# Industrial batteries over 2 kWh: which units need a passport > Forklifts, UPS, telecom, grid storage, machinery: which industrial batteries need a battery passport from 18 February 2027 and how to check. [Industry](https://kabin.sh/en/blog/category/industry) # Industrial batteries over 2 kWh: which units need a passport Forklifts, UPS, telecom, grid storage, machinery: which industrial batteries need a battery passport from 18 February 2027 and how to check. By [BatteryPass-Redaktion](https://kabin.sh/en/about#batterypass-team)Published: 25 October 2026Updated: 25 October 2026Facts checked: 25 October 202618 min read ## In short From 18 February 2027, every industrial battery above 2 kWh placed on the EU market or put into service needs its own battery passport. That covers far more than home storage: forklift traction batteries, UPS and telecom back-up, grid-scale storage and batteries in machinery. What decides it is the category, the capacity and what counts as one battery. ## Key facts - Passport obligation for industrial batteries Capacity greater than 2 kWh, from 18 February 2027; exactly 2 kWh is not covered [Source](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_77) - What an industrial battery is Designed for industrial uses, intended for them after preparation for repurposing or repurposing, or above 5 kg and not an EV, LMT or SLI battery [Source](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_3) - Traction off the road Traction batteries for rail, waterborne and aviation transport and off-road machinery remain industrial batteries [Source](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#rct_15) - Several small units If they form one system with a common BMS, the combined capacity counts [Source](https://single-market-economy.ec.europa.eu/single-market/digital-product-passport/eu-digital-product-passport-faq-batteries_en) - BMS data under Annex VII Required for stationary battery energy storage systems, not for every industrial battery [Source](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_14) - Batteries with external storage Need a passport above 2 kWh; no minimum values under Art. 10(2), no recycled content requirements under Art. 8 [Source](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_10) From 18 February 2027, every industrial battery with a capacity greater than 2 kWh that is placed on the EU market or put into service needs its own battery passport (Article 77(1) of Regulation (EU) 2023/1542). That includes forklift traction batteries, UPS and telecom back-up, grid-scale storage and the traction batteries of trains. Whether a given unit needs a passport comes down to three questions: is it an industrial battery, is it above 2 kWh, and what exactly is the one battery being placed on the market? This article works through those questions for applications beyond home storage. Our [battery passport guide](https://kabin.sh/en/battery-passport) covers content, deadlines and responsibilities; the specifics of home, commercial and grid-scale storage are in [Battery passport for stationary storage](https://kabin.sh/en/blog/battery-passport-stationary-storage). ## What is an industrial battery under the Battery Regulation? Article 3(1), point 13, offers three routes into the category. An [industrial battery](https://kabin.sh/en/battery-passport/glossary#industrial-battery) is a battery that 1. is specifically designed for industrial uses, 2. is intended for industrial uses after preparation for repurposing or repurposing, or 3. weighs more than 5 kg and is neither an electric vehicle, an LMT nor an SLI battery. The third route is a catch-all: any battery above 5 kg that fits no other category is an industrial battery. A light battery is not automatically a portable battery, either. Only a battery that is sealed, weighs 5 kg or less and is not designed specifically for industrial use counts as portable (point 9). Recital 15 gives examples: batteries for industrial activities, communication infrastructure, agricultural activities and the generation and distribution of electric energy. Batteries used for traction in rail, waterborne and aviation transport or in off-road machinery expressly remain industrial batteries, as do batteries for energy storage in private or domestic environments. Recitals create no obligations of their own, but they show how the legislator reads the definition. The Regulation also covers batteries built into other products (Art. 1(3)), and chemistry plays no role: a lead-acid forklift battery is as much an industrial battery as a lithium-ion storage system. ## Is a forklift battery an industrial battery? As a rule, yes. An electric vehicle battery under the Regulation provides traction for a vehicle of category L and weighs more than 25 kg, or provides traction for a vehicle of category M, N or O under Regulation (EU) 2018/858 (Art. 3(1), point 14). That Regulation applies to motor vehicles intended to be used on public roads (its Art. 2(1)). A forklift in a warehouse or factory is not one of them, and recital 15 places traction batteries for off-road machinery among industrial batteries. So a forklift's traction battery placed on the market from the start date needs a passport as soon as it is above 2 kWh. That threshold is easily passed: 48 V and 625 Ah come to 30 kWh. Two borderline cases are worth knowing: - **Work vehicles with type-approval.** For vehicles used principally on construction sites, in quarries, ports or airports, and for certain self-propelled working machines, the manufacturer may apply for type-approval under Regulation (EU) 2018/858 (Art. 2(3)). If such a vehicle is approved as category M or N, its traction battery is an electric vehicle battery, and the passport applies regardless of capacity. - **Agricultural and forestry vehicles.** Regulation (EU) 2018/858 does not apply to them (Art. 2(2)(a)). The traction battery of an electric tractor is therefore not an electric vehicle battery but an industrial battery. When in doubt, the vehicle's approval decides. Many forklift batteries have no BMS; see below for what that means. ## How do you read the 2 kWh threshold? Article 77(1) requires a passport for industrial batteries “with a capacity greater than 2 kWh”. A battery of exactly 2 kWh is not covered. From the start date it still needs a QR code that leads to the declaration of conformity and the other mandatory information (Art. 13(6)(b)). The threshold is stated in kWh, an amount of energy. Elsewhere the Regulation works in ampere-hours: Annex IV defines rated capacity as the ampere-hours that can be withdrawn from a fully charged battery under reference conditions, and Annex XIII, point 1(g), asks for the rated capacity “in Ah”. The Regulation does not prescribe how to get from ampere-hours to kWh. In physical terms, energy is capacity multiplied by nominal voltage. The arithmetic is no legal assessment, but it shows where things get tight: | Nominal voltage | Capacity | Energy | Above 2 kWh? | | --------------- | -------- | --------- | --------------- | | 12 V | 100 Ah | 1.2 kWh | No | | 25.6 V | 100 Ah | 2.56 kWh | Yes | | 51.2 V | 39 Ah | 1.997 kWh | No, just below | | 51.2 V | 40 Ah | 2.048 kWh | Yes, just above | | 48 V | 625 Ah | 30 kWh | Yes | Worked examples: energy = capacity × nominal voltage In borderline cases, use the energy value you declare in the data sheet and technical documentation, and record how you determined it. If the data sheet rounds to “2 kWh”, the unrounded value counts: 2.048 kWh is more than 2 kWh. The threshold also triggers the performance documentation (Art. 10(1)), the carbon footprint declaration (Art. 7) and the recycled content rules (Art. 8). ## Do several small units count as one battery? It depends on what the finished battery is. The Commission answers this in its battery passport FAQ, which is not legally binding but shows its reading. The passport applies to the finished, safely working battery that can deliver electrical energy; it may contain several cells, modules or packs (FAQ 3.1). If 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 they are complete, independently functioning batteries, each is considered separately (FAQ 3.2). For the threshold, this means (FAQ 3.3): - **Independent units below 2 kWh** are assessed individually. Four self-contained batteries of 1.8 kWh each need no passport, even if they sit side by side in one cabinet. - **Units of one integrated system** with common components form one battery, and the combined capacity counts. Six modules of 1.5 kWh each on a common BMS are one 9 kWh battery and need a passport. The Commission stresses that this is decided case by case. How to draw the line between module, pack and container, and how to record the decision, is covered in [Module, pack or container](https://kabin.sh/en/blog/module-pack-or-container-battery-passport). ## Which products need a passport, and which do not? The overview below classifies typical products by the wording of the Regulation and the Commission's FAQ. It does not replace a case-by-case assessment; it reflects our check on 25 October 2026. | Your product | Category | Passport from 2027 | Notes | | -------------------------------------------------------------------- | ----------------------------------------------------------------------- | --------------------------------- | ---------------------------------------------------------- | | Traction battery of a forklift or warehouse vehicle | Industrial battery (off-road machinery) | Yes, if above 2 kWh | Not stationary storage; Art. 14 BMS data not required | | Traction battery of an electric van approved as category N | Electric vehicle battery | Yes, no capacity threshold | Check the category in the vehicle approval | | Traction battery of an electric tractor | Industrial battery | Yes, if above 2 kWh | Regulation (EU) 2018/858 does not apply to tractors | | UPS with a battery cabinet | Industrial battery; whether also stationary storage depends on the case | Yes, if the system is above 2 kWh | With a common BMS, the combined capacity counts | | Commercial or grid-scale storage (BESS) | Stationary battery energy storage system | Yes | Annex VII BMS data already required | | Battery with exclusively external storage | Industrial battery with external storage | Yes, if above 2 kWh | No minimum values, no recycled content requirements | | Traction battery of a ship or rail vehicle | Industrial battery | Yes, if above 2 kWh | Starter batteries on board are SLI batteries | | Starter battery of a construction machine | SLI battery | No | QR code from the start date | | Industrial battery of exactly 2 kWh | Industrial battery | No | QR code with mandatory information | | Repurposed EV battery used as commercial storage | Industrial battery (stationary storage) | Yes, a new passport | Linked to the original battery's passport, if there is one | | Imported machine with a built-in battery above 2 kWh | Depends on the battery, usually industrial | Yes | Usually the importer is responsible | | Battery in equipment for specifically military purposes or for space | Outside the scope (Art. 1(5)) | No | | Typical products, category and passport obligation A special case: under Article 1(6) of the consolidated text, Chapters III (labelling) and IX (battery passport) do not apply to equipment specifically designed for the safety of nuclear installations. ## What applies to UPS, telecom and stationary storage? Batteries at mobile phone masts and other telecom sites are usually industrial batteries; recital 15 names communication infrastructure expressly. For a UPS the category is equally clear, but a second question remains open: is the battery also a [stationary battery energy storage system](https://kabin.sh/en/battery-passport/glossary#stationary-battery-energy-storage-system)? Article 3(1), point 15, defines such a system as an industrial battery with internal storage that is specifically designed to store energy from and deliver it to the grid, or to store energy for and deliver it to end-users. A UPS stores energy from the grid and supplies the connected loads during an outage. The Regulation does not say expressly whether that counts as “storing for and delivering to end-users”; it depends on the case. The answer matters: for stationary systems, Article 14(1) already requires the BMS to hold up-to-date data on state of health and expected lifetime under Annex VII. If your UPS's BMS records those values anyway, the stricter classification costs little. Either way, record your reasoning. Commercial and grid-scale storage systems are stationary systems under point 15; the Article 14 BMS duties have applied to them since 18 August 2024. Details: [stationary storage](https://kabin.sh/en/blog/battery-passport-stationary-storage). ## What is different for batteries with external storage? A battery with external storage is specifically designed to have its energy stored exclusively in one or more attached external devices (Art. 3(1), point 8). The Regulation names no technology; the obvious candidates are systems whose energy-storing medium sits in attached tanks, such as redox flow batteries. Check a specific system against the definition. There is no exemption from the passport: Article 77(1) covers every industrial battery above 2 kWh. Several other obligations, however, do not apply or apply later. | Obligation | Industrial battery above 2 kWh | With exclusively external storage | | ------------------------------------------------------ | ------------------------------------------------------------------------------------- | ------------------------------------------------------------------- | | Battery passport (Art. 77(1)) | From 18 February 2027 | From 18 February 2027 | | Documentation of performance values (Art. 10(1)) | Already applies | Already applies | | Minimum performance and durability values (Art. 10(2)) | From 18 August 2027 or 18 months after the delegated act, whichever is later | Does not apply | | Carbon footprint declaration (Art. 7(1)) | 18 months after the acts still missing; the fixed date of 18 February 2026 has passed | 2030 at the earliest; method and format are due by 18 February 2029 | | Recycled content (Art. 8) | Documentation from 18 August 2028 at the earliest, minimum shares from 18 August 2031 | Does not apply | | Annex VII BMS data (Art. 14(1)) | Only for stationary battery energy storage systems | Does not apply, as a stationary system requires internal storage | Industrial batteries above 2 kWh with and without external storage The Commission confirms in FAQ 7.8 that recycled content reporting does not apply to batteries with external storage only. All deadlines are in our [timeline](https://kabin.sh/en/battery-passport/timeline). ## What goes into the passport of an industrial battery that is not stationary storage? In principle the same as for any battery with a passport: model data under Annex XIII, points 1 to 3, and data on the individual battery under point 4. Article 77(2) adds a limit, though: the information is included “to the extent applicable to the category or sub-category of the battery concerned”. Three differences matter. - **No Article 14 BMS duty.** Article 14(1) names only stationary battery energy storage systems, LMT and electric vehicle batteries. For a forklift battery, the Regulation requires no Annex VII data in the BMS. - **Cycle values only where they fit.** The Commission's guidance on data points (Version 2.0, non-binding) marks the expected lifetime in cycles, the round trip efficiency and the c-rate of the cycle-life test as “only applicable for some industrial batteries”. Annex IV, Part A, point 5, excludes non-cycle applications from the lifetime in cycles. - **No BMS, no state of health.** Under FAQ 8.5, the state of health requirements apply only where the battery has a BMS. The status and the performance values at placing on the market remain required. For usage data such as cycles and temperatures under Annex XIII, point 4(d), the Commission notes that the text provides no such exemption. Our field registry reflects this with three categories: stationary storage, industrial battery and industrial battery without BMS. The third is not a category of the Regulation. We take it from the Battery Pass consortium data model (version 2.0.1 on GEFEG GitLab), a public, non-binding model that, despite the similar name, is not our product BatteryPass. Besides EV and LMT, it keeps separate schemas for stationary and other industrial batteries above 2 kWh and for industrial batteries without a BMS. | Requirement | Stationary storage | Industrial battery | Industrial battery without BMS | | ----------------------------------------------------------- | ---------------------------- | ------------------ | -------------------------------------- | | Passport, status (Annex XIII, point 4(c)) | Required | Required | Required | | Performance values (Art. 10(1)) | Required | Required | Required | | Cycle life and round trip efficiency (point 1(j), (n), (p)) | Required | Optional | Optional | | State of health, e.g. remaining capacity (point 4(b)) | Required | Optional | Optional, not applicable without a BMS | | Time at extreme temperatures, deep discharges (point 4(d)) | Required (Annex VII, Part B) | Optional | Optional; record what is available | Where the three industrial categories of our field registry differ “Optional” means that neither the Regulation nor the guidance makes the value mandatory for every battery in that group. If you have the value and it fits the battery, it belongs in the passport. The mapping is our interpretation, reviewed with every registry version. These public fields are required by our registry for every industrial battery: | Data field | Section | Requirement | Legal basis | | ---------------------------------- | ----------------------------- | ----------- | ----------------------------------------------------------- | | Model identifier / SKU | Identification & product data | required | Annex XIII 1(a); Annex VI Part A(2); Art. 38(6) | | GTIN (GS1) | Identification & product data | required | Art. 77(3) unique identifier (ISO/IEC 15459) | | Battery category | Identification & product data | required | Annex XIII 1(a); Annex VI Part A(2) | | Manufacturer name | Identification & product data | required | Annex XIII 1(a); Annex VI Part A(1); Art. 38(7) | | Manufacturer address | Identification & product data | required | Annex XIII 1(a); Annex VI Part A(1); Art. 38(7) | | Responsible economic operator | Identification & product data | required | Art. 77(3)–(4) | | Battery mass (kg) | Identification & product data | required | Annex XIII 1(a); Annex VI Part A(5) | | Serial number | Identification & product data | required | Annex XIII 1(a); Annex VI Part A(2); Art. 38(6); Art. 77(3) | | Manufacturing date | Identification & product data | required | Annex XIII 1(a); Annex VI Part A(4) (month and year) | | Place of manufacture | Identification & product data | required | Annex XIII 1(a); Annex VI Part A(3) | | Battery chemistry | Materials & composition | required | Annex XIII 1(a), 1(b); Annex VI Part A(7) | | Critical raw materials (> 0.1 wt%) | Materials & composition | required | Annex XIII 1(a), 1(b); Annex VI Part A(10) | Data fields from field registry 0.5.0 · 22 more fields Every field with its legal basis and access tier is listed on [Data fields](https://kabin.sh/en/battery-passport/data-fields). Who may see which information is explained in [Access tiers in the battery passport](https://kabin.sh/en/blog/access-tiers-in-the-battery-passport). ## Who is responsible when the battery sits inside a machine? The passport attaches to the finished battery, not to the machine it powers (FAQ 3.5). Under Article 77(4), the economic operator placing the battery on the market is responsible. Three typical situations follow: - **You buy a finished battery in the EU and install it.** It has already been placed on the market, and whoever did so (the EU battery manufacturer or the importer) is responsible. FAQ 2.3 explains this with a vehicle manufacturer that merely installs a finished battery. - **You complete the battery yourself**, for example by combining bought-in modules with a BMS into one unit. Then you place the finished battery on the market and are responsible (FAQ 2.3 and 2.5). - **You import a machine with a built-in battery.** In the Commission's view, the battery is normally placed on the market when the product is imported, and the importer is responsible (FAQ 3.5). Beforehand, the importer checks among other things that the battery is marked under Article 13 (Art. 41). A company that builds a battery for its own use, such as storage for its own plant, puts it into service and counts as a manufacturer (Art. 3(1), points 18 and 33). Article 77(1) requires a passport in that case too. ## What applies when a vehicle battery gets a second life in industry? A battery intended for industrial uses after preparation for repurposing or repurposing is an industrial battery (Art. 3(1), point 13); repurposing can move it into a different category (Art. 45(2)). Whoever repurposes or remanufactures it and places it on the market again counts as its manufacturer (Art. 38(11)). The battery gets a new passport linked to the passport of the original battery or batteries (Art. 77(7)). The new passport is needed even if the original battery was placed on the market before the start date; the Commission confirms this for remanufacturing (FAQ 9.4). Some obligations fall away: the carbon footprint and recycled content rules do not apply if the battery had been placed on the market before the operation (Art. 7(5), 8(4)), and the performance rules do not apply if the operator shows that this happened before their deadlines (Art. 10(4)). Where an obligation does not apply, the passport needs no corresponding information (FAQ 9.4). If the original battery had no passport, there is nothing to link to; the Regulation does not address that case expressly. ## Do batteries already in use need a passport retrofitted? No. Article 77(1) is tied to placing on the market or putting into service from 18 February 2027. Placing on the market is the first making available on the Union market (Art. 3(1), point 16), and Article 77(1) speaks of “each” battery: it is the individual unit that counts. Recital 11 makes clear that batteries placed in stock by distributors before a requirement applies do not need to meet it. The battery of a forklift that has been running for years needs no passport. A replacement battery that you place on the market for the first time after the start date does. ## How do you prepare now? 1. **Classify products.** Per model: category, energy in kWh and how you calculated it, stationary or not, BMS or not. 2. **Define the one battery.** For cabinets, racks and containers, decide what is placed on the market as one battery. 3. **Clarify roles.** Who places the battery on the market: you, your supplier or the machine's importer? 4. **Collect data.** Start from your Article 10(1) performance documentation; composition and critical raw materials usually come from the cell or module supplier. 5. **Plan identifier and QR code.** One identifier per unit; the code goes on the battery or, where that is not possible, on packaging and accompanying documents (Art. 13(7)). 6. **Document the classification.** Keep reasoning and evidence per model for questions from market surveillance. In BatteryPass you set the category per model, and the field registry shows for stationary storage, industrial batteries and industrial batteries without a BMS which information is required, optional or required later in testing. Responsibility for the data stays with you. More about what we offer is on [Industrial batteries](https://kabin.sh/en/solutions/industrial-batteries); more answers are collected in our [battery passport FAQ](https://kabin.sh/en/battery-passport/faq). 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 ### Does a forklift traction battery need a battery passport? Yes, if it is above 2 kWh and placed on the market from 18 February 2027. A warehouse forklift is normally not a road vehicle of category L, M, N or O, so its traction battery is not an electric vehicle battery but an industrial battery (Art. 3(1), points 13 and 14, recital 15). ### 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. From 18 February 2027 the battery still needs a QR code leading to the declaration of conformity and the other mandatory information (Art. 13(6)). ### Our UPS is built from modules of 1.5 kWh each. Do we need a passport? If the modules depend on a common BMS and together form one working battery, the whole system is the battery and the combined capacity counts. Only independently functioning units are assessed individually (Commission FAQ 3.2 and 3.3). Record your classification in writing. ### Do industrial batteries without a BMS need a battery passport? Yes, if they are above 2 kWh. According to the Commission, state of health information does not apply without a BMS; the status and the performance values at placing on the market remain required, and the text gives no such exemption for usage data (FAQ 8.5). ### Who is responsible when we import machines with a built-in battery from outside the EU? Usually you, as the importer. The Commission considers that a finished battery in an imported product is normally placed on the market when the product is imported (FAQ 3.5). You may authorise others in writing to act for you, but you remain responsible for the passport data (Art. 77(4)). ### Do forklifts and storage systems already in use need a passport retrofitted? No. The obligation applies to batteries placed on the market or put into service from 18 February 2027. If an older battery is later repurposed or remanufactured and placed on the market again, it needs a new passport. ## 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 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, consolidated text, Article 1: Subject matter and scope](http://data.europa.eu/eli/reg/2023/1542/2026-08-13#art_1) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 4. [Regulation (EU) 2023/1542, recital 11: placing on the market and stock](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#rct_11) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 5. [Regulation (EU) 2023/1542, recital 15: battery categories](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#rct_15) · 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 38: Obligations of manufacturers](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_38) · 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 45: Repurposed and remanufactured batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#art_45) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 14. [Regulation (EU) 2023/1542, Annex IV: Electrochemical performance and durability](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng#anx_IV) · Publications Office of the European Union (EUR-Lex) · accessed 25 October 2026 15. [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 16. [Regulation (EU) 2018/858, Article 2: Scope of type-approval for vehicles of categories M, N and O](https://eur-lex.europa.eu/eli/reg/2018/858/oj/eng#art_2) · 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. [Commission guidance: Digital Batteries Passport, data points by category (Version 2.0, non-binding)](https://single-market-economy.ec.europa.eu/document/download/cd1e5e6c-4a4a-4b99-995a-49eb6916187e_en?filename=Digital+Batteries+Passport+-+data+point+by+category.pdf) · European Commission, DG GROW · accessed 25 October 2026 19. [Battery Pass consortium data model, JSON schemas version 2.0.1 (BatteryPass Data Model, GEFEG GitLab; non-binding)](https://git.gefeg.com/bp/BatteryPassDataModel) · Battery Pass consortium (GEFEG GitLab) · accessed 25 October 2026 This article 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. ## About the author BatteryPass-Redaktion BatteryPass product and regulation team We build BatteryPass and read the Battery Regulation, the Commission's guidance and the ERP vendors' documentation in the original for it. Drafts are written with AI assistance; people review every article, and every regulatory statement links to its primary source. 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) ## More articles - [GuideModule, pack or container: what counts as one battery for the passportCell, module, pack or container: what the Regulation and the Commission treat as one battery, and how to record your classification.25 October 2026](https://kabin.sh/en/blog/module-pack-or-container-battery-passport) - [RegulationBattery passport for stationary storage: what applies from 18 February 2027Which storage systems need a battery passport, what goes into it, who is responsible and what is still open, for home, C\&I and grid-scale storage.25 October 2026](https://kabin.sh/en/blog/battery-passport-stationary-storage) - [RegulationAccess tiers in the battery passport: public, legitimate interest, authoritiesWhat the Commission's draft on legitimate interest under Art. 77(9) sets out, what it leaves open and what manufacturers should do now about restricted data.25 October 2026](https://kabin.sh/en/blog/access-tiers-in-the-battery-passport)