The battery passport: scope, duties and checklist
2027-02-18 —
Batteries are the first mandatory category in the EU Digital Product Passport system: from 18 February 2027, electric vehicle batteries, light means of transport (LMT) batteries and industrial batteries above 2 kWh must carry a digital battery passport when placed on the EU market or put into service, with their unique identifier uploaded to the EU registry. This is a statutory date (Art 77(1)), not an industry forecast.
1. Scope first
| Battery category | In scope? | Notes |
|---|---|---|
| Electric vehicle (EV) batteries | Mandatory | From 18 Feb 2027 at placing on the market |
| Light means of transport (LMT) | Mandatory | E-bikes, scooters and similar |
| Industrial > 2 kWh | Mandatory | Storage, backup power, telecom, etc. |
| Industrial ≤ 2 kWh | Not this passport | Exactly 2 kWh counts as “not greater” |
| Portable and other categories | Not this passport | Labelling, CE and substance duties still apply |
Two boundary notes: ① the duty attaches at the time of placing / putting into service — batteries lawfully placed before 18 Feb 2027 are not retroactively covered; stock placed later is. ② The duty follows the battery, not the finished product — with batteries inside equipment, confirm who places the battery on the EU market.
2. Who does what
| Role | Statutory duty | Typical EU buyer position |
|---|---|---|
| Manufacturer | Supply accurate Annex XIII data, configure QR carrier and unique identifier | Your Chinese supplier sits here |
| First placer / person putting into service | Create the passport, register in the EU registry, answer for data accuracy | Usually you, your EU entity, or your importer |
| Importer / distributor | Verify passport existence and registration identifier before placing | Your inbound QC step |
| Mandated party | May execute creation / maintenance / registration under written mandate | A service provider — a mandate does not transfer statutory liability |
3. What goes in: how the 71 data points tier out
Annex XIII carries roughly ninety attributes; the Commission guidance “Digital Batteries Passport — data point classification” v2.0 (21 Aug 2026) consolidates them into 71 data points with five applicability tiers. Mandatory counts differ by category (industry tallies: LMT the most, then EV, then industrial — verify against the official document):
| Tier | Meaning | Examples |
|---|---|---|
| Mandatory | Must be complete on day one (18 Feb 2027) | Manufacturer info, model & batch, chemistry, critical raw materials, rated capacity, safety, QR & unique identifier |
| Conditional | Applies when the scenario applies | Certified SOCE for EV (LMT exempt); real-time dynamic metrics for LMT (remaining capacity/power, resistance — not required for EV); substances of concern |
| Deferred | Not in round one; mandatory later | Recycled-content declaration and due diligence (from 18 Aug 2027); carbon footprint class (awaiting delegated act) |
| Voluntary | Fill if available | Some usage-history data (“where applicable”) |
| Exempt | Permanently out for that category | Check item by item — never assume |
4. Identifiers and carriers
- The QR code is the statutory data carrier (Art 13(6), Annex VI Part C; harmonised standard EN 18220:2026);
- The unique identifier must comply with the ISO/IEC 15459 series or equivalent (Art 77(3); EN 18219:2026). GS1 is a recognised issuing agency under that series — GS1 Digital Link is one compliant route, not the mandated one;
- The identifier must be uploaded to the EU registry at passport creation (Art 77(10)); customs and market-surveillance authorities verify against it.
5. Phased plan to 18 Feb 2027
| Phase | Window | Key actions |
|---|---|---|
| Settle duties | Now | Triage roles; written create / maintain / register split with suppliers; identify the registering entity |
| Settle identifiers | Now – 1 month | Choose an ISO/IEC 15459 issuing agency (GS1 or equivalent); apply for prefixes |
| Collect data | In parallel | Generate the gap checklist; dispatch by owner function; prioritise the mandatory tier |
| Select services | –3 months | Software & hosting selection (guide); if you register, start organisation validation (QSeal) in parallel |
| Dry run | –2 months | Walk data → passport → QR → resolution with dummy data; verify tiered access |
| Operate | After launch | Dynamic updates, versioning (registry requires full audit trail), persistence outliving the battery |
6. What non-compliance costs
From 18 Feb 2027, batteries without a passport cannot lawfully be placed on the EU market. Member-state market surveillance and customs are wired into the registry (Implementing Regulation (EU) 2026/1778). Penalties are set by national law; the nearer-term risk is a market-access break — shipments stopped or recalled.
Next
- Requesting data from suppliers → how to ask
- Organisation validation → the QSeal question