Battery passport for stationary storage: what applies from 18 February 2027

From 18 February 2027, every stationary battery above 2 kWh that is placed on the EU market or put into service needs its own digital battery passport, reachable through a QR code on the battery. The economic operator that places the battery on the market is responsible for it. For stationary storage the passport is not the first obligation, though: the Battery Regulation already requires performance and durability values and data in the battery management system today.

Below: what Regulation (EU) 2023/1542 means for home, commercial and grid-scale storage, and where it still waits for Commission acts.

Which stationary storage systems need a battery passport?

Article 77(1) names three categories: batteries for light means of transport (LMT batteries), electric vehicle batteries and industrial batteries with a capacity greater than 2 kWh. Stationary storage falls into the third group. The regulation defines a "stationary battery energy storage system" as an industrial battery with internal storage that stores energy from and delivers it to the grid, or stores and delivers it to end-users, "regardless of where and by whom the battery is being used" (Art. 3(1), point 15). A home battery in a basement is therefore as much an industrial battery as a container at a substation.

The threshold is "greater than 2 kWh": a battery of exactly 2 kWh needs no passport, but from the same date a QR code leading to the other mandatory information (Art. 13(6), point (b)).

The obligation is tied to placing on the market, the first making available on the Union market (Art. 3(1), point 16), or putting into service from that date. Earlier storage systems need no passport under Article 77(1).

What already applies today, and what comes when?

Some obligations already apply; others depend on acts the Commission still has to adopt.

1. already applies

   Performance and durability values

   Rechargeable industrial batteries above 2 kWh must be accompanied by a document with the values set out in Annex IV, Part A (Art. 10(1)).

2. already applies

   Data in the battery management system

   The BMS of stationary battery energy storage systems holds up-to-date data on state of health and expected lifetime under Annex VII (Art. 14(1)).

3. 18 August 2026

   Deadline for the act on legitimate interest

   By this date the Commission was to specify who counts as a person with a legitimate interest (Art. 77(9)). When we checked, the act had not been adopted.

4. 18 February 2027

   Battery passport and QR code

   Every industrial battery above 2 kWh needs a battery passport when placed on the market, and all batteries need a QR code (Art. 77(1), Art. 13(6)).

5. 18 August 2027

   Supply chain due diligence

   Applies to economic operators with a net turnover of €40 million or more; information from the report becomes part of the public passport data (Art. 47, Art. 48(1) as amended by Regulation (EU) 2025/1561).

6. pending

   Carbon footprint

   The declaration applies at the earliest 18 months after the delegated act on the method and the implementing act on the format enter into force (Art. 7(1)).

7. pending

   Minimum performance and durability values

   Apply at the earliest 18 months after the delegated act under Art. 10(5) enters into force.

8. 18 August 2031

   First minimum recycled content

   16 % cobalt, 85 % lead, 6 % lithium and 6 % nickel in active materials, per model, year and plant (Art. 8(2)).

9. 18 August 2036

   Second stage of recycled content

   26 % cobalt, 85 % lead, 12 % lithium and 15 % nickel (Art. 8(3)).

The exception in Article 8 for industrial batteries with exclusively external storage does not cover typical lithium-ion storage systems.

What is in the battery passport of a stationary storage system?

Annex XIII sets out the content in four groups: three describe the battery model, one the individual battery, "including resulting from the use of that battery" (Art. 77(2)).

Our field registry requires these public performance fields for stationary storage:

Many of these values are already in your documentation under Article 10(1). The passport makes them accessible on open standards, machine-readable and "without vendor lock-in" (Art. 77(5)).

Who may see which data?

Article 77(2) distinguishes information accessible to the general public (Annex XIII, point 1), information for notified bodies, market surveillance authorities and the Commission (points 2 and 3) and information for persons with a legitimate interest (points 2 and 4). A legitimate interest exists for two purposes: dismantling and the detailed composition, so that repairers, remanufacturers, second-life operators and recyclers can do their work; and, for individual batteries, so that the purchaser can make the battery available to independent energy aggregators or energy market participants.

Who exactly counts as a person with a legitimate interest, and what they may download, share and re-use, the Commission was to specify by implementing act by 18 August 2026 (Art. 77(9)). When we checked in October 2026, no such act had been published in the Official Journal. The data of points 2 and 4 still has to exist and be protected.

In BatteryPass the server separates the levels: public pages and exports contain only the public part in testing. Access for persons with a legitimate interest and for authorities, where you grant access per email address and every read is logged, exists behind a switch until the act is in place limited. How we protect data and access is described on Security and data protection.

One passport per battery: what counts for modules, packs and containers?

Article 77(1) requires a passport for "each" battery placed on the market, not per model. The notion of a battery is deliberately broad: a battery consists of one or more cells, modules "or of packs of them" (Art. 3(1), point 1). A module is a set of connected cells meant to be used alone or with other modules (point 3); a battery pack is a complete unit that is not meant to be split up or opened by the end-user (point 2). What matters is which unit reaches the market as a finished, safely working battery; that is how the Commission reads it in its battery passport FAQ (questions 3.1 and 3.2).

The regulation does not spell out every design; the article Module, pack or container has examples and a template for your reasoning. Record your classification per product in writing, consistent with the rating plate and the declaration of conformity. You enter model data only once: a "battery model" is a version whose units share the same relevant characteristics and the same model identifier (Art. 3(1), point 19). Each individual battery gets its own identifier and its own QR code.

Which data must the battery management system provide?

Article 14 connects the passport with operation: the BMS of a stationary battery energy storage system must contain up-to-date data for the parameters in Annex VII. Anyone who has legally purchased the battery gets read-only access at any time, for example to evaluate its residual value or to prepare it for repurposing (Art. 14(2)).

Annex XIII, point 4, takes this data into the passport: state of health under Article 14 and usage data such as cycles, negative events, temperature and state of charge. Our registry requires these condition fields for stationary storage:

In BatteryPass a BMS or a service system reports measurements with their measurement time through an API key; the passport is then re-published according to your organisation's rule in testing. The interface is described on Developers; how ERP and monitoring data are connected is shown in our integration patterns.

Who is responsible: manufacturer, importer or authorised representative?

Under Article 77(4), the economic operator placing the battery on the market ensures that the passport information is accurate, complete and up to date. It may authorise others in writing to act on its behalf; responsibility for the data stays with it, even when software manages it.

• Manufacturers in the EU: whoever places the battery on the market under its own name is responsible.
• Importers: whoever places a battery from a third country on the EU market carries the obligation of Article 77(4). Before doing so, the importer checks among other things that the battery is marked and labelled under Article 13, which from the start date includes the QR code (Art. 41(2)).
• Service providers: whoever stores passport data on behalf of the operator may not sell it or process it beyond the service (Art. 78, point (d)).

Article 78 also requires that the authenticity, reliability and integrity of the data are ensured (point (g)) and that the passport remains available after the economic operator ceases to exist or ceases its activity in the Union (point (e)).

What happens with second life and remanufacturing?

Stationary storage is a typical second life for vehicle batteries. Under Article 77(7), a battery that has been prepared for re-use or repurposing, repurposed or remanufactured gets a new passport linked to the passport of the original battery or batteries. Responsibility passes to the operator that places it on the market again.

• Repurposing means using a battery that is not waste for a purpose other than the original one, such as a vehicle battery used as home storage (Art. 3(1), point 31).
• Remanufacturing requires disassembling and evaluating all cells and modules, a restored capacity of at least 90 % of the original rated capacity and no more than 3 % difference in state of health between cells; the battery is then used for the same purpose as before (point 32).
• The status ("original", "repurposed", "re-used", "remanufactured", "waste") is part of the battery-specific data (Annex XIII, point 4(c)); the battery carries new labels (Art. 13(9)).
• For a waste battery, responsibility passes to the producer, a producer responsibility organisation or a waste management operator. The passport ceases to exist once the battery has been recycled (Art. 77(8)).

In BatteryPass, a repurposed or remanufactured battery is a new unit with its own passport that names its predecessor in testing.

How does the passport get onto the battery?

Through the QR code. Article 77(3) requires the passport to be accessible through the QR code under Article 13(6), which links to a unique identifier. The economic operator placing the battery on the market assigns that identifier. Both must comply with ISO/IEC 15459-1 to -6 or equivalent standards. The code is printed or engraved visibly, legibly and indelibly on the battery, or on packaging and accompanying documents where that is not possible (Art. 13(7)).

BatteryPass creates a GS1 Digital Link from the GTIN and serial number for every unit, signs every published passport version and provides QR codes for label printing in testing. Our example battery passport shows what a published passport looks like.

Then there is the EU's digital product passport registry: since the amendment by the Ecodesign Regulation, the economic operator uploads the unique identifier to that registry (Art. 77(10)). Implementing Regulation (EU) 2026/1778 sets out how the registry works; only economic operators whose identity has been checked under its Article 4, for example with a qualified electronic seal, may record passports there. Submission from BatteryPass to the registry is planned planned.

What is still open?

When we checked in October 2026, these were still missing from the Official Journal:

• the implementing act on legitimate interest (Art. 77(9)), whose deadline passed on 18 August 2026;
• the acts on the method and format of the carbon footprint (Art. 7(1)); until then the carbon footprint fields stay empty;
• the minimum values for performance and durability (Art. 10(5));
• the method for recycled content (Art. 8(1)).

BatteryPass marks fields that only become mandatory with a future act as "later required", not as missing; the product page explains the requirement status per field.

How do you prepare now?

Most of the data already exists in data sheets, technical documentation, ERP exports and with suppliers. The work is to bring it together and review it.

1. Classify products. Decide per model above 2 kWh what is placed on the market as one battery (for UPS, see Industrial batteries).
2. Clarify roles. Who places on the market, and who acts on whose behalf?
3. Collect model data. Match Annex XIII, points 1 and 2, against your Article 10 documentation and data sheets.
4. Ask suppliers. Composition, critical raw materials and hazardous substances usually come from the cell supplier.
5. Decide identifier and label. Plan the QR code into the rating plate and label printing.
6. Open up BMS data. Clarify how Annex VII data gets from the device into the passport.
7. Organise review. Decide who enters values and who approves them.
8. Secure availability. The passport must stay reachable without you.

How to get from spreadsheets and ERP exports to a reviewed passport is described in From Excel and ERP exports to a reviewed battery passport. More about what we offer is on Stationary storage and Importers.