legitimate interest | Battery passport content under Annex XIII and access under Art. 77(2) Information is included only to the extent it applies to the battery's category (Art. 77(2)). Information that is not language-neutral must be given in the language the Member State sets for end-users (FAQ 7.4). ### Who counts as a person with a legitimate interest? Article 77(2) names two purposes: dismantling, safety and detailed composition, so that repairers, remanufacturers, second-life operators and recyclers can do their work; and, for individual batteries, enabling the purchaser to make the battery available to independent energy aggregators or energy market participants. Who exactly has a [legitimate interest](https://kabin.sh/en/battery-passport/glossary#legitimate-interest) and what they may download, share, publish and re-use was for the Commission to specify by 18 August 2026 in an [implementing act](https://kabin.sh/en/battery-passport/glossary#implementing-act) (Art. 77(9)). When we checked, that act existed only as a draft, open for public feedback from 19 October to 16 November 2026. Among others, the draft names repairers, remanufacturers, repurposers, waste treatment operators, recyclers and vocational training centres for composition and dismantling information, and the purchaser and third parties acting on its behalf for the data on the individual battery. It has not been adopted and may still change. The restricted data must still exist and be protected from the start. The [access tiers](https://kabin.sh/en/battery-passport/access-tiers) page and the article [Access tiers in the battery passport](https://kabin.sh/en/blog/access-tiers-in-the-battery-passport) explain the levels in detail. ### How the content maps to data fields Our field registry maps Annex XIII and the related articles to 97 fields, by section, access tier and category. This overview shows how they are distributed: | Section | public | legitimate interest | authorities | Total | | ----------------------------- | ------ | ------------------- | ----------- | ----- | | Identification & product data | 16 | 2 | 1 | 19 | | Materials & composition | 3 | 1 | 0 | 4 | | Hazardous substances | 3 | 0 | 0 | 3 | | Carbon footprint | 5 | 0 | 0 | 5 | | Due diligence | 3 | 0 | 0 | 3 | | Circularity | 7 | 3 | 0 | 10 | | Performance & durability | 21 | 2 | 0 | 23 | | Battery condition (dynamic) | 0 | 22 | 0 | 22 | | Labelling & conformity | 7 | 0 | 1 | 8 | | Total | 65 | 30 | 2 | 97 | Fields per section and access tier in field registry 0.5.0 | Battery category | required | required later | conditional | | ------------------------------------ | -------- | -------------- | ----------- | | EV battery | 51 | 6 | 6 | | LMT battery | 59 | 6 | 6 | | Industrial battery (> 2 kWh) | 44 | 6 | 6 | | Stationary storage battery (> 2 kWh) | 58 | 6 | 6 | | Industrial battery without BMS | 44 | 6 | 6 | Required fields per battery category in field registry 0.5.0 (required later and conditional counted separately) One example: these public identification fields are required by the registry for stationary storage. | Data field | Requirement | Legal basis | | ----------------------------- | ----------- | ----------------------------------------------------------- | | Model identifier / SKU | required | Annex XIII 1(a); Annex VI Part A(2); Art. 38(6) | | GTIN (GS1) | required | Art. 77(3) unique identifier (ISO/IEC 15459) | | Battery category | required | Annex XIII 1(a); Annex VI Part A(2) | | Manufacturer name | required | Annex XIII 1(a); Annex VI Part A(1); Art. 38(7) | | Manufacturer address | required | Annex XIII 1(a); Annex VI Part A(1); Art. 38(7) | | Responsible economic operator | required | Art. 77(3)–(4) | | Battery mass (kg) | required | Annex XIII 1(a); Annex VI Part A(5) | | Serial number | required | Annex XIII 1(a); Annex VI Part A(2); Art. 38(6); Art. 77(3) | | Manufacturing date | required | Annex XIII 1(a); Annex VI Part A(4) (month and year) | | Place of manufacture | required | Annex XIII 1(a); Annex VI Part A(3) | Data fields from field registry 0.5.0 The complete list, filterable by category, access tier and section, is on [data fields](https://kabin.sh/en/battery-passport/data-fields). It reflects our reading of the Regulation and does not replace a case-by-case assessment. ### What is not required at the start The Commission has published guidance on the passport's data points, most recently version 2.0 of 15 August 2026 with 71 data points. It is not binding, but it classifies each data point: required from the start, required only in certain cases, not required at the start, or relevant only to certain battery types (FAQ 1.1 and 7.1). Three items of point 1 are expressly not yet required at the start (FAQ 7.2): - **Carbon footprint** ([Art. 7(1)](https://kabin.sh/en/battery-passport/glossary#carbon-footprint)): the declaration applies only a set period after the delegated act on the calculation method and the implementing act on the format enter into force. Both are missing, so it does not yet apply to any category. - **Recycled content** (Art. 8(1)): documentation for industrial batteries above 2 kWh (except those with exclusively external storage), electric vehicle and SLI batteries applies from 18 August 2028 or 24 months after the delegated act on the method, whichever is later. - **Due diligence** (Art. 48): applies from 18 August 2027, postponed by Regulation (EU) 2025/1561, and only to economic operators with a net turnover of EUR 40 million or more, including at group level (Art. 47). The report under Art. 52(3) then feeds the responsible sourcing information. Passports contain this information only for batteries placed on the market after the relevant obligation applies (FAQ 7.2). If a battery contains none of the materials concerned, the recycled content and due diligence information does not apply at all (FAQ 7.8). ### Dynamic data from day one According to the Commission FAQ, the requirements on data from use are expected to apply from the start; they are not among the items expressly deferred (FAQ 8.1). The operator placing the battery on the market remains responsible but may delegate the practical work in writing (FAQ 8.2). There is no fixed update frequency. Updates are due at least when the status changes or a change is being considered, for example before deciding on remanufacturing, repurposing or recycling (FAQ 8.3). Real-time transmission is not required (FAQ 8.4). For a new battery the usage fields may start empty, but not the status and the performance values (FAQ 8.6). [State of health](https://kabin.sh/en/battery-passport/glossary#state-of-health) is required only where the battery has a [battery management system](https://kabin.sh/en/battery-passport/glossary#battery-management-system); for the usage data under point 4(d) the text provides no such exemption (FAQ 8.5). Anyone who has legally purchased the battery has read-only access to the BMS data (Art. 14(2)). ## How does the passport get onto the battery? Through a QR code linked to a unique identifier. Article 77(3) requires the passport to be accessible through the QR code under Article 13(6), and the identifier to be assigned by the economic operator placing the battery on the market. ### The QR code From 18 February 2027, all batteries carry a QR code in line with Annex VI, Part C (Art. 13(6)). For LMT, electric vehicle and industrial batteries above 2 kWh it leads to the passport; for other batteries to the label information, the declaration of conformity, the due diligence report and the information on waste batteries. Annex VI, Part C requires strong colour contrast and a size that commonly available QR readers, including those in mobile devices, can read easily. The code is printed or engraved visibly, legibly and indelibly on the battery; where that is not possible, it goes on the packaging and accompanying documents (Art. 13(7)). The Commission could provide for alternative smart labels in addition to or instead of the QR code by delegated act (Art. 13(8)); no such act existed when we checked. ### The unique identifier The [unique identifier](https://kabin.sh/en/battery-passport/glossary#unique-identifier) is “a unique string of characters for the identification of batteries that also enables a web link to the battery passport” (Art. 3(1), point 66). QR code and identifier comply with ISO/IEC 15459-1 to -6 or equivalent standards (Art. 77(3)). Operators can create the identifier themselves using one of the options in those standards or obtain it from a commercial service; it is stored with the passport and registered in the registry (FAQ 5.2). ### GS1 Digital Link as one option A common route is [GS1 Digital Link](https://kabin.sh/en/battery-passport/glossary#gs1-digital-link). The GS1 standard describes how GS1 identifiers such as the GTIN and serial number are encoded in a web address. An address for an individual battery looks like `https://resolver.example/01/GTIN/21/SERIAL`, where key 01 introduces the GTIN and 21 the serial number. A QR code carrying this address is both a web link and a structured identifier; the URI syntax is at version 1.7.0. The Regulation does not prescribe GS1, though; any scheme that meets Article 77(3) is acceptable. What matters more is that the address stays reachable for years: plan a domain you control yourself, so that changing service provider does not invalidate the codes already printed. ## What goes into the EU registry, and how does the passport stay available? The unique identifier goes into the EU registry, not the passport. The economic operator placing the battery on the market or putting it into service uploads it to the [digital product passport registry](https://kabin.sh/en/battery-passport/glossary#dpp-registry) (Art. 77(10), inserted by the Ecodesign Regulation). The registry expressly stores the unique identifiers of batteries under Article 77(3) (Art. 13(1) of the Ecodesign Regulation). ### How registration works The Commission launched the registry on 20 July 2026, with a testing environment and a helpdesk (FAQ 1.2). Implementing Regulation (EU) 2026/1778 has governed how it works since 6 August 2026; it expressly covers batteries under Article 77 (Art. 1(1)(b)): 1. **Verification.** Economic operators that are legal persons prove their identity and establishment with a qualified electronic seal under eIDAS or a qualified electronic attestation of attributes (Art. 4). The status lasts until the identification means expires, at most three years; after that, no new registrations or changes are possible until verification is repeated. 2. **Registration.** Through the web interface or an API (Art. 8(6)). The registry automatically checks semantic conformity and granularity and stores the identifiers, registrant information with date and time, and the integrity of the passport (Art. 8(7) and (9)). It returns a unique registration identifier. 3. **Proof.** The operator can generate proof of registration at any time, with a qualified electronic seal, a time stamp and a hash of the registered passport version (Art. 9). Under the Ecodesign Regulation, the registration identifier is not proof of compliance (Art. 13(5)). Unlike for ecodesign products, it does not go into the customs declaration for batteries either (FAQ 4.1). | Data | In the registry? | Basis | | ---------------------------------------------------- | ----------------------------------------------------------------- | -------------------------------------------- | | Unique identifier of the battery | Yes | Art. 77(10); Art. 13(1) Ecodesign Regulation | | Registration identifier | Yes, generated by the registry | Art. 8(8) IR (EU) 2026/1778 | | Registrant, date and time, integrity of the passport | Yes | Art. 8(9) IR (EU) 2026/1778 | | Passport content under Annex XIII | No, kept by the economic operator or someone acting on its behalf | Art. 78(c); FAQ 6.5 | | Release of restricted data | No, controlled by the economic operator | FAQ 6.5 | What the EU registry stores for the battery passport, and what it does not Still unfinished are the semantic repository for batteries, which the registry is to use to check completeness (FAQ 11.1), and the full API; manual registration and bulk upload are also foreseen (FAQ 5.1). ### What Article 78 requires for availability Article 78 sets essential requirements for technical design and operation. They apply whether you run the passport yourself or use a service provider: | Art. 78 | Requirement | | --------- | ------------------------------------------------------------------------------------------------------------------- | | Point (a) | Fully interoperable with other digital product passports under ecodesign law | | Point (b) | Free access for consumers, economic operators and others according to their access rights | | Point (c) | Data stored by the responsible economic operator or by operators authorised to act on its behalf | | Point (d) | Those operators may not sell, re-use or process the data beyond the service | | Point (e) | The passport remains available even after the economic operator ceases to exist or ceases its activity in the Union | | Point (f) | Access, entry, modification and updates only according to the access rights of Annex XIII and the Art. 77(9) act | | Point (g) | Authenticity, reliability and integrity of the data | | Point (h) | High level of security and privacy; fraud avoided | Article 77 sets no period in years: the passport exists until the battery has been recycled (Art. 77(8)). The Regulation does not say how the passport stays available once the company is gone. That is a core question when you weigh [building or buying](https://kabin.sh/en/battery-passport-build-or-buy). ## What is still open? Several acts that affect the passport's content and access are still missing, some of them past their deadline. The status when we checked: | Item | Legal basis | Deadline | Status | As of our check | | ----------------------------------------------------------------------------------------------------------------- | ----------------------------------------------- | --------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------- | | Access rights for persons with a legitimate interest (implementing act) | Art. 77(9) | 18 August 2026 | Draft open for public feedback from 19 October to 16 November 2026; not adopted | 25 October 2026 | | Harmonised labelling (implementing act) | Art. 13(10) | 18 August 2025 | Draft open for feedback from 15 December 2025 to 26 January 2026; not adopted | 25 October 2026 | | Carbon footprint: method for electric vehicle batteries (delegated act) and declaration format (implementing act) | Art. 7(1) | 18 February 2024 | Drafts open for feedback in April and May 2024; not adopted | 25 October 2026 | | Carbon footprint: method for industrial batteries (delegated act) | Art. 7(1) | 18 February 2025 | Planned only, no draft | 25 October 2026 | | Minimum performance and durability values for rechargeable industrial batteries (delegated act) | Art. 10(5) | 18 February 2026 | Draft open for public feedback from 29 September to 27 October 2026; not adopted | 25 October 2026 | | Recycled content method (delegated act) | Art. 8(1) | 18 August 2026 | Draft open for feedback for four weeks from 12 August; not adopted | 25 October 2026 | | Harmonised standards under the Battery Regulation | Art. 15 | None | First reference since 16 September 2026: EN 18060:2025 on the performance and durability of electric vehicle batteries (Implementing Decision (EU) 2026/2048); none yet for stationary or other industrial batteries | 25 October 2026 | | Digital product passport standards | Ecodesign Regulation | None | Six of eight standards referenced since 15 July 2026 (Implementing Decision (EU) 2026/1736); presumption of conformity only under the Ecodesign Regulation | 25 October 2026 | | EU registry: semantic repository for batteries and full API | Art. 13 Ecodesign Regulation; IR (EU) 2026/1778 | None for repository and API | Registry running with a testing environment since 20 July 2026; repository and API for batteries not finished | 25 October 2026 | Open acts, standards and building blocks for the battery passport In practice: the label obligation of Article 13(1) to (3) applies from 18 August 2026 or 18 months after the labelling implementing act, whichever is later; since that act is missing, it does not apply yet. No carbon footprint declaration applies so far. Minimum values for industrial batteries apply from 18 August 2027 or 18 months after the delegated act, whichever is later (Art. 10(2)). The Commission's due diligence guidelines were due by 26 July 2026 (Art. 48(5)); we did not find them in the Official Journal. The proposed environmental omnibus (COM(2025) 981) amends parts of the Battery Regulation but not the battery passport; it was still in the legislative procedure when we checked. There is no binding data model yet; the registry's semantic repository is meant to provide one (FAQ 11.1). Until then, the freely downloadable DIN DKE SPEC 99100 on battery passport data attributes (a DIN SPEC, not a harmonised standard, with no presumption of conformity) and the equally non-binding data model of the Battery Pass consortium offer guidance. We track every item in our [implementation status](https://kabin.sh/en/battery-passport/implementation-status), with source and check date per row; the glossary explains the difference between [delegated acts](https://kabin.sh/en/battery-passport/glossary#delegated-act) and implementing acts. ## What are the penalties in Germany? A fine of up to EUR 10,000 for inaccurate, incomplete or outdated passport information, and above all market surveillance measures. Article 93 required Member States to lay down penalties by 18 August 2025. In Germany, the Batterierecht-Durchführungsgesetz (BattDG) does so; it has been in force since 7 October 2025. The offences in Section 60 BattDG that matter most for the passport, each when committed intentionally or negligently: | Offence | Provision | Fine up to | | ------------------------------------------------------------------------------------------------------------- | -------------------------------------- | ----------- | | Failing, contrary to Art. 77(4), to ensure that the passport information is accurate, complete and up to date | Section 60(2) no. 29 | EUR 10,000 | | Labelling and marking, including the QR code under Art. 13(4) to (7), missing or wrong (via Art. 38(1)(b)) | Section 60(2) no. 6 | EUR 10,000 | | Breach of the producer registration obligation under Art. 55 | Section 60(2) no. 23 | EUR 100,000 | | Breaches of supply chain due diligence obligations | Section 60(2) nos. 14 to 18, 20 and 22 | EUR 500,000 | Selected administrative offences under Section 60 BattDG Market access usually matters more than the fine. Where market surveillance authorities find that a battery does not meet the requirements, they require corrective action and can order its withdrawal or recall; if that does not happen, they restrict or prohibit making it available (Art. 79 et seq.). Importers may not place a battery on the market at all unless it is labelled and marked under Article 13 (Art. 41(1)). ## How do you prepare? Most of the data already exists: in data sheets, technical documentation, ERP exports and with suppliers. The work lies in bringing it together, reviewing it and keeping it current. We recommend this order: 1. **Classify products.** For each product, settle category, capacity and what is placed on the market as one finished battery. Record the reasoning in writing. 2. **Clarify roles.** Who places on the market: you as manufacturer, you as importer, or a customer who completes your battery? Record written authorisations. 3. **Match your data.** Compare Annex XIII, points 1, 2 and 4, with your Article 10 documents, technical documentation and declaration of conformity; the [data fields](https://kabin.sh/en/battery-passport/data-fields) work as a checklist. 4. **Involve suppliers.** Composition, critical raw materials and hazardous substances usually come from the cell or module supplier, which must provide the necessary information free of charge under Article 39. 5. **Organise review and approval.** Decide who enters values, who approves them on what evidence, and how changes stay traceable. The article [Provenance and four-eyes review](https://kabin.sh/en/blog/provenance-and-four-eyes-review-battery-passport) explains why this matters. 6. **Settle identifier and QR code.** Choose a scheme under ISO/IEC 15459, such as GS1 Digital Link with GTIN and serial number, fix a domain you control for the long term, and plan the code into the rating plate and label printing. 7. **Connect data from use.** Clarify how BMS and service data reach the passport, at least at every status change. 8. **Prepare access tiers.** Separate public and restricted data technically. Until the Article 77(9) act applies, grant access individually and log it. 9. **Prepare for registration.** Obtain a qualified electronic seal from a trust service provider or a qualified electronic attestation of attributes, and try out the registry's testing environment. 10. **Secure availability and exit.** Make sure the passport stays reachable without you and without your service provider; insist on complete exports in open formats. 11. **Connect your systems.** Take master data and serial numbers from the ERP instead of retyping them. The articles [From Excel and ERP exports to a reviewed battery passport](https://kabin.sh/en/blog/excel-erp-exports-to-battery-passport) and [Connecting the battery passport to SAP, Business Central and Odoo](https://kabin.sh/en/blog/connecting-battery-passport-sap-business-central-odoo) show how. 12. **Choose your tooling.** Decide whether to implement the passport with an ERP vendor module, a specialised platform, a consultancy build or in-house. Criteria are in [Choosing battery passport software](https://kabin.sh/en/choosing-battery-passport-software). ## Where does BatteryPass help? BatteryPass is a platform for manufacturers and importers, mainly of stationary storage and industrial batteries. It brings existing data sheets, ERP exports and supplier information together into a reviewed passport. No customer runs BatteryPass in production yet, so we state the status of each feature: - Import from CSV and Excel, provenance per value, four-eyes review and supplier requests by link without an account in testing - Separation of model, model version and unit, signed and versioned passports with GS1 Digital Link QR codes, server-side access tiers in testing - Access to restricted tiers, only by grant per email address limited - Submission to the EU registry and managed ERP connections planned Responsibility for the data stays with you as the economic operator. Details are on the [product page](https://kabin.sh/en/product) and under [security](https://kabin.sh/en/security). Your data, a reviewed battery passport In 30 minutes we show you how your existing spreadsheets, supplier data and serial numbers become a maintained battery passport. [Request a demo](https://kabin.sh/en/contact)[See an example passport](https://kabin.sh/en/example-passport) ## Frequently asked questions ### When does a battery need a battery passport? From 18 February 2027, if it is placed on the EU market or put into service from that day (Art. 77(1)). Which obligations apply before and after is shown in our [battery passport timeline](https://kabin.sh/en/battery-passport/timeline). ### Does an industrial battery of exactly 2 kWh need a passport? No. Article 77(1) requires a passport for industrial batteries with a capacity greater than 2 kWh. The battery still needs a QR code (Art. 13(6)). Examples around the threshold are in [Industrial batteries over 2 kWh](https://kabin.sh/en/blog/industrial-batteries-over-2-kwh-battery-passport). ### Is one passport per model enough? No. Every individual battery placed on the market needs its own passport. All units share the model data; the data on the individual battery comes on top. What counts as one battery for modules, racks and containers is explained in [Module, pack or container](https://kabin.sh/en/blog/module-pack-or-container-battery-passport). ### Do batteries sold before the start date need a passport retrospectively? No, the obligation is not retroactive. If such a battery is repurposed or remanufactured after the start date and placed on the market again, it does need one (Art. 77(7); the Commission confirms this for remanufacturing in FAQ 9.4). More answers are in our [battery passport FAQ](https://kabin.sh/en/battery-passport/faq). ### Who is responsible if a service provider maintains the passport for us? You remain responsible if you place the battery on the market. You may authorise others in writing to act on your behalf, but responsibility for accurate, complete and up-to-date information stays with you (Art. 77(4); Commission FAQ 2.1). The [glossary](https://kabin.sh/en/battery-passport/glossary#economic-operator) explains the term. ### Who may see the restricted data in the battery passport? Notified bodies, market surveillance authorities and the Commission see Annex XIII points 2 and 3; persons with a legitimate interest see points 2 and 4. Who counts as such a person is for an implementing act under Art. 77(9) to settle; when we checked, it existed only as a draft. More on [access tiers](https://kabin.sh/en/battery-passport/access-tiers). ### Must the carbon footprint be in the passport from the start? No. According to the Commission's guidance and FAQ, carbon footprint, recycled content and due diligence information are not yet required at the start. They have their own dates, some of which depend on acts that are still missing. See our [implementation status](https://kabin.sh/en/battery-passport/implementation-status). ### Does the identifier have to be a GS1 Digital Link? No. The Regulation requires a unique identifier and a QR code that comply with ISO/IEC 15459 or equivalent standards (Art. 77(3)), but prescribes no particular scheme. GS1 Digital Link is one common option; see the [glossary](https://kabin.sh/en/battery-passport/glossary#gs1-digital-link). ### Does the EU registry store the content of the battery passport? No. The registry stores the unique identifier and registration data. The passport itself is kept by the economic operator or by someone acting on its behalf (Art. 78(c); Commission FAQ 6.5). Only verified economic operators may register, for example with a qualified electronic seal. The registry's status is tracked in our [implementation status](https://kabin.sh/en/battery-passport/implementation-status). ### What happens to the passport if the responsible company closes down? The passport must remain available even after the responsible economic operator ceases to exist or ceases its activity in the Union (Art. 78(e)). That applies whether you build the system yourself or buy software; see [build or buy](https://kabin.sh/en/battery-passport-build-or-buy). ### What data goes into the passport of a stationary storage system? Public model data such as label information, chemistry, capacity, voltages and efficiency; restricted model data such as dismantling information; and data on the individual battery such as state of health and usage data (Annex XIII). Our field list per category is on [data fields](https://kabin.sh/en/battery-passport/data-fields). ### How often must dynamic data be updated? The Regulation sets no fixed frequency. According to the Commission FAQ, at least when the battery's status changes or a change is being considered, for example before remanufacturing (FAQ 8.3 and 8.4). How condition data reaches the passport is described in [Battery passport for stationary storage](https://kabin.sh/en/blog/battery-passport-stationary-storage). ### Is there an approval scheme for battery passport software? No. The Battery Regulation does not regulate software providers; whether and which provider you use is your decision alone (Commission FAQ 10.3). Selection criteria are in [Choosing battery passport software](https://kabin.sh/en/choosing-battery-passport-software). ### What fines apply in Germany? Anyone who intentionally or negligently fails to ensure that the passport information is accurate, complete and up to date commits an administrative offence, punishable by a fine of up to EUR 10,000 (Section 60 BattDG). Market surveillance measures under Art. 79 et seq. of the Regulation are usually the bigger risk. More in our [FAQ](https://kabin.sh/en/battery-passport/faq). ## Sources 1. [Regulation (EU) 2023/1542, Article 1: Subject matter and scope](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_1) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 2. [Regulation (EU) 2023/1542, Article 3: Definitions](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_3) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 3. [Regulation (EU) 2023/1542, Article 7: Carbon footprint of electric vehicle batteries, rechargeable industrial batteries and LMT batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_7) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 4. 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[Have your say: Batteries, definition of labelling requirements (Art. 13(10))](https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14456-Batteries-definition-of-labelling-requirements_en) · European Commission · accessed 25 October 2026 36. [Have your say: Carbon footprint methodology for electric vehicle batteries](https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13877-Carbon-footprint-methodology-for-electric-vehicle-batteries_en) · European Commission · accessed 25 October 2026 37. [Have your say: Format of the carbon footprint declaration for batteries](https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13878-Format-of-the-carbon-footprint-declaration-for-batteries_en) · European Commission · accessed 25 October 2026 38. [Have your say: Carbon footprint methodology for industrial batteries (planned)](https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14313-Carbon-footprint-methodology-for-industrial-batteries_en) · European Commission · accessed 25 October 2026 39. [Have your say: Minimum values for the electrochemical performance and durability of rechargeable industrial batteries (Art. 10(5))](https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14460-Minimum-values-for-the-electrochemical-performance-and-durability-of-rechargeable-industrial-batteries_en) · European Commission · accessed 25 October 2026 40. [Have your say: Methodology for calculation and verification of recycled content in batteries (Art. 8(1))](https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14858-Methodology-for-calculation-and-verification-of-recycled-content-in-batteries_en) · European Commission · accessed 25 October 2026 41. [German Battery Law Implementation Act (BattDG), Section 60: Administrative fines](https://www.gesetze-im-internet.de/battdg/__60.html) · Federal Ministry of Justice (gesetze-im-internet.de) · accessed 25 October 2026 42. [GS1 Digital Link standard](https://www.gs1.org/standards/gs1-digital-link) · GS1 · accessed 25 October 2026 43. [DIN DKE SPEC 99100:2025-02, Requirements for data attributes of the battery passport](https://www.dinmedia.de/de/technische-regel/din-dke-spec-99100/385692321) · DIN Media · accessed 25 October 2026 44. [Battery Pass consortium data model (BatteryPass Data Model, GEFEG GitLab)](https://git.gefeg.com/bp/BatteryPassDataModel) · Battery Pass consortium (GEFEG GitLab) · accessed 25 October 2026 This page reflects the law as we checked it against the linked primary sources on 25 October 2026. It is not legal advice; the text published in the Official Journal of the EU prevails. 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