Battery passport: which batteries need one in the EU, who makes it, and from when

A battery passport is an electronic record of one battery, opened by scanning the QR code on it (Art. 77(1)Regulation (EU) 2023/1542, Batteries RegulationArticle 77, paragraph 1Click opens the article on EUR-Lex., Art. 77(3)Regulation (EU) 2023/1542, Batteries RegulationArticle 77, paragraph 3Click opens the article on EUR-Lex.). From 18 February 2027 each e-bike or e-scooter battery, each industrial battery above 2 kWh and each electric vehicle battery placed on the EU market has to have one. The business that places the battery on the market makes it and keeps it up to date.

What applies now, and what waits

Which batteries need a passport

Art. 77(1)Regulation (EU) 2023/1542, Batteries RegulationArticle 77, paragraph 1Click opens the article on EUR-Lex. names three categories and no others:

A battery built into a product is covered, and so is one made to be built in (Art. 1(3)Regulation (EU) 2023/1542, Batteries RegulationArticle 1, paragraph 3Click opens the article on EUR-Lex.). An e-bike you sell carries a battery that needs a passport, and so does a replacement e-bike battery you sell on its own. A portable power station whose battery weighs more than 5 kg and has a capacity above 2 kWh, and that is not made for a vehicle, falls under the industrial definition; that is our reading of Art. 3(13)Regulation (EU) 2023/1542, Batteries RegulationArticle 3, point 13Click opens the article on EUR-Lex., and the Commission lists home storage batteries among those affected.

One battery or several. The passport belongs to the finished, working battery. Several packs that share a battery management system and work as one are one battery with one passport; packs that each work on their own are separate batteries, and the 2 kWh test is applied to each. Cells or modules imported to be assembled into a battery in the EU are components, and the one who completes the battery becomes the manufacturer. A cell or module sold ready for the end user to use, such as a do-it-yourself kit, is treated as a battery (Art. 1(4)Regulation (EU) 2023/1542, Batteries RegulationArticle 1, paragraph 4Click opens the article on EUR-Lex.; Commission FAQ for batteries, questions 3.1 to 3.4).

Which units. The duty covers each battery “placed on the market or put into service” from 18 February 2027, and placing on the market is the first making available in the EU (Art. 77(1)Regulation (EU) 2023/1542, Batteries RegulationArticle 77, paragraph 1Click opens the article on EUR-Lex., Art. 3(16)Regulation (EU) 2023/1542, Batteries RegulationArticle 3, point 16Click opens the article on EUR-Lex.). Our reading: a unit first supplied in the EU before that date needs no passport. A battery that is repurposed or remanufactured after that date gets a passport, even if the original was placed on the market earlier, and where the original had one, the new passport links to it (Art. 77(7)Regulation (EU) 2023/1542, Batteries RegulationArticle 77, paragraph 7Click opens the article on EUR-Lex.; Commission FAQ, question 9.4).

Who must make and keep the passport

The duty falls on “the economic operator placing the battery on the market” (Art. 77(3)Regulation (EU) 2023/1542, Batteries RegulationArticle 77, paragraph 3Click opens the article on EUR-Lex., Art. 77(4)Regulation (EU) 2023/1542, Batteries RegulationArticle 77, paragraph 4Click opens the article on EUR-Lex.). Placing on the market is the first making available in the EU (Art. 3(16)Regulation (EU) 2023/1542, Batteries RegulationArticle 3, point 16Click opens the article on EUR-Lex.). The Regulation does not list the operators for this duty; the definitions and the duties of each role give the answer:

The Commission states that the duty lies with the business placing the finished battery on the market, not with the suppliers of cells or modules. If a vehicle maker completes a battery, for example by adding the battery management system, the vehicle maker is the responsible operator; if it only installs a finished battery, the battery maker is (Commission battery passport page; Commission FAQ for batteries, questions 2.3 to 2.5). Written authorisation does not move the responsibility (question 2.1).

When the battery becomes waste, responsibility passes to the producer, its producer responsibility organisation or the waste operator selected, and the passport ends when the battery is recycled (Art. 77(7)Regulation (EU) 2023/1542, Batteries RegulationArticle 77, paragraph 7Click opens the article on EUR-Lex., Art. 77(8)Regulation (EU) 2023/1542, Batteries RegulationArticle 77, paragraph 8Click opens the article on EUR-Lex.). The producer duties of registration and take-back are a separate set, covered in the EU Battery Regulation. The difference between the authorised representative of the manufacturer and the authorised representative for extended producer responsibility is explained on EU authorised representative.

What the passport holds, and who can open which part

The passport holds data about the battery model and data about each battery, in four parts that differ in who may open them (Art. 77(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 77, paragraph 2Click opens the article on EUR-Lex., Annex XIII):

Who has a legitimate interest. The Regulation gives the purposes. For the model data it is dismantling the battery, with its safety measures, and the detailed composition, where repairers, remanufacturers, second-life operators and recyclers need them for their work. For the data of an individual battery it is the buyer, or someone acting for the buyer, making the battery available to independent energy aggregators or energy market participants (Art. 77(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 77, paragraph 2Click opens the article on EUR-Lex.). Which persons count, and how far they may download, share, publish and re-use the data, is for the implementing act of Art. 77(9)Regulation (EU) 2023/1542, Batteries RegulationArticle 77, paragraph 9Click opens the article on EUR-Lex., which is to weigh the need to assess the battery’s status and residual value, the need for reuse, repurposing, remanufacturing and recycling, and the protection of commercially sensitive data.

What the Commission says need not be shown on 18 February 2027. Its guidance, which it states is not an authoritative reading, marks the carbon footprint declaration and label, the recycled content shares and the responsible-sourcing entry as not to be filled in at that date. The first waits for a format in an implementing act, the second for Art. 8Regulation (EU) 2023/1542, Batteries RegulationArticle 8Click opens the article on EUR-Lex. and its delegated act, and the third for 18 August 2027 (Art. 48(1)Regulation (EU) 2023/1542, Batteries RegulationArticle 48, paragraph 1Click opens the article on EUR-Lex.). An entry that repeats another is not filled twice, and some entries apply to one category only: the capacity threshold for exhaustion is for electric vehicle batteries. Data that comes from use, such as cycle counts, may be empty when a new battery is first placed on the market (Commission guidance; Commission FAQ for batteries, questions 7.1, 7.2, 8.6). Information that is not language-neutral goes in the language end users understand, as the EU country where the battery is sold decides (question 7.4).

How the QR code and the unique identifier work

From 18 February 2027 all batteries carry a QR code. For an LMT battery, an industrial battery above 2 kWh and an electric vehicle battery it leads to the battery passport; for other batteries it leads to the label information, the declaration of conformity, the due diligence report and the waste information (Art. 13(6)Regulation (EU) 2023/1542, Batteries RegulationArticle 13, paragraph 6Click opens the article on EUR-Lex.). The code links to a unique identifier that the business placing the battery on the market gives it: “a unique string of characters for the identification of batteries that also enables a web link to the battery passport” (Art. 77(3)Regulation (EU) 2023/1542, Batteries RegulationArticle 77, paragraph 3Click opens the article on EUR-Lex., Art. 3(66)Regulation (EU) 2023/1542, Batteries RegulationArticle 3, point 66Click opens the article on EUR-Lex.).

• Standard. The QR code and the unique identifier follow ISO/IEC 15459-1 to 15459-6, or their equivalent (Art. 77(3)Regulation (EU) 2023/1542, Batteries RegulationArticle 77, paragraph 3Click opens the article on EUR-Lex.). The Commission may replace these standards by delegated act; none had been found by 6 October 2026.
• Look. The code is in high contrast to its background and big enough for a common QR reader, such as the one in a phone (Annex VI Part C).
• Place. It is printed or engraved on the battery, visibly, legibly and indelibly. Where that is not possible or not warranted given the nature and size of the battery, it goes on the packaging and the documents that come with the battery (Art. 13(7)Regulation (EU) 2023/1542, Batteries RegulationArticle 13, paragraph 7Click opens the article on EUR-Lex.).
• Who creates the identifier. The Commission says an operator can create it itself, following the options in the standards, or buy it from a commercial service (Commission FAQ for batteries, question 5.2). Two of the six harmonised standards cited in July 2026 cover this: EN 18219 for unique identifiers and EN 18220 for data carriers (Implementing Decision (EU) 2026/1736, Annex).
• Resellers. A distributor does not make the code, but it may not make a battery available that lacks the markings of Art. 13Regulation (EU) 2023/1542, Batteries RegulationArticle 13Click opens the article on EUR-Lex., and the QR code is one of them (Art. 42(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 42, paragraph 2Click opens the article on EUR-Lex., point (b), Art. 42(3)Regulation (EU) 2023/1542, Batteries RegulationArticle 42, paragraph 3Click opens the article on EUR-Lex.).

How the battery passport connects to the ESPR digital product passport

The battery passport is the one the Batteries Regulation sets itself. It does not wait for an ecodesign delegated act. It plugs into the system of Regulation (EU) 2024/1781Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationThe whole regulationClick opens the law on the EU Publications Office., the Ecodesign for Sustainable Products Regulation (ESPR), at five points. The general framework is in digital product passport.

1. Interoperability. The battery passport must be fully interoperable with other digital product passports required by Union law on ecodesign, in technical, semantic and organisational terms (Art. 78Regulation (EU) 2023/1542, Batteries RegulationArticle 78Click opens the article on EUR-Lex., point (a)).
2. The registry. The ESPR added the duty to upload the battery’s unique identifier to the ESPR registry, and its registry stores those identifiers (Art. 78Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 78Click opens the article on EUR-Lex., Art. 13(1)Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationArticle 13, paragraph 1Click opens the article on EUR-Lex., Art. 77(10)Regulation (EU) 2023/1542, Batteries RegulationArticle 77, paragraph 10Click opens the article on EUR-Lex.).
3. The registry act. Implementing Regulation (EU) 2026/1778 covers batteries under Art. 77Regulation (EU) 2023/1542, Batteries RegulationArticle 77Click opens the article on EUR-Lex. of the Batteries Regulation and counts the battery passport as a digital product passport (its Art. 1(1) and Art. 2Regulation (EU) 2023/1542, Batteries RegulationThe whole regulationClick opens the law on the EU Publications Office.). The operator registers through the web interface or the API; the registry reads the passport, checks that the data fit the required model, and returns a unique registration identifier; the operator can download a proof of registration that stays available for 90 calendar days from its creation (its Art. 8 and 9).
4. Where the data sits. The registry holds the identifiers and the registration data, not the whole passport. The business that placed the battery on the market, or the one it authorises, stores the passport and decides who opens what, within the access rights of Annex XIII (Art. 78Regulation (EU) 2023/1542, Batteries RegulationArticle 78Click opens the article on EUR-Lex., points (c) and (f); Commission FAQ for batteries, question 6.5).
5. Standards. Six of the eight harmonised standards for digital product passports are cited in the Official Journal. The Commission’s battery passport page counts them among the standards for the battery passport; the decision itself names only Regulation (EU) 2024/1781Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationThe whole regulationClick opens the law on the EU Publications Office. (Implementing Decision (EU) 2026/1736).

What is adopted, and what is not, on 6 October 2026

What happens if you do nothing

From 18 February 2027 a battery of the three categories without a passport does not meet Art. 77(1)Regulation (EU) 2023/1542, Batteries RegulationArticle 77, paragraph 1Click opens the article on EUR-Lex.. The Regulation sets no fine: each EU country lays down penalties that are effective, proportionate and dissuasive (Art. 93Regulation (EU) 2023/1542, Batteries RegulationArticle 93Click opens the article on EUR-Lex.). It does not say which procedure a missing passport falls under. The list of formal non-compliances, which authorities order put right, names the CE marking, the declaration of conformity, the technical documentation and the contact details; the passport is not on it by name, but point (g) also covers “any other administrative requirement provided for in Article 38Regulation (EU) 2023/1542, Batteries RegulationThe whole regulationClick opens the law on the EU Publications Office. or 41”, and Art. 38(1)Regulation (EU) 2023/1542, Batteries RegulationArticle 38, paragraph 1Click opens the article on EUR-Lex. requires the Art. 13Regulation (EU) 2023/1542, Batteries RegulationArticle 13Click opens the article on EUR-Lex. marking, QR code included, so a missing QR code may fall under it (Art. 83Regulation (EU) 2023/1542, Batteries RegulationArticle 83Click opens the article on EUR-Lex., Art. 38(1)Regulation (EU) 2023/1542, Batteries RegulationArticle 38, paragraph 1Click opens the article on EUR-Lex.). Where an authority evaluates a battery it has reason to believe presents a risk and finds it non-compliant, it requires corrective action and, if none follows, restricts or prohibits the battery being made available, or has it withdrawn or recalled (Art. 79Regulation (EU) 2023/1542, Batteries RegulationArticle 79Click opens the article on EUR-Lex., paragraphs 1, 4 and 8).

Two practical stops come earlier. You cannot register a battery’s identifier without being a verified operator, and a verification lasts at most three years (Implementing Regulation (EU) 2026/1778, Art. 4(3) and 4(4)). And for batteries placed on the market from 18 February 2027, a reseller may not make available a battery lacking the QR code (Art. 42(2)Regulation (EU) 2023/1542, Batteries RegulationArticle 42, paragraph 2Click opens the article on EUR-Lex., point (b), Art. 42(3)Regulation (EU) 2023/1542, Batteries RegulationArticle 42, paragraph 3Click opens the article on EUR-Lex., Art. 13(6)Regulation (EU) 2023/1542, Batteries RegulationArticle 13, paragraph 6Click opens the article on EUR-Lex.), so a reseller will ask the maker for it.

What you can skip for now

What the law leaves open

• A seller outside the EU shipping straight to an EU buyer, with no EU importer. The duty is on “the economic operator placing the battery on the market” (Art. 77(4)Regulation (EU) 2023/1542, Batteries RegulationArticle 77, paragraph 4Click opens the article on EUR-Lex.). An online offer aimed at EU end users counts as making available on the EU market (Art. 6Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 6Click opens the article on EUR-Lex.), and the definition of economic operator covers placing batteries on the market “including online” (Art. 3(22)Regulation (EU) 2023/1542, Batteries RegulationArticle 3, point 22Click opens the article on EUR-Lex.). The registry rules let a business that is not established in the EU become a verified operator (Implementing Regulation (EU) 2026/1778, Art. 4(2), point (b)). Neither the Regulation nor the Commission’s FAQ says outright that such a seller is the operator who must make the passport. Meanwhile, a distributor in the EU that resells the battery will ask for the QR code.
• Who has a legitimate interest. Until the act of Art. 77(9)Regulation (EU) 2023/1542, Batteries RegulationArticle 77, paragraph 9Click opens the article on EUR-Lex. is adopted, the law does not say which repairers, recyclers or energy parties may open points 2 and 4, or how much they may download and re-use. You can build the four parts now and wait for the list.
• Units placed before 18 February 2027. Neither Art. 77Regulation (EU) 2023/1542, Batteries RegulationArticle 77Click opens the article on EUR-Lex. nor Art. 96Regulation (EU) 2023/1542, Batteries RegulationArticle 96Click opens the article on EUR-Lex. has a rule for stock. Our reading is that a unit first made available before that date needs no passport; no official text confirms it.
• Whether the standards give a presumption of conformity for the battery passport. Art. 15(3)Regulation (EU) 2023/1542, Batteries RegulationArticle 15, paragraph 3Click opens the article on EUR-Lex. gives batteries that follow harmonised standards cited in the Official Journal a presumption of conformity with Art. 78Regulation (EU) 2023/1542, Batteries RegulationArticle 78Click opens the article on EUR-Lex.. The decision that cited six passport standards names only Regulation (EU) 2024/1781Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationThe whole regulationClick opens the law on the EU Publications Office., so it does not itself say that the presumption of the Batteries Regulation applies to them.