# Battery passport: frequently asked questions > Answers on the EU battery passport: which batteries need one, who is responsible, who sees what, the QR code, the EU registry, deadlines and software. Answers on the EU battery passport: which batteries need one, who is responsible, who sees what, the QR code, the EU registry, deadlines and software. By [BatteryPass-Redaktion](https://kabin.sh/en/about#batterypass-team)Published: 25 October 2026Updated: 25 October 2026Facts checked: 25 October 20261 min read ## In short Brief answers to the most common questions about the EU battery passport, in seven topics: which batteries need one from 18 February 2027, who is responsible, what goes into it, who may see which data, what applies to the QR code and the EU registry, which deadlines run and what software has to do. Every answer names its legal basis. This page answers the questions that come up again and again when companies start on the EU battery passport: briefly, with the answer first, and with the legal basis in the Battery Regulation (EU) 2023/1542, Germany’s Battery Law Implementation Act (BattDG) or the European Commission’s own answers. Each answer links to the page that covers the topic in depth. Facts checked on 25 October 2026. The questions are grouped in seven topics: scope, duties and responsibility, content, access, data carrier and registry, timing, and software and integration. Where the Commission has answered a question in its battery passport FAQ, we give the question number. Those answers are not legally binding, but they show how the Commission reads the Regulation. Some points still depend on acts that were missing when we checked, above all the implementing act on legitimate interest (Art. 77(9)). Where that is the case, we say so. Further reading: - [Battery passport guide](https://kabin.sh/en/battery-passport): the whole subject on one page - [Timeline](https://kabin.sh/en/battery-passport/timeline): every date with its status - [Implementation status](https://kabin.sh/en/battery-passport/implementation-status): which acts and standards are still missing - [Data fields](https://kabin.sh/en/battery-passport/data-fields) and [access tiers](https://kabin.sh/en/battery-passport/access-tiers): what goes into the passport and who may see it - [Glossary](https://kabin.sh/en/battery-passport/glossary): the Regulation’s terms, briefly explained ## Scope ### Which batteries need a battery passport? Every LMT battery (light means of transport), every electric vehicle battery and every industrial battery with a capacity greater than 2 kWh that is placed on the market or put into service from 18 February 2027 (Art. 77(1)). Portable and SLI batteries do not need one, but from the same day they carry a QR code that leads to their mandatory information (Art. 13(6)). Our [battery passport guide](https://kabin.sh/en/battery-passport) explains how to classify a battery. ### Does a 10 kWh home storage battery need a battery passport? Yes. A home storage battery is a stationary battery energy storage system and therefore an industrial battery, regardless of where and by whom it is used (Art. 3(1)(15)). At 10 kWh it is above the 2 kWh threshold and needs its own passport from 18 February 2027. More in our article on the [battery passport for stationary storage](https://kabin.sh/en/blog/battery-passport-stationary-storage). ### What about a battery with exactly 2 kWh? It does not need a battery passport, because Article 77(1) only covers a capacity ‘greater than 2 kWh’. From 18 February 2027 it still carries a QR code that leads to its label information, the declaration of conformity, the due diligence report and the information on waste batteries (Art. 13(6)(b)). Borderline cases are covered in [industrial batteries over 2 kWh](https://kabin.sh/en/blog/industrial-batteries-over-2-kwh-battery-passport). ### Do batteries sold before the start date need a passport? No. The obligation is tied to each individual battery placed on the market or put into service from 18 February 2027; Article 77(1) does not require a passport for batteries placed on the market before then. If such a battery is later repurposed or remanufactured and placed on the market again, it needs a passport (Art. 77(7); the Commission confirms this for remanufacturing in its FAQ, question 9.4). The key dates are in our [timeline](https://kabin.sh/en/battery-passport/timeline). ### Is there one passport per module or one for the whole system? It depends on what the finished battery is. If several packs depend on a common BMS or other common components and together form one working battery, the whole system is the battery and needs one passport; if each pack works on its own, each is a separate battery (Commission FAQ, question 3.2). The 2 kWh threshold then applies to the capacity of the system or of the individual pack (question 3.3). Examples in [module, pack or container](https://kabin.sh/en/blog/module-pack-or-container-battery-passport). ### Do imported cells or modules need a passport? Usually not, as long as they are only components that will be assembled into a finished battery in the EU. The obligation arises for the finished battery, and whoever completes it in the EU becomes its manufacturer (Commission FAQ, questions 3.4 and 4.3). It is different for do-it-yourself kits that end-users assemble with common tools, and for cells or modules made available for end use without further assembly: they count as batteries in their own right (Art. 1(4)). Term: [battery module](https://kabin.sh/en/battery-passport/glossary#battery-module). ## Duties and responsibility ### Who is responsible for the battery passport? The economic operator that places the battery on the EU market or puts it into service. It ensures that the information in the passport is accurate, complete and up to date (Art. 77(4)) and attributes the unique identifier (Art. 77(3)). Responsibility moves on after repurposing or remanufacturing and when the battery becomes waste (Art. 77(7)). Term: [economic operator](https://kabin.sh/en/battery-passport/glossary#economic-operator). ### Who is responsible when we import batteries from outside the EU? Normally you, as the importer, because you place the battery on the EU market. That also applies when the finished battery is built into a device, machine or vehicle: it is normally placed on the market when the product is imported (Commission FAQ, question 3.5). Before that, you check the declaration of conformity, the technical documentation and the labelling, among other things (Art. 41). More on our page for [importers](https://kabin.sh/en/solutions/importers). ### We assemble imported packs into a system in the EU. Who is responsible? The company in the EU that completes the finished, safely functioning battery and places it on the market, or puts it into service where there is no placing on the market (Commission FAQ, question 2.5). If you only connect imported packs to a BMS here to make one battery, you are responsible, not the supplier of the packs. Suppliers of cells and modules must give you the information you need free of charge (Art. 39). How to collect it is described in [supplier data for the battery passport](https://kabin.sh/en/blog/supplier-data-battery-passport-without-supplier-accounts). ### Can a service provider manage the battery passport for us? Yes. You may give other operators written authorisation to act on your behalf, for example a software provider, a manufacturer outside the EU or a cell manufacturer (Art. 77(4); Commission FAQ, question 2.1). Responsibility for the data stays with you, and the provider may neither sell the passport data nor use it beyond the service (Art. 78(d)). What to look for is covered in [choosing battery passport software](https://kabin.sh/en/choosing-battery-passport-software). ### What happens to the passport if our company goes out of business? The passport must stay available even after the responsible economic operator ceases to exist or stops its activity in the Union (Art. 78(e)). The Regulation does not say how this is to be done technically. Settle it in your contract with your provider or in your own operating plan; the trade-offs are discussed in [build or buy](https://kabin.sh/en/battery-passport-build-or-buy). ### 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 under section 60(2) no. 29 of the German BattDG, with a fine of up to EUR 10,000. The same ceiling applies to breaches of the labelling rules, including the QR code. Often the bigger risk is that market surveillance authorities can require corrective action, withdrawal or recall (Art. 79 et seq.). Context in our [battery passport guide](https://kabin.sh/en/battery-passport). ## Content ### What is in the battery passport? Information on the battery model and on the individual battery, in four groups under Annex XIII: public model data such as chemistry, capacity and the declaration of conformity (point 1), restricted model data such as the detailed composition and dismantling information (point 2), test results for authorities (point 3) and data on the individual battery such as state of health and usage data (point 4). Which of it applies to each battery category is shown on the [data fields](https://kabin.sh/en/battery-passport/data-fields) page. ### Does the carbon footprint have to be in the passport at the start? No. The carbon footprint declaration only applies once the Commission has adopted the acts on the calculation method and the format, and for industrial batteries at the earliest 18 months after they enter into force (Art. 7(1)); when we checked, both were missing. Recycled content and due diligence information are not required at the February 2027 start either (Commission FAQ, question 7.2). Our [implementation status](https://kabin.sh/en/battery-passport/implementation-status) tracks these acts. ### Which dynamic data belongs in the passport, and how often must it be updated? Mainly the status, the state of health and usage data such as cycles, negative events, temperature and state of charge (Annex XIII point 4). The Regulation sets no fixed frequency; according to the Commission FAQ (question 8.3), the data must be updated at least when the battery’s status changes or a change is being considered, for example before deciding whether to remanufacture, repurpose or recycle it. More often only where monitoring the state of health requires it and it is technically feasible and proportionate. Term: [state of health](https://kabin.sh/en/battery-passport/glossary#state-of-health). ### May fields be empty when a new battery is placed on the market? Yes, as far as data from use is concerned: it only arises in operation, may be empty for a new battery and does not prevent registration (Commission FAQ, questions 4.2 and 8.6). The status and the performance and durability values, however, must be in the passport from the start. Fields that only become mandatory later are marked on the [data fields](https://kabin.sh/en/battery-passport/data-fields) page. ### What happens to the passport after repurposing or remanufacturing? The battery gets a new passport linked to the passport of the original battery or batteries, and the economic operator that places it on the market again or puts it into service becomes responsible (Art. 77(7)). A simple repair does not require a new passport (Commission FAQ, question 9.2). Terms: [repurposing](https://kabin.sh/en/battery-passport/glossary#repurposing) and [remanufacturing](https://kabin.sh/en/battery-passport/glossary#remanufacturing). ## Access ### Which information in the battery passport is public? The model data in Annex XIII point 1, including the label information, chemistry, hazardous substances, critical raw materials, capacity, voltages, power, lifetime, efficiency, the declaration of conformity and information on waste batteries; later also the carbon footprint and recycled content. Anyone can read it through the QR code, free of charge (Art. 77(2), Art. 78(b)). The tiers are explained in detail on the [access tiers](https://kabin.sh/en/battery-passport/access-tiers) page. ### Who counts as a person with a legitimate interest? An implementing act under Article 77(9) is meant to settle this; its deadline passed on 18 August 2026, and when we checked on 25 October 2026 it had not been adopted. The Regulation itself names two purposes: dismantling and composition for repairers, remanufacturers, second-life operators and recyclers, and, for individual batteries, the purchaser who wants to make the battery available to energy aggregators or market participants (Art. 77(2)). A Commission draft is open for feedback until 16 November 2026 and is not law. More under [legitimate interest](https://kabin.sh/en/battery-passport/glossary#legitimate-interest) and in [access tiers in the battery passport](https://kabin.sh/en/blog/access-tiers-in-the-battery-passport). ### Do authorities see more than the public? Yes. Notified bodies, market surveillance authorities and the Commission get the restricted model data in Annex XIII point 2 and the test results in point 3, which nobody else sees, in addition to the public information (Art. 77(2)(b)). By contrast, the Regulation opens the data on the individual battery (point 4) only to persons with a legitimate interest. Overview: [access tiers](https://kabin.sh/en/battery-passport/access-tiers). ### Who checks whether someone may access restricted data? The economic operator, or the operator that provides the passport on its behalf: it hosts the passport and manages access, while the EU registry gives no access to the full passport (Commission FAQ, question 6.5). In the Commission’s view the authentication mechanism cannot readily be specified or run centrally, because the system is decentralised; national registers of recyclers and waste operators may help confirm an organisation’s status (question 6.4). What this can look like in practice is shown on the [access tiers](https://kabin.sh/en/battery-passport/access-tiers) page. ### Does access to the battery passport cost anything? No. Consumers, economic operators and other relevant actors get free access according to their access rights (Art. 78(b)). That applies to the public tier as much as to authorised parties. Which information belongs to which tier is shown on the [data fields](https://kabin.sh/en/battery-passport/data-fields) page. ## Data carrier and registry ### Must the QR code be on the battery, or is the packaging enough? As a rule on the battery: printed or engraved visibly, legibly and indelibly (Art. 13(7)). Only where the nature and size of the battery make that impossible or unwarranted does the QR code go on the packaging and the accompanying documents. Where the code leads is shown in our [example passport](https://kabin.sh/en/example-passport). ### Do we have to use GS1? No. The QR code and the unique identifier must comply with ISO/IEC 15459-1 to -6 or equivalent standards (Art. 77(3)); the Regulation does not prescribe a particular identification scheme. GS1 Digital Link is one way of combining GTIN and serial number in a web address, but not the only one. Term: [GS1 Digital Link](https://kabin.sh/en/battery-passport/glossary#gs1-digital-link). ### Do we need to register in the EU digital product passport registry? Yes. The economic operator that places the battery on the market or puts it into service uploads its unique identifier to the registry (Art. 77(10)), even where a service provider creates the passport (Commission FAQ, questions 2.1 and 2.2). To do so it must be verified in the registry; legal persons prove their identity with a qualified electronic seal or a qualified electronic attestation of attributes (Implementing Regulation (EU) 2026/1778, Art. 4). Term: [digital product passport registry](https://kabin.sh/en/battery-passport/glossary#dpp-registry). ### Is the battery passport itself stored in the EU registry? No. The registry mainly records the registration and metadata such as the unique identifier; the passport itself is stored by the economic operator or an operator acting on its behalf (Art. 78(c); Commission FAQ, question 6.5). The Commission launched the registry on 20 July 2026, with a testing environment for first steps. Our [implementation status](https://kabin.sh/en/battery-passport/implementation-status) follows its progress. ### Does the passport’s registration identifier go into the customs declaration? No. Unlike product passports under the Ecodesign Regulation, the battery passport’s registration identifier is not entered in the electronic customs declaration (Commission FAQ, question 4.1). The passport must still be registered. What else importers need to know is on our page for [importers](https://kabin.sh/en/solutions/importers). ## Timing ### When does the battery passport obligation start? On 18 February 2027, for every LMT battery, every electric vehicle battery and every industrial battery above 2 kWh placed on the market or put into service (Art. 77(1)). The QR code obligation for all batteries starts on the same day (Art. 13(6)). All dates are in our [timeline](https://kabin.sh/en/battery-passport/timeline). ### What already applies before the passport starts? Since 18 August 2024, rechargeable industrial batteries above 2 kWh, LMT and electric vehicle batteries must be accompanied by a document with their performance and durability values (Art. 10(1)). Since the same day, the battery management system of stationary storage, LMT and electric vehicle batteries has had to hold up-to-date data on state of health and expected lifetime (Art. 14(1)). The [timeline](https://kabin.sh/en/battery-passport/timeline) gives the overview. ### When do carbon footprint, recycled content and due diligence enter the passport? Due diligence obligations apply from 18 August 2027 to economic operators with a net turnover of EUR 40 million or more, also as a group; information from their report then becomes part of the public passport data (Art. 47, Art. 48, Annex XIII point 1(d)). Carbon footprint and recycled content depend on Commission acts that were missing when we checked: recycled content documentation applies from 18 August 2028 at the earliest, the carbon footprint declaration for industrial batteries at the earliest 18 months after the acts enter into force (Art. 7 and 8). The [implementation status](https://kabin.sh/en/battery-passport/implementation-status) shows the current state. ### When will the act on legitimate interest arrive? That is not yet known. The Commission’s deadline passed on 18 August 2026 (Art. 77(9)); a draft is open for public feedback from 19 October to 16 November 2026. The examination procedure with the Member States follows, and no adoption date has been announced. We track it on the [implementation status](https://kabin.sh/en/battery-passport/implementation-status) page. ### How long does a battery passport exist? Until the battery has been recycled; then the passport ceases to exist (Art. 77(8)). Until then it must remain available, through repurposing, remanufacturing and the change to waste battery, and even if the responsible economic operator no longer exists (Art. 77(7), Art. 78(e)). The life of a passport is described in our [battery passport guide](https://kabin.sh/en/battery-passport). ## Software and integration ### Is there a certification or approval scheme for battery passport software? No. The Battery Regulation does not regulate providers of battery passport solutions; whether you use one is your decision, and the relationship is governed only by your contract (Commission FAQ, question 10.3). There is no EU approval, test or list of such software. What to look for is covered in [choosing battery passport software](https://kabin.sh/en/choosing-battery-passport-software). ### Is a blockchain required? No. No particular technology is prescribed; blockchain is allowed but not required (Commission FAQ, question 11.3). What is required are open standards, an interoperable, machine-readable format and the authenticity, reliability and integrity of the data (Art. 77(5), Art. 78(g)). How BatteryPass signs published passports is described on the [security](https://kabin.sh/en/security) page. ### How do we avoid vendor lock-in? The Regulation requires all information to be based on open standards, interoperable, machine-readable and transferable through an open data exchange network ‘without vendor lock-in’ (Art. 77(5)). In the contract, make sure you can export all data, evidence and versions in full at any time, and that the passport stays reachable under the same identifier if you switch. More in [build or buy](https://kabin.sh/en/battery-passport-build-or-buy). ### Can our ERP system fill the battery passport? Partly. Serial numbers, production dates and item master data usually sit in the ERP and can be taken over by export or interface; composition, evidence and supplier information often come from other sources and need a review before they go into the passport. How this works with SAP, Business Central and Odoo is described in [connecting the battery passport to SAP, Business Central and Odoo](https://kabin.sh/en/blog/connecting-battery-passport-sap-business-central-odoo). ### Does the passport need a real-time connection to the battery management system? No. According to the Commission FAQ, real-time or very frequent communication is not necessarily required; at a minimum, the data must be available when a change of status is being considered (questions 8.3 and 8.4). For an offline e-bike battery, the Commission considers updating it when it comes in for servicing appropriate (question 8.7). How measurements reach the passport through an interface is shown on the [developers](https://kabin.sh/en/developers) page. ## Sources 1. [Regulation (EU) 2023/1542, Article 77: Battery passport](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_77) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 2. [Regulation (EU) 2023/1542, Article 78: Technical design and operation of the battery passport](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_78) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 3. [Regulation (EU) 2023/1542, Annex XIII: Information to be included in the battery passport](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#anx_XIII) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 4. [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 5. [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 6. [Regulation (EU) 2023/1542, Article 7: Carbon footprint](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 7. [Regulation (EU) 2023/1542, Article 8: Recycled content](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_8) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 8. [Regulation (EU) 2023/1542, Article 10: Performance and durability requirements](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_10) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 9. [Regulation (EU) 2023/1542, Article 13: Labelling, marking and the QR code](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_13) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 10. [Regulation (EU) 2023/1542, Article 14: State of health and expected lifetime](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_14) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 11. [Regulation (EU) 2023/1542, Article 39: Obligations of suppliers of battery cells and battery modules](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_39) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 12. [Regulation (EU) 2023/1542, Article 41: Obligations of importers](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_41) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 13. [Regulation (EU) 2023/1542, Article 79: Procedure at national level for dealing with batteries presenting a risk](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_79) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 14. [Regulation (EU) 2023/1542, consolidated text with Article 77(10) (upload of the identifier to the registry)](http://data.europa.eu/eli/reg/2023/1542/2026-08-13#art_77) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 15. [Regulation (EU) 2025/1561 amending Regulation (EU) 2023/1542 (due diligence)](https://eur-lex.europa.eu/eli/reg/2025/1561/oj/eng) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 16. [Implementing Regulation (EU) 2026/1778 on the digital product passport registry, Article 4: Verification](https://eur-lex.europa.eu/eli/reg_impl/2026/1778/oj/eng#art_4) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 17. [EU Digital Product Passport FAQ for Batteries](https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/eu-digital-product-passport-faq-batteries_en) · European Commission, DG GROW · accessed 25 October 2026 18. [Have your say: Batteries – access rights to certain parts of the battery passport (draft, initiative 16473)](https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/16473-Batteries-access-rights-to-certain-parts-of-the-battery-passport_en) · European Commission · accessed 25 October 2026 19. [German Battery Law Implementation Act (BattDG), section 60: Administrative offences (German)](https://www.gesetze-im-internet.de/battdg/__60.html) · Federal Ministry of Justice (gesetze-im-internet.de) · accessed 25 October 2026 20. [GS1 Digital Link Standard](https://www.gs1.org/standards/gs1-digital-link) · GS1 · 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. 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)