Short answerThe battery passport is an item-level electronic record required by the EU Batteries Regulation (EU) 2023/1542 from 18 February 2027 for every electric vehicle battery, light means of transport battery and industrial battery above 2 kWh. It holds composition, carbon footprint, recycled content, due diligence and performance data, and is accessed through a QR code.
Key takeaways
- The battery passport becomes mandatory on 18 February 2027 for EV batteries, LMT batteries and industrial batteries with a capacity above 2 kWh.
- Each passport is linked to one individual battery through a unique identifier, which makes it the first item-level product passport at scale in the EU.
- Minimum recycled content shares apply from 2031: 16% cobalt, 85% lead, 6% lithium and 6% nickel, with documentation duties starting earlier.
The battery passport is an item-level record with fixed deadlines
The battery passport is the first EU product passport with a confirmed application date. Article 77 of the Batteries Regulation requires it from 18 February 2027 for three categories: electric vehicle batteries, light means of transport (LMT) batteries such as e-bike and e-scooter packs, and industrial batteries with a capacity above 2 kWh. Portable and SLI batteries are excluded.
Granularity is the defining feature. Each passport relates to one physical battery, identified by a unique identifier, which means serialisation must reach the end of the production line. The passport also follows the battery through its life: when a battery is repaired, repurposed or remanufactured, the operator that places it back on the market becomes responsible for a new passport linked to the original. The general concept is described in the Digital Product Passport overview.
Annex XIII defines three access tiers of data
The content of the passport sits in Annex XIII of the regulation and splits by audience.
| Access tier | Example data fields |
|---|---|
| Public | Manufacturer, battery category, model, weight, capacity, chemistry, hazardous substances, critical raw materials, carbon footprint, recycled content share, renewable content share, expected lifetime |
| Persons with a legitimate interest (repairers, recyclers, second-life operators) | Detailed composition, part numbers, dismantling and safety information, contact points for spare parts |
| Authorities and the Commission | Test reports demonstrating compliance |
Some fields change over time. State of health, remaining capacity and usage data for EV and industrial batteries come from the battery management system and must be updated, which pushes the passport beyond a static record into an operational data feed.
Carbon footprint, due diligence and recycled content carry the heaviest effort
Three obligations feed the passport with data that most manufacturers do not yet hold in auditable form.
- Carbon footprint declaration: EV, rechargeable industrial and LMT batteries need a lifecycle carbon footprint per model and manufacturing plant, calculated using a Commission methodology set in delegated and implementing acts. Application dates are linked to the adoption of those acts, and as of October 2026 the methodology act for EV batteries had not yet been adopted, so the declaration date for each category remains open while the passport date of 18 February 2027 stands.
- Supply chain due diligence: operators above a turnover threshold must run due diligence on cobalt, lithium, nickel and natural graphite sourcing. A 2025 amendment, Regulation (EU) 2025/1561, postponed this obligation to 18 August 2027.
- Recycled content: documentation of recovered cobalt, lead, lithium and nickel precedes binding minimum shares from 2031 of 16% cobalt, 85% lead, 6% lithium and 6% nickel, rising further in 2036.
Each of these depends on supplier data at material and facility level. Collecting it follows the same patterns as EUDR traceability, with mass balance and chain-of-custody questions that need agreed rules early.
The QR code and the economic operator anchor responsibility
The economic operator that places the battery on the market carries legal responsibility for the passport. That is usually the manufacturer, importer or distributor that sells under its own name. It may delegate hosting to a service provider, but accuracy and availability stay with the operator, and the passport must remain accessible for the life of the battery and beyond, until it is recycled.
The passport is reached through a QR code printed or engraved on the battery. The Batteries Regulation separately requires QR codes on all batteries from 18 February 2027, linking to labelling and conformity information. Codes must stay legible across the battery's life, which affects material, placement and marking technology choices. Identifier and resolver design is covered in the DPP data architecture guide.
Start with the data model and the supplier contracts
The central insight is that the battery passport is a supply chain data project with a software component, and the binding constraint is supplier evidence. Platforms that host and serve passports are available from several providers. The scarce resource is verified data on materials, origin, carbon and recycled content.
A practical sequence for the remaining months before February 2027:
- Map every Annex XIII field to a source system and owner.
- Update supplier contracts to require material, origin and footprint data.
- Implement serialisation and marking on production lines.
- Select a passport hosting approach and test the access tiers.
- Run a pilot with one battery model before ramp-up.
A broader planning frame for other product groups sits in the DPP readiness roadmap.
Frequently asked questions
Which batteries need a battery passport?
Electric vehicle batteries, light means of transport batteries and industrial batteries with a capacity above 2 kWh need a passport from 18 February 2027. Portable batteries and starting, lighting and ignition batteries are outside the passport obligation, although they fall under other labelling and QR code rules.
Who creates the battery passport for a repurposed battery?
The economic operator that places a repaired, repurposed or remanufactured battery on the market becomes responsible for a new passport. That passport must link to the passport of the original battery, so the history of the cells and the pack remains traceable across lives.
Can a battery passport be hosted by a third party?
Yes. Economic operators may use a service provider to store and serve the passport data. Legal responsibility for accuracy, completeness and long-term availability remains with the economic operator, so contracts should cover data continuity if the provider ceases operations.