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# EU Battery Passport: Requirements Under the EU Battery Regulation

The EU Battery Regulation (Regulation 2023/1542) introduces the Battery Passport — a digital record accessible via QR code that must accompany industrial batteries, LMT batteries, and EV batteries placed on the EU market from February 2027. For hardware companies with large battery systems, e-mobility products, or stationary storage, the implementation timeline is tight and the data collection challenge is significant.

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Battery Regulation overview

## The EU Battery Regulation and where the Battery Passport fits

Regulation 2023/1542 (the EU Battery Regulation) replaces Directive 2006/66/EC (the Batteries Directive) and establishes a comprehensive regulatory framework for batteries placed on the EU market. It covers safety requirements (building on IEC 62133 and IEC 62619), performance requirements (capacity, cycle life), supply chain due diligence (cobalt, lithium, nickel, natural graphite sourcing), carbon footprint declaration, recycled content minimum thresholds (increasing over time to 2040), EPR registration, and the Battery Passport.

The Battery Passport applies to three battery categories above portable battery scale: industrial batteries with a capacity above 2 kWh (including stationary energy storage systems, UPS batteries, telecom backup batteries); light means of transport (LMT) batteries used in e-bikes, e-scooters, and similar micro-mobility devices; and electric vehicle (EV) batteries. Each battery in these categories placed on the EU market from February 2027 must be accompanied by a Battery Passport accessible via a QR code affixed to the battery or pack.

Required data

## What the Battery Passport must contain

The Battery Regulation specifies minimum data categories for the Battery Passport in Annex XIII, with additional requirements to be defined by Commission delegated acts. Current requirements include: a unique battery identifier (at individual battery level — each battery must have its own passport); manufacturer identity, place of manufacture, and contact details for the EU responsible person; battery model information (cell chemistry, nominal capacity, voltage, energy density, expected service life and cycle life); and carbon footprint data per lifecycle phase (raw material extraction, manufacture, distribution, use, and end-of-life).

Supply chain information: for cobalt, natural graphite, lithium, and nickel — the sourcing country for the raw material used in active materials, and third-party verification of supply chain due diligence. Recycled content declaration: percentages of cobalt, lithium, lead, and nickel from recycled sources. State of health and state of charge (for batteries in use — this requires that the Battery Passport data be updatable throughout the battery's service life, not just at point of sale). End-of-life information: disassembly instructions and material composition for recyclability optimization.

Implementation steps

## How to prepare for the February 2027 deadline

Step 1: Determine if your batteries are in scope. If your product contains a battery with a capacity above 2 kWh, an LMT battery, or is an EV battery, Battery Passport obligations apply from February 2027. Small consumer electronics batteries below 2 kWh (smartphones, laptops, wearables) are outside the Battery Passport scope — but still subject to the Battery Regulation's other requirements including carbon footprint declaration (from different dates) and EPR registration.

Step 2: Assess your supply chain data gaps. The most challenging Battery Passport data elements — carbon footprint per lifecycle phase, recycled content percentages with verification, raw material sourcing country for critical minerals — require structured data from battery cell and material suppliers that most do not currently provide. Supplier data requirements should be incorporated into purchase contracts and supplier qualification criteria immediately.

Step 3: Select a Battery Passport system. You need a hosted system that can store and serve Battery Passport data via QR code, maintain data for the battery lifetime (potentially 10-20+ years), support state-of-health updates, and meet EU interoperability requirements. The EU is developing a registry, but qualified third-party passport providers are also emerging. Evaluate options and select your system no later than 2025-2026 to allow time for data migration and QR code integration into production.

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## Frequently asked questions

### Which batteries need a Battery Passport?

The Battery Passport is mandatory from February 2027 for: industrial batteries with a capacity above 2 kWh; light means of transport (LMT) batteries (e-bike batteries, e-scooter batteries); and EV batteries for electric vehicles. Portable batteries (below 2 kWh, used in consumer electronics) do not require a Battery Passport but are subject to other Battery Regulation obligations including carbon footprint and recycled content declarations from separate dates.

### What data must the Battery Passport contain?

Required data includes: unique battery identifier; battery manufacturer identity; battery model (cell type, chemistry, nominal capacity, voltage, power); carbon footprint per lifecycle phase; recycled content (cobalt, lithium, nickel, lead) with verification; state of health and remaining capacity (for in-service batteries); original equipment manufacturer for battery application; and battery management system data access permissions. Additional data requirements will be defined by Commission delegated acts.

### How is the Battery Passport accessed?

The Battery Passport must be accessible via a QR code affixed to the battery or battery pack. The QR code must resolve to the battery passport data hosted by the manufacturer or importer in a system that meets EU interoperability requirements. The data must be accessible throughout the battery lifetime including post-use phases. The EU is developing a registry infrastructure for Battery Passport data but manufacturers may also use approved private systems.

### Does the Battery Passport apply to batteries already on the market before 2027?

The Battery Passport obligation applies to batteries placed on the EU market from the mandatory date onwards. Batteries sold before the deadline are subject to the previous Batteries Directive requirements. However, because product development and supply chain data collection takes 12-24 months to implement properly, hardware companies with in-scope batteries should begin implementation well before the February 2027 deadline.

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*   [EU Battery EPR Producer ResponsibilityExtended producer responsibility under EU Battery Regulation (EU) 2023/1542: Articles 55-61 collection and recycling targets, national producer register entries, compliance scheme selection, and labelling obligations for hardware companies.](/guides/eu-battery-epr-producer-responsibility)

Educational resource only. Battery Passport data requirements are being defined by Commission delegated acts. Verify current applicable requirements for your battery category against the latest published acts and guidance.