Battery Passport
Battery passport mandatory from 2027: what it contains, who it affects and how to comply on time
From 18 February 2027, certain batteries may no longer be placed on the EU market without a digital battery passport. For manufacturers, importers and every economic operator in the supply chain, this means one thing: implementation must start now. Data collection, process adaptation and system integration take far longer than most companies anticipate.
This article explains precisely what the battery passport contains, which batteries are in scope, what the key deadlines are and what your organisation needs to do operationally to comply on time.
The battery passport originates from the EU Battery Regulation and contains all product-specific information about a battery, which can be accessed via a QR code. The overall goal of the battery passport is to create absolute transparency, promote the circular economy, and thus ensure more sustainable and ethical battery production in Europe.
What is the battery passport?
The battery passport is a digital record assigned to an individual physical battery across its entire lifecycle. It is accessible via a QR code and holds structured information on the battery's origin, composition, carbon footprint, performance parameters and repair history.
The legal basis is Article 77 of Regulation (EU) 2023/1542, the EU Batteries Regulation, which entered into force on 17 August 2023. The battery passport is the first mandatory Digital Product Passport (DPP) under EU law and a direct template for similar requirements in other product categories under the Ecodesign for Sustainable Products Regulation, ESPR (EU) 2024/1781.
The battery passport is not a marketing document. It is a machine-readable, authority-accessible dataset with legal effect.
To be clear on scope: the battery passport is not a nameplate, which describes a model rather than an individual unit, and it is not a carbon footprint label, which is one data point within the passport rather than a standalone document. For a detailed comparison, see our article on the difference between the battery passport, nameplate and carbon footprint label.
Who is affected by its introduction?
Economic operators placing the battery on the EU market must provide the battery passport. The following products must carry the battery passport from February 18, 2027:
Electric vehicle (EV) batteries
Light-duty transport (LMT) batteries ≤ 25 kg
Industrial storage batteries > 5kg > 2 kWh
If you find yourself in this list, you should start looking into introducing the battery passport as soon as possible. The deadline is approaching, and implementation could take some time, as effective implementation of the battery passport means that processes will have to be adapted.
What data does the battery passport contain?
The content requirements are set out in Annex XIII of Regulation (EU) 2023/1542. The technical specifications will be defined by delegated acts from the European Commission. For EV batteries, this was originally due by February 2025; for industrial batteries, by August 2026. Companies should actively track the adoption of these acts, as they will determine the precise data formats and interfaces required.
In substantive terms, passport data falls into five areas.
1. Identification Unique battery ID, model designation, manufacturer, date and place of manufacture, and serial number.
2. Material data and raw material origin Chemical composition by cathode material, anode material and electrolyte, data on critical raw materials including lithium, cobalt, nickel and graphite, their geographical origin, and the share recovered from recycled material.
3. Carbon footprint Lifecycle-based carbon footprint value in kg CO2 equivalent, calculated in accordance with the methodology defined under the delegated acts for Art. 7. For EV batteries, this declaration has been mandatory since February 2025.
4. Performance and condition data State of health (SOH), rated capacity, charge cycles, depth of discharge, and power at 80 per cent and 20 per cent state of charge. These data points must be kept current throughout the battery's lifecycle.
5. Repair, disassembly and recycling information Disassembly instructions including tool requirements and safety warnings, repair and maintenance history, and information for recyclers to support efficient material recovery.
The DIN DKE SPEC 99100 standard provides a national implementation framework for these requirements and defines the structured attributes, approximately 100 data points in total. We are happy to provide the full attribute list on request.
Who can see what?
The battery passport is not fully public. Art. 77(2) together with Annex XIII establishes a tiered access model with three levels.
Tier 1: Publicly accessible information (Annex XIII, point 1) Available to anyone scanning the QR code: chemical composition, carbon footprint declaration under Art. 7, responsible sourcing data, recycled content, performance and capacity indicators, EU declaration of conformity, and end-of-life guidance.
Tier 2: Information for persons with a legitimate interest (Annex XIII, points 2 and 4) Accessible to recyclers, repair operators, second-life battery users and energy market participants: full material composition down to cathode and anode level, disassembly instructions with exploded diagrams, tool and safety specifications (point 2), as well as individual battery condition data including SOH, charge and discharge cycles, temperature records and status information (point 4).
Tier 3: Information for notified bodies, market surveillance authorities and the Commission only (Annex XIII, point 3) Test reports demonstrating compliance with the requirements of the Regulation.
This model protects commercially sensitive information such as formulations and supplier details while enabling the transparency the regulation requires towards regulators and authorised parties.
Why do we need the battery passport?
Promotion of the circular economy:
Currently, battery recycling is often inefficient because the exact chemical composition, state of health (SOH), and history of the battery are unknown. The passport provides recycling companies or operators of second-life applications with immediate, accurate data on material types, critical ingredients, and health status. This optimizes dismantling and recycling, increases the recovery rate of valuable raw materials, and maximizes battery life through reuse.
Transparency and ethical procurement:
Batteries contain critical raw materials such as lithium, cobalt, and nickel, the mining of which is often associated with environmental pollution and social risks. The passport creates the necessary traceability by documenting compliance with ethical standards and providing data on the carbon footprint of the entire production process. This enables manufacturers and consumers to make informed decisions and demonstrate compliance with ESG (environmental, social, governance) criteria to market surveillance authorities or the European Commission.
This description already makes it clear that different stakeholders need different information, which the battery passport must cover. It is essential to take this possibility into account when introducing the passport so that not all data is made accessible to everyone.
Timeline: what applies when?
| Date | Requirement |
|---|---|
| 17 August 2023 | Batteries Regulation (EU) 2023/1542 enters into force |
| 18 February 2025 | Carbon footprint declaration mandatory for EV batteries (Art. 7(1)(a)) |
| 18 August 2025 | Due diligence obligations for critical raw materials under Art. 48: cobalt, lithium, nickel, graphite |
| 18 February 2026 | Carbon footprint declaration mandatory for rechargeable industrial batteries above 2 kWh (Art. 7(1)(b)) |
| 18 February 2027 | Battery passport mandatory for EV, LMT and industrial batteries above 2 kWh (Art. 77(1)); QR code mandatory for all batteries (Art. 13(6)) |
| 18 August 2028 | Carbon footprint declaration mandatory for LMT batteries (Art. 7(1)(c)); recycled content documentation mandatory for industrial batteries above 2 kWh, EV and SLI batteries (Art. 8(1)) |
What are the consequences of non-compliance?
Art. 93 requires Member States to set penalties that are effective, proportionate and dissuasive. Specific amounts are determined nationally. The EU-wide consequence is clear: from 18 February 2027, a battery without a valid passport may not be placed on the EU market or put into service. In practice, this means loss of market access, recall of products already placed on the market, rejection at the EU border and reputational damage with customers and business partners.
Market surveillance authorities can verify compliance with a single QR-code scan, which substantially lowers the threshold for enforcement action.
Recommended actions
There are two different ways to implement the battery passport. You can either build a battery passport yourself or get support from a DPP provider.
You can read about the advantages of a DPP porvider here . However, we recommend that you note the following when implementing it:
Prepare the contents of the battery passport attributes as quickly as possible so that they can be easily transferred to the battery passport. You will need to request some of these from your suppliers.
Decide whether you want to develop the battery passport yourself or implement it with a DPP provider.
Clarify any questions you may have about the EU Battery Regulation or the battery passport.
To achieve long-term efficiency, you should view the implementation of the battery passport as a process optimization project. Set up new processes to create the battery passport automatically and with as little manual effort as possible.
If you have any further questions about the battery passport, please feel free to contact us or register for our free webinar. We will be happy to assist you with the implementation of the battery passport.
Want to see how SecIdent implements the battery passport in your specific production environment?
