For industrial & storage batteries
Battery passports for industrial and energy storage batteries
Above 2 kWh the passport is mandatory — including home batteries and commercial storage. These systems stay in service for decades, which makes the durability of the record the real requirement.
Updated 2026-09-20 · All industries · Guides to the regulation
The 2 kWh line
Industrial batteries above 2 kWh need a passport from 18 February 2027. That threshold catches far more than factory equipment: home batteries, commercial and grid-scale storage, marine and traction batteries, backup systems. If you sell storage in the EU, assume you are in scope and check the exceptions afterwards.
What makes storage different
Service life measured in decades
A home battery installed in 2027 may still be running in 2045, quite possibly after a change of owner, a change of installer and a second life in another application. The passport has to be reachable for all of it. That puts weight on questions most software procurement skips: what happens to these URLs if the provider disappears, can you export everything, and can the QR code keep pointing at a domain you control?
Condition data over a long tail
State of health matters commercially here. Warranty claims, resale value and second-life decisions all hang on the measured condition of the system. Where a BMS or monitoring platform can post updates automatically, the passport turns into a genuinely useful service record. Where it cannot, condition should be updated at each maintenance visit rather than left at its factory value forever.
Installers and service partners in the chain
The party that installs or services a system is rarely the party that placed it on the market. Access control matters: an installer needs the safety and dismantling information, a recycler needs the composition, and the end customer needs the public data. Article 77 splits these tiers, and access grants should be recorded rather than handled by e-mailing a PDF around.
What this looks like in OrigoPass
- Separate product types for storage batteries with and without a BMS, so the field set matches what you can actually measure.
- Lifecycle updates that append a new sealed version — the full history stays visible and nothing overwrites the original declaration.
- Documents such as declarations of conformity and test reports linked with a cryptographic fingerprint, so a swapped file is detectable.
- Access requests from installers, repairers and recyclers handled from the passport page, with every grant sealed and every view logged.
- A 15-year archive guarantee: passports sealed in a paid period stay online even if you stop paying, and a signed export lets you host them yourself.
A workable sequence
- List the systems you place on the market and their capacities — the 2 kWh line decides scope.
- Collect module and cell data from suppliers; this is the long pole, particularly composition and carbon footprint.
- Decide where the data carrier goes on the enclosure, and how it survives an outdoor or technical-room environment.
- Connect monitoring to the passport for condition updates, or define a service routine that updates it.
- Agree with your second-life and recycling partners how they get access when the time comes.
General information, not legal advice. Verify obligations for your specific products against the regulation and, where needed, with a qualified adviser.
Frequently asked
Does a home battery need a battery passport?
If its capacity is above 2 kWh, yes. Home and commercial energy storage systems fall under industrial batteries in Regulation (EU) 2023/1542, and every such battery placed on the EU market from 18 February 2027 needs a digital passport.
What about a battery system without its own battery management system?
It is still in scope above 2 kWh. Some performance and condition attributes simply cannot be measured continuously without a BMS, so they are declared at market placement and updated when the system is serviced. Declare what is measured and leave the rest empty rather than inventing values.
Who is responsible when a system integrator assembles the system?
Whoever places the battery on the EU market in its final form. If you assemble modules into a storage system and sell it under your name, that is you — even when the modules came from elsewhere with their own documentation.