Battery Passport

Battery Passport readiness begins with a controlled data map.

For each covered battery, the responsible economic operator needs to identify which Annex XIII fields apply, which data exist at battery-model level, which data must be associated with the individual battery, and the source and owner of each data field.

The mapping must also cover which information is public and which requires restricted access, which information changes during the battery lifecycle, and which evidence supports the information.

The Passport should be connected to, but not confused with, the battery technical documentation and EU Declaration of Conformity. Annex XIII expressly includes the EU Declaration of Conformity among the publicly accessible Passport information, while other technical evidence has restricted access.

Battery Passport requirements apply from 18 February 2027 to LMT batteries, industrial batteries with a capacity greater than 2 kWh and electric-vehicle batteries placed on the market or put into service.

The same date is relevant to the Article 13(6) QR-code requirement, but QR-code scope is broader than Battery Passport scope.

Passport implementation should therefore begin before the legal application date because battery classification, source-data collection, unique-identifier logic, access rights, technical architecture and lifecycle data governance need to be established in advance.

The Battery Passport does not apply to all five battery categories.

From 18 February 2027 it applies only to LMT batteries, industrial batteries with a capacity greater than 2 kWh, and electric-vehicle batteries.

A portable battery, SLI battery or industrial battery at or below the relevant 2 kWh threshold is not brought into the Battery Passport regime merely because Article 13 also requires a QR code.

Battery category and capacity therefore have to be confirmed before Passport implementation begins.

From 18 February 2027, Article 13(6) introduces QR-code requirements for batteries, but the information reached through the QR code depends on the battery category.

For a battery subject to Article 77, the QR code provides access to the Battery Passport.

For battery categories outside Article 77, the QR code can provide access to other information required by the Battery Regulation without creating a Battery Passport.

A QR code and a Battery Passport must therefore not be treated as synonymous.

For a covered battery, the QR code links to a unique identifier attributed by the economic operator placing the battery on the market.

Article 77 requires the QR code and unique identifier to follow the applicable ISO/IEC 15459-series standards or their legally recognised equivalent.

The Regulation also links the Battery Passport architecture to the product-passport registry framework established under Regulation (EU) 2024/1781. The unique identifier is therefore part of the wider EU digital-product-passport infrastructure.

Under Article 77(4), the economic operator placing the battery on the market is responsible for ensuring that the Battery Passport information is accurate, complete and up to date.

That operator may give another operator written authorisation to act on its behalf. Using an external Passport platform, software provider or data-service provider does not by itself transfer the legal responsibility assigned by the Regulation.

The responsible economic operator therefore needs both a compliant technical solution and a controlled data-governance process.

Annex XIII divides Battery Passport information by both data type and access level.

The Passport contains information relating to the battery model and information relating to the individual battery, including lifecycle and use data where applicable.

Model-level information can include, where applicable, battery identification, material composition and chemistry, carbon-footprint information, responsible-sourcing information, recycled-content information, performance parameters, marking information, the EU Declaration of Conformity and waste-prevention / management information.

Individual-battery information can include changing performance and durability values, state of health, battery status and relevant use data.

Not every field applies identically to every battery. Annex XIII expressly ties information to the category or sub-category concerned and to the underlying Battery Regulation requirements.

Battery Passport information is not one fully public data set.

Article 77 and Annex XIII distinguish several access layers: information accessible to the general public; information accessible to persons with a legitimate interest for specified purposes; information accessible to notified bodies, market-surveillance authorities and the European Commission; and individual-battery information subject to restricted legitimate-interest access.

Restricted information includes commercially and technically sensitive data such as detailed composition, dismantling information, specified test results and defined lifecycle information.

The Passport solution must therefore support access control rather than publishing the complete data set to every QR-code user.

The publicly accessible part of the Passport includes defined model-level information under Annex XIII.

Depending on applicability, this can include information such as battery and manufacturer identification, battery category, material composition and chemistry, carbon-footprint information, recycled-content information, relevant performance information, applicable marking information, the EU Declaration of Conformity, and specified waste-prevention and waste-management information.

The precise required data set must be mapped against Annex XIII and the Battery Regulation provisions applicable to the particular battery.

Annex XIII also protects information that is not intended for unrestricted public access.

Examples include detailed cathode, anode and electrolyte composition, component and spare-part information, dismantling instructions, safety measures, specified conformity test results, and state-of-health and other individual-battery lifecycle data.

Access depends on the legal access category and purpose. Commercially sensitive information should therefore not be exposed merely because the Passport is reached through a public QR code.

Article 78 establishes essential technical requirements for the Battery Passport.

Passport data must be based on open standards and provided in an interoperable, machine-readable, structured and searchable format through an open interoperable data-exchange network without vendor lock-in.

The technical design must support interoperability with other EU digital product passports, role-based access rights, data authentication, reliability and integrity, security and privacy, controlled rights to introduce, modify or update data, and continued availability even if the responsible economic operator ceases to exist or ceases activity in the Union.

The Regulation therefore requires more than attaching a static PDF to a QR code.

The Passport data may be stored by the responsible economic operator or by an operator authorised to act on its behalf.

Where an authorised service provider stores or processes the data, Article 78 restricts that provider from selling, re-using or processing the data beyond what is necessary to provide the relevant storage or processing service.

Selecting a Passport technology provider therefore requires both technical and data-governance assessment.

The Battery Passport is designed to follow the battery through relevant lifecycle changes.

Where a battery is prepared for re-use, repurposed or remanufactured, Article 77 transfers responsibility for Passport information to the economic operator placing that changed battery on the market or putting it into service. A new Battery Passport is created and linked to the Passport or Passports of the original battery or batteries.

Where the battery becomes a waste battery, responsibility for the relevant Passport obligations transfers as provided by Article 77 to the producer, the producer responsibility organisation where appointed, or the relevant waste-management operator.

The Battery Passport ceases to exist after the battery has been recycled.

The Battery Passport and an ESPR Digital Product Passport are related but legally distinct frameworks.

The Battery Passport is established directly by Regulation (EU) 2023/1542 for the defined battery categories.

Regulation (EU) 2024/1781 (ESPR) establishes the wider Digital Product Passport framework for products subject to product-specific ecodesign requirements.

The Battery Regulation requires technical interoperability with other EU digital product passports and now links the Battery Passport unique identifier to the ESPR registry framework. This technical integration does not make the Battery Passport and every ESPR DPP the same legal obligation.

The Battery Passport is a product-information and lifecycle-data obligation. It does not replace battery EPR.

National producer registration, authorised representation, collection and treatment arrangements, EPR contributions, waste-battery records and reporting continue as a separate compliance layer.

Some underlying product and material data may support both systems, but a Battery Passport is not an EPR report and national EPR reporting is not a Battery Passport.