EU Battery Passport: Which Batteries Need One, What It Contains and When It Applies

Three of the five categories are covered, and only the industrial one has a capacity condition.

The passport, also called the battery pass or digital battery passport, is reached through a QR code, and the economic operator placing the battery on the market is responsible for it.

Articles 77 and 78 form Chapter IX of the EU Battery Regulation, which entered into force on 17 August 2023 and has applied since 18 February 2024.

The sections below map Article 77, paragraphs 1 to 10, against the Commission's FAQ for batteries.

They cover which batteries need a passport, who answers for it, what it holds and who reads it, how the EU registry links it, how it survives repurposing and ends at recycling, and the dated status of each pending act.

What Is the EU Battery Passport?

The EU battery passport is the electronic record of one individual battery that holds information on the battery model and on that specific battery, including information resulting from its use, as listed in Annex XIII of Regulation (EU) 2023/1542 (Article 77(2)). Each battery has its own passport, not each battery model.

Article 77(1) names the passport "an electronic record ('battery passport')". Chapter IX of the Regulation, titled "Digital battery passport", holds two articles: Article 77 sets the duty, the content, the identifier and the responsible operator, and Article 78 sets the essential requirements for the technical design and operation of the passport.

Annex XIII combines two kinds of information. Model information, such as general data on the battery, its composition and its test reports, is shared by every battery of the same model. Individual information, such as state of health, status and use data, belongs to one battery and changes over its life.

The Commission's FAQ for batteries, published by DG GROW as a first edition in September 2026, explains how Article 77 works in practice. The FAQ is non-binding guidance, so this page cites it by question number (for example FAQ 3.1) wherever a rule comes from the FAQ rather than the Regulation.

A Decentralised Electronic Record with Free Access

The battery passport is a decentralised data system that economic operators set up and maintain (recital 126 of Regulation (EU) 2023/1542). Article 77(6) adds that access to the information in the passport is regulated in accordance with the essential requirements laid down in Article 78.

Consumers, economic operators and other relevant actors access the passport free of charge, according to their access rights (Article 78(b)). The data follow open standards in an interoperable format, transferable through an open interoperable data exchange network without vendor lock-in, and are machine-readable, structured and searchable (Article 77(5)).

Storage lies with the responsible operator or with operators authorised to act on its behalf (Article 78(c)). An authorised operator may not sell, re-use or process the data beyond the service it provides (Article 78(d)). The passport stays available after the responsible operator ceases to exist or ceases its activity in the Union (Article 78(e)).

Battery Passport Data, Standards and Software

Three guides cover the battery passport in detail: the Annex XIII data and access groups, the standards and industry initiatives behind the format, and the software that operators use to issue and host passports. The table below lists each guide with the question it answers and its legal hook in Regulation (EU) 2023/1542.

Software choice does not move the legal duty. The Commission's FAQ (10.3) states that "The Batteries Regulation does not define or regulate 'solution providers'" and that commercial agreements govern that relationship. Article 77(4) keeps the economic operator placing the battery on the market in charge of the passport, whoever hosts it.

Need help issuing battery passports? Where the passport sits among the other duties is set out under how to comply with the EU Battery Regulation.

Which Batteries Need a Battery Passport?

Three of the five battery categories need a battery passport: every LMT battery, every electric vehicle battery and every industrial battery with a capacity greater than 2 kWh, while portable and SLI batteries do not (Article 77(1)).

The duty arises when such a battery is placed on the market or put into service in the EU.

The capacity condition "greater than 2 kWh" applies to industrial batteries only. Article 77(1) sets no capacity threshold for LMT batteries or electric vehicle batteries, so a small LMT battery needs a passport just as a large traction battery does. An industrial battery of exactly 2 kWh needs none, because the condition is "greater than".

The Commission names home storage batteries among the batteries affected by the passport. Home energy storage batteries are industrial batteries under recital 15, so a home storage battery with a capacity greater than 2 kWh needs a passport. The table below sets out the five categories of Article 1(3) against the passport duty.

The Finished Battery Rule: Cells, Modules, Packs and a Shared BMS

One passport attaches to one finished battery, which may contain several cells, modules or packs, and a traction battery normally includes its battery management system (BMS) (Commission FAQ 3.1). The finished battery, not each cell or module inside it, is the unit that carries the passport.

Packs that depend on a common BMS form one battery with one passport, while independent packs each need their own (FAQ 3.2). A storage installation of four packs on one shared BMS therefore carries one passport, and four packs that each run their own BMS carry four.

For the 2 kWh test of an industrial battery, an integrated system with common components counts at its combined capacity, while independent units are assessed individually (FAQ 3.3). Cells and modules supplied for assembly in the EU are not the finished battery, with one exception: batteries sold as DIY kits (FAQ 3.4).

Batteries That Carry Only the QR Code

Portable and SLI batteries need no passport, but from 18 February 2027 every battery carries a QR code under Article 13(6) of Regulation (EU) 2023/1542.

The code leads either to a passport or to a set of information, and how the Regulation sorts every battery into the five battery categories decides which of the two the QR code opens.

For a portable or SLI battery, the QR code gives access to the Article 13(6) information, which includes the due diligence report of Article 52(3). For an LMT battery, an electric vehicle battery or an industrial battery with a capacity greater than 2 kWh, the same code gives access to the battery passport.

From When the Battery Passport Applies

The battery passport applies from 18 February 2027 to each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market or put into service from that day (Article 77(1)). The date sits in the Regulation itself, not in a secondary act.

The same day brings two linked duties. The QR code becomes mandatory on all batteries (Article 13(6)), and each Member State must designate a national administrator for the EU registry under Article 7(1) of Implementing Regulation (EU) 2026/1778. Every other date sits on the EU Battery Regulation timeline.

One passport field follows a later date. The Commission's guidance requires the responsible-sourcing data point (DP 19) from August 2027, in line with the due diligence obligations that apply from 18 August 2027 under Article 48(1), as amended by Regulation (EU) 2025/1561.

Is the Battery Passport Postponed?

The battery passport is not postponed: as of 13 November 2026, no adopted act and no Commission proposal moves the 18 February 2027 date of Article 77(1). The Commission's battery passport page names 18 February 2027 as the start of the obligation and mentions no postponement.

The only amendment to Articles 77 and 78 and Annex XIII is Article 77(10), the registry duty inserted by Regulation (EU) 2024/1781. Regulation (EU) 2026/1738, which replaces Annex I, and Delegated Regulation (EU) 2026/1770 on Article 11(2) leave the passport untouched; each change is listed under Battery Regulation amendments.

The Commission proposal COM(2025) 981 of 10 December 2025 contains no change to the passport. It is pending: as of 13 November 2026, the procedure file 2025/0397(COD) shows the ENVI committee stage "Awaiting committee decision" and an indicative plenary date of 14 December 2026.

Who Is Responsible for the Battery Passport?

The economic operator that places the battery on the market is responsible for the battery passport and ensures that its information is accurate, complete and up to date (Article 77(4)). Depending on who places the finished battery on the market, that operator may be a battery manufacturer, an importer or a vehicle maker.

The same operator attributes the unique identifier to the battery (Article 77(3)) and uploads that identifier to the EU registry (Article 77(10)). Which role a company holds under the Regulation, and which other duties come with that role, is set out under Battery Regulation obligations by role.

Responsibility includes keeping dynamic data current, such as the battery's status. The Commission's FAQ (8.3 and 8.4) states that dynamic data are updated at least on a change of status and that real-time updating is not required. A passport is therefore accurate when each change of status reaches it.

Importers, Vehicle Makers and Written Authorisation

The operator placing the battery on the market may give written authorisation to any other operator to act on its behalf, but the authorisation does not transfer legal responsibility (Article 77(4); Commission FAQ 2.1). The authorising operator remains the addressee of the Article 77(4) duty.

A battery imported inside a product is normally placed on the market at the moment of import, so the importer is responsible for its passport (FAQ 3.5). The other duties of importers under the EU Battery Regulation follow the same import moment.

A vehicle maker that completes the battery, for example by adding the BMS, is responsible for the passport, while the battery maker stays responsible where a finished battery is merely installed (FAQ 2.3). A written authorisation never makes a non-EU entity the manufacturer or the importer (FAQ 2.4).

Fines for Inaccurate Passport Information in Germany

In Germany, failing to ensure that passport information is accurate, complete or up to date, contrary to Article 77(4), first sentence, is an administrative offence under § 60(2) Nr. 29 BattDG with a fine of up to EUR 10,000 (§ 60(3) BattDG). The BattDG (Batterierecht-Durchführungsgesetz, the German Battery Law Implementation Act) implements the Regulation in Germany.

German law adds a power to set further rules on passport access. § 59(1) Nr. 8 BattDG lets the federal environment ministry regulate access to passport information by ordinance. Registration, take-back and the other fines are covered under EU Battery Regulation in Germany.

What the Passport Contains and Who Can Read It

Annex XIII of Regulation (EU) 2023/1542 sorts the battery passport into four groups: public general information on the battery model (point 1), composition and dismantling information (point 2), test reports (point 3) and use and state-of-health data of the individual battery (point 4).

Non-binding Commission guidance splits these groups into 71 data points (version 3.2 of 19 October 2026).

Point 1 is public. Points 2 and 3 are open to notified bodies, market surveillance authorities and the Commission, and points 2 and 4 to persons with a legitimate interest and the Commission (Article 77(2), second subparagraph). The whole passport is therefore never public: detailed composition, test reports and use data sit behind access rights.

The implementing act on access, due by 18 August 2026 under Article 77(9), missed that deadline.

As of 13 November 2026 only a draft exists: Ares(2026)9814179 of 19 October 2026, open for feedback until 16 November 2026, adoption planned for the fourth quarter of 2026. Other drafts are listed under Battery Regulation delegated and implementing acts.

Annex XIII, point 1, in force runs from (a) to (s); a point 1(t) on instructions for use of stationary battery energy storage systems is only proposed.

The proposal, COM(2025) 504 (procedure 2025/0134(COD)), is pending: as of 13 November 2026, its agreed text was approved in committee on 14 July 2026, with an indicative plenary date of 23 November 2026.

How the Passport Is Reached: QR Code, Identifier and the EU Registry

The battery passport is reached through a QR code that links to the battery's unique identifier, which the economic operator placing the battery on the market attributes (Article 77(3)).

The identifier is "a unique string of characters for the identification of batteries that also enables a web link to the battery passport" (Article 3(1), point (66)).

The identifier and the QR code follow ISO/IEC 15459-1 to 15459-6 "or their equivalent" (Article 77(3), second subparagraph). EN 18219 and EN 18220 appear only in a draft delegated act (Ares(2026)9188325), not adopted as of 13 November 2026. Where and how the code is printed is set out under labelling, marking and QR code.

Registering the Identifier in the EU Registry

The operator placing the battery on the market or putting it into service uploads the unique identifier to the registry set up under Article 13(1) of Regulation (EU) 2024/1781, a duty added to the Battery Regulation as Article 77(10) with effect from 18 July 2024. That registry has been operational since 20 July 2026.

Implementing Regulation (EU) 2026/1778, in force since 6 August 2026, sets the registry's implementation arrangements and covers batteries under Article 77 (Article 1(1)(b)). Operators register through three channels: the user interface, an API or a bulk upload from their own systems (Commission FAQ 5.1).

Before registering, an operator verifies its identity with a qualified electronic seal under eIDAS or a qualified electronic attestation of attributes. The verification stays valid until the eID means expire, and for at most three years after the initial verification (FAQ 6.1 and 6.2).

The registry gives no access to the passport content, because the operator hosting the passport manages that access (FAQ 6.5). The battery passport registration identifier is not entered in the electronic customs declaration (FAQ 4.1). The general digital product passport for other products belongs to ecodesign law, a separate topic.

A non-EU company may verify itself and register digital product passports, but the battery passport registration is made by the operator placing the battery on the EU market (FAQ 2.2). The other duties of non-EU manufacturers and exporters follow from the same rule.

A New Passport after Repurposing, and the End after Recycling

A battery that undergoes preparation for re-use, preparation for repurposing, repurposing or remanufacturing gets a new battery passport linked to the passport or passports of the original battery, and the passport ceases to exist once the battery has been recycled (Article 77(7) and (8)). The original passport is not carried over unchanged.

A simple repair needs no new passport (Commission FAQ 9.2). A battery placed on the market before 18 February 2027 and remanufactured after that date needs a passport (FAQ 9.4), although no passport duty applied when it was first placed on the market. Remanufacturing, not the original sale, triggers the passport in that case.

The operator that first makes a battery available after preparation for re-use, preparation for repurposing, repurposing or remanufacturing is its producer (Article 56(2)). A second-life battery thus brings two duties together: a new passport under Article 77(7) and the producer role under Article 56(2). The full rules for second-life batteries sit on their own page.

At the waste stage, responsibility for the passport passes to the producer, to the producer responsibility organisation appointed under Article 57(1) or to the waste management operator selected under Article 57(8) (Article 77(7)). That operator answers for the passport until recycling of the battery ends it.

Battery Passport FAQ

Six questions come up when the battery passport meets other battery rules or is read in a hurry; each answer gives the article behind it.

The Passport and Other Battery Rules

Two battery rules sit next to the passport and are often confused with it: the label and due diligence.

Is the battery passport the same as the battery label?

No: the label is printed on the battery under Article 13, while the passport is an electronic record under Article 77 that the QR code opens for LMT batteries, industrial batteries with a capacity greater than 2 kWh and electric vehicle batteries. The QR code itself is a labelling duty of Article 13(6).

Is responsible-sourcing information public in the passport?

Yes: Annex XIII, point 1(d), places the responsible-sourcing information of the Article 52(3) report in the public part of the passport. The report follows from battery due diligence under Chapter VII, whose obligations apply from 18 August 2027 (Article 48(1), as amended by Regulation (EU) 2025/1561).

Common Misreadings of Article 77

Four claims about the battery passport recur in vendor and media summaries and are wrong under the Regulation's text.

Does the 2 kWh condition apply to every passport category?

No: Article 77(1) sets the 2 kWh condition for industrial batteries only, so every LMT battery and every electric vehicle battery needs a passport whatever its capacity. For industrial batteries the wording is "greater than 2 kWh", so an industrial battery of exactly 2 kWh needs no passport.

Is blockchain required for a battery passport?

No: the Regulation prescribes no specific technology, and the Commission FAQ (11.3) states that blockchain is not required. Article 77(5) asks instead for open standards, an interoperable format and machine-readable, structured and searchable data, without naming a technology.

Does the EU registry hold the full battery passport?

No: the registry holds the unique identifier uploaded under Article 77(10), not the passport data. The operator hosting the passport manages access to its content (Commission FAQ 6.5), within the access groups of Article 77(2).

Does it cost anything to read a battery passport?

No: consumers, economic operators and other relevant actors access the passport free of charge, according to their access rights (Article 78(b)). Free access covers reading only within each reader's group, from the public point 1 to the restricted points 2 to 4.