Which batteries need a passport
The obligation in Article 77(1) covers three categories of batteries placed on the market or put into service from 18 February 2027:
- LMT batteries, for light means of transport such as e-bikes and e-scooters;
- industrial batteries with a capacity above 2 kWh, e.g. stationary energy storage and machinery batteries;
- electric vehicle batteries (EV).
Portable, starting (SLI) and industrial batteries up to 2 kWh do not need a passport. From the same date, however, every battery must carry a QR code (Article 13(6)). For these batteries the code gives access to the information that applies to them: label data, the EU declaration of conformity, the due diligence policy report and information on collecting waste batteries.
Not sure which category your battery falls into? The obligations survey shows the requirements for your company and product.
Who is responsible for the passport
The passport is created and maintained by the economic operator placing the battery on the market: usually the manufacturer, or the importer for batteries from outside the EU. It must ensure the information in the passport is accurate, complete and up to date. It may authorise another operator in writing to act on its behalf, for example a passport system provider (Article 77(4)).
Responsibility moves on through the battery's life cycle (Article 77(7)–(8)):
- a battery prepared for re-use, repurposed or remanufactured gets a new passport linked to the passport of the original battery, and the operator placing it on the market again is responsible for it;
- once a battery becomes waste, the obligations pass to the producer, the producer responsibility organisation or the selected waste management operator;
- the passport ceases to exist once the battery is recycled.
The passport must also remain available if the responsible operator ceases its activity in the EU (Article 78(e)).
What the passport contains: three access levels
Annex XIII splits the data by who may see it. Most of it describes the battery model, but part is kept separately for each individual battery.
For anyone who scans the code
- manufacturer and battery data from the label (Annex VI, Part A);
- material composition, hazardous substances and critical raw materials;
- carbon footprint and responsible sourcing;
- recycled content and share of renewable content;
- capacity, voltages, power, cycle life, energy efficiency and internal resistance;
- commercial warranty, labelling, the EU declaration of conformity and collection information.
For repair, remanufacturing and recycling
- detailed composition, including cathode, anode and electrolyte materials;
- part numbers and contact details of spare part sources;
- dismantling: exploded views, sequence, tools and cell layout;
- safety measures;
- for each individual battery: performance and durability, state of health, status and usage data.
For notified bodies and market surveillance
- results of test reports proving compliance with the Regulation and the acts adopted under it.
Exactly who has a legitimate interest, and to what extent they may access and use the data, is set by the Commission implementing act provided for in Article 77(9). The Regulation sets the criteria: assessing a battery's state and residual value, preparing it for re-use, remanufacturing or recycling, and limiting access to commercially sensitive information to the necessary minimum.
Model and individual battery
The battery passport contains information on the battery model and information specific to the individual battery, including information resulting from its use (Article 77(2)). In practice you describe shared data such as composition, carbon footprint and dismantling instructions once for the model. Each battery gets its own serial number, QR code and history: status, state of health (Article 14) and usage data such as the number of cycles, events and operating temperatures.
Usage data usually comes from the battery management system (BMS) or from a service provider. The passport system should therefore let them add it through an API, with control over who may enter and change which data (Article 78(f)).
QR code, identifier and the EU registry
The passport is accessed through a QR code linked to a unique identifier that the operator placing the battery on the market assigns to it. The QR code and the identifier must comply with ISO/IEC 15459 (parts 1–6) or equivalent standards (Article 77(3)). The code is printed or engraved on the battery visibly, legibly and indelibly, or on the packaging and accompanying documents where that is not possible (Article 13(7)).
One way to meet this requirement is a GTIN with a serial number encoded in the QR code as a GS1 Digital Link. GS1 is an issuing agency for identifiers under ISO/IEC 15459. See how a GS1 Digital Link QR code works.
Battery unique identifiers are stored in the EU digital product passport registry (ESPR Article 13(1)), which the Commission was due to set up by 19 July 2026. Registration rules are set by Implementing Regulation (EU) 2026/1778. Read more about the registry in the Digital Product Passport guide.
Technical requirements
Article 77(5) and Article 78 set the essential requirements for the system in which you keep passports:
- data based on open standards in an interoperable format, machine-readable, searchable and transferable without vendor lock-in;
- full interoperability with other digital passports required by EU ecodesign law;
- free access for consumers, economic operators and other relevant actors, according to their access rights;
- data stored by the responsible operator or an authorised operator, who may not sell or use it beyond the service provided;
- authentication, reliability and integrity of data, a high level of security and privacy, and fraud prevention.
How to prepare in 6 steps
- Determine the battery category. Check whether it is an LMT, EV or industrial battery and what its capacity is. This decides whether you need a passport or only a QR code.
- Collect model data. Datasheet, composition and substances, carbon footprint, recycled content, the EU declaration of conformity and collection information.
- Separate restricted data. Detailed composition, dismantling instructions, part numbers and safety measures must not appear on the public page.
- Assign identifiers. A model number such as a GTIN and a serial number for each battery, compliant with ISO/IEC 15459.
- Plan per-battery data. Decide who adds state of health, status and usage data, and how: the BMS, a service provider or a recycler.
- Choose a system and test the label code. Check data export and access rights, and scan a test print of the QR code before series production.
Battery passports in PassTrace
PassTrace always issues battery passports per individual battery. Data shared by a series sits on the model card, and every battery has a serial number, a GS1 Digital Link QR code and a status history. The form has nine sections matching Annex XIII, and the panel checks that all required fields are filled before publishing. Restricted data never appears on the public page.
See a sample battery passport or check what the battery form covers.
Frequently asked questions
When does the battery passport become mandatory?
From 18 February 2027 for LMT batteries, industrial batteries with a capacity above 2 kWh and electric vehicle batteries placed on the market or put into service (Article 77(1) of Regulation (EU) 2023/1542).
Does a portable or starter battery need a passport?
No. The passport only applies to LMT, EV and industrial batteries above 2 kWh. From 18 February 2027, however, every battery must carry a QR code with the information listed in Article 13(6).
Is all passport data public?
No. Public data includes performance parameters, material composition, carbon footprint and collection information. Detailed composition, dismantling information and per-battery data are only available to persons with a legitimate interest, and test results only to notified bodies, market surveillance authorities and the Commission.
Can I have another company keep the passport for me?
Yes. Article 77(4) lets you authorise another operator in writing to act on your behalf. That operator may not sell, re-use or process passport data beyond the service it provides (Article 78(d)).
What happens to the passport after remanufacturing or recycling?
A battery that is remanufactured, repurposed or prepared for re-use gets a new passport linked to the original one. Once the battery is recycled, the passport ceases to exist (Article 77(7)–(8)).
Which QR code meets the requirements?
The QR code and the battery identifier must comply with ISO/IEC 15459 or equivalent standards. A GS1 identifier, i.e. a GTIN with a serial number encoded as a GS1 Digital Link, is one option that does.
Sources
- Regulation (EU) 2023/1542 concerning batteries and waste batteries
- Regulation (EU) 2024/1781 (ESPR) on ecodesign requirements for sustainable products
- Implementing Regulation (EU) 2026/1778 on the digital product passport registry
This guide is based on the texts of acts published in the Official Journal of the EU and is not legal advice.