Battery Regulation
EU Battery Passport 2027: what it is, who must comply, and what data it needs
Updated 2026-09-09 · All guides
The short version
From 18 February 2027, every LMT battery (e-bikes, e-scooters, e-cargo bikes), every EV battery and every industrial battery above 2 kWh placed on the EU market needs a digital battery passport: a data record, reachable through a QR code on the battery itself, that stays available for the battery's entire life — first life, second life and recycling.
The obligation sits with the economic operator placing the battery on the market: the manufacturer, or the importer for batteries made outside the EU. It is not something you can outsource away. A platform gives you the infrastructure and the evidence; the legal responsibility stays with you.
Which batteries are in scope?
- LMT batteries — batteries for light means of transport: e-bikes, e-cargo bikes, e-scooters, mobility scooters.
- EV batteries — traction batteries for electric vehicles.
- Industrial batteries above 2 kWh — including home and commercial energy storage, marine and traction batteries.
Portable batteries (AA cells, power tool packs, laptop batteries) are not in scope for the passport, though other parts of the Battery Regulation still apply to them.
What has to be in the passport?
Annex XIII sets the attribute list. In practice it falls into six groups:
- Identity & market placement — manufacturer, address, model, serial or batch number, manufacturing date and place, producer registration (EPR) number.
- Performance & durability — rated capacity and energy, nominal voltage, rated cycle life including its test conditions, charge and discharge currents, round-trip efficiency, expected lifetime.
- Composition & hazardous substances — chemistry, the substances present with CAS/EC identifiers and mass percentages, critical raw materials, substances of concern and their classification.
- Carbon footprint — the total figure per kWh and, increasingly expected, the breakdown by lifecycle stage.
- Recycled content — post-consumer cobalt, lithium, nickel and lead shares.
- Circularity & end of life — separate collection statement, waste classification, dismantling and safe-removal information, spare parts, second-life status.
Some attributes are public to anyone who scans the code; others are restricted to authorised parties such as market-surveillance authorities, notified bodies, repairers and recyclers. That access model comes from Article 77.
Static data versus data that keeps changing
A battery passport is not a document you publish once. Identity data is fixed at market placement, but state of health, state of charge, cycle count and lifecycle status change continuously, and write authority moves along the chain: manufacturer, then second-life operator, then recycler. A passport populated once and never updated does not meet the requirement. This is why passport data belongs in a system with versioning and an audit trail rather than in a static PDF or a spreadsheet.
What is still moving
Six horizontal DPP standards (EN 18216, 18219, 18220, 18221, 18222, 18223) are published, the EU DPP Registry is operating, and the deadline itself has not shifted. The delegated act that fixes the detailed access rights and the rules for updating passport information is the last major piece. Practical consequence: build now against the attribute list you know, but keep the data model flexible enough to adjust the public/restricted split later.
A sensible plan for 2026-2027
- Inventory which of your products are in scope, and confirm whether you are manufacturer or importer for each.
- Collect the data — most of the effort is here, not in the software. Composition and carbon footprint data usually has to come from suppliers.
- Choose a data carrier and get QR codes onto labels; codes must survive the product's lifetime.
- Pick a system that versions data, supports API updates from your ERP or BMS, and can prove that its records were not altered.
- Run a pilot on one product line well before the deadline, then scale.
This guide is general information, not legal advice. Verify obligations for your specific products against the regulation and, where needed, with a qualified adviser.
Frequently asked
When is the EU battery passport mandatory?
From 18 February 2027. Every LMT battery, EV battery and industrial battery over 2 kWh placed on the EU market from that date must have a digital battery passport reachable via a QR code on the battery.
Who is responsible for the battery passport?
The economic operator placing the battery on the EU market — typically the manufacturer or importer. The obligation cannot be transferred to a software supplier; a platform such as Origopass provides the infrastructure, while the operator remains the responsible party.
What data must a battery passport contain?
Annex XIII of Regulation (EU) 2023/1542 lists the required attributes: manufacturer identity, battery model and serial, chemistry and composition, carbon footprint, recycled content, performance and durability data, hazardous substances, and end-of-life information — split into publicly accessible data and data restricted to authorised parties.