In short
The battery passport (German Batteriepass) is an electronic record that accompanies every larger battery in the EU throughout its life cycle. It is regulated in Article 77 of the EU Batteries Regulation (Regulation (EU) 2023/1542) and becomes mandatory from 18 February 2027 for batteries for light means of transport, industrial batteries with a capacity of more than 2 kWh and electric vehicle batteries.
The passport can be accessed via a QR code on the battery, contains data on origin, materials, carbon footprint, performance and condition and is regarded as the blueprint for the digital product passport that the Ecodesign Regulation (ESPR) is gradually introducing for further product groups.
Legal basis: the EU Batteries Regulation
The Batteries Regulation (EU) 2023/1542 entered into force on 17 August 2023 and replaces the Batteries Directive of 2006. It regulates the entire life cycle of batteries, from the extraction of raw materials through design, labelling and placing on the market to collection and recycling. As a regulation, it applies directly in all member states. Its obligations come into force in stages: labelling and information obligations, carbon footprint declarations, due diligence obligations in the supply chain, minimum recycled content, requirements for the replaceability of portable batteries and finally the battery passport.
Article 77(1) states the obligation concisely: from 18 February 2027, every LMT battery, every industrial battery with a capacity of more than 2 kWh and every electric vehicle battery placed on the market or put into service must have an electronic record, the battery passport. Responsibility lies with the economic operator that places the battery on the market, i.e. the manufacturer or, in the case of imported goods, the importer.
Which batteries need a battery passport
- LMT batteries (batteries for light means of transport): batteries for e-bikes, pedelecs, e-scooters and similar vehicles weighing less than 25 kg.
- Industrial batteries over 2 kWh: stationary energy storage systems, batteries in industrial trucks, storage in industrial plants.
- Electric vehicle batteries: traction batteries for cars, vans and other road vehicles.
Not covered are portable batteries such as smartphone or laptop batteries, starter batteries and industrial batteries up to 2 kWh. Other obligations of the regulation apply to them, such as labelling and replaceability, but no passport.
What the battery passport contains
The passport is kept per battery model and additionally per individual battery, so it contains both model-related and item-related data. Annex XIII of the regulation lists the content, which can be arranged in four groups:
| Data group | Examples | Visible to |
|---|---|---|
| General information | Manufacturer, battery category, date and place of manufacture, weight, capacity, cell chemistry, hazardous substances | The public |
| Sustainability | Carbon footprint, recycled content of cobalt, lithium, nickel and lead, due diligence report, information on take-back and recycling | The public |
| Performance and durability | Rated capacity, charging cycles, expected lifetime, condition data (state of health), temperature history | Authorities, the Commission, operators with a legitimate interest |
| Dismantling and safety | Dismantling instructions, safety measures, detailed composition | Notified bodies, authorities, repair and recycling companies |
The data must be accurate, complete and up to date, based on open standards and available in an interoperable, machine-readable format. If a battery is remanufactured or repurposed for a second life, responsibility for the passport passes to the operator that places it on the market again. After recycling, the passport is deleted.
Technology: QR code and unique identifier
Access to the battery passport is via the QR code, which according to Article 13 of the regulation must be affixed to the battery, and via a unique identifier assigned by the economic operator. The regulation does not prescribe a specific identification system; in practice, industry relies on GS1 Digital Link, i.e. a URL with GTIN and serial number, or on comparable schemes. Behind the URL, the passport sits in a system operated or commissioned by the manufacturer. For interoperability and data exchange, the Battery Pass initiative has published technical guidelines and data models on which many implementations are based.
The identifiers of the battery passports are also entered in the European Commission's central digital product passport registry, which has been in operation since 20 July 2026. Article 13 of the ESPR explicitly provides that the identifiers under the Batteries Regulation are stored there. Technically, the battery passport is therefore already part of the DPP infrastructure.
Access rights: who may see which data
Article 78 of the Batteries Regulation grades access to the battery passport by role. The public, i.e. anyone who scans the QR code, sees the general information, the sustainability information and the basic data on performance and durability. Persons with a legitimate interest, such as repair shops, operators of second-life applications and recyclers, additionally receive the detailed composition, the dismantling instructions and the condition data they need for their work. Market surveillance authorities, customs and the Commission can access all data, including the evidence on due diligence and conformity. Notified bodies see what they need for the conformity assessment. The economic operator that keeps the passport must implement this grading technically, for example via a login or certificates for the protected areas.
Personal data of the battery user do not belong in the passport. Condition data such as charging cycles or temperature history are assigned to the battery, not to a person; here the regulation refers to the General Data Protection Regulation.
Implementation: what manufacturers and retailers should prepare now
For manufacturers and importers, the battery passport is a data project along the entire supply chain. Cell chemistry, recycled content and carbon footprint come from cell and module suppliers, condition data from the battery management system, and dismantling and safety information from development. These sources have to converge in a system that generates a passport per serial number, provides it under a permanent URL, enforces the access rights and registers the identifier in the EU registry. Many manufacturers turn to specialised service providers for this instead of building the infrastructure themselves.
For retailers and online shops, the effort is smaller, but not zero. They should ensure that every battery arrives with a QR code and labelling, store the serial number down to the order line so that customers can find their battery again later, and take over the passport URL from the manufacturer into the product data. Anyone who sells batteries in a set with bicycles or devices has to clarify which serial number belongs to which order.
- Check the range: which items contain LMT, industrial or vehicle batteries within the scope?
- Ask suppliers: from when will they supply passports, and in what format will identifiers and URLs come?
- Create data fields: serial number per order line, passport URL per product or item.
- Prepare the display: product page, order confirmation and customer account with a passport link.
- Define the process: what happens with batteries that are delivered without a passport?
Example: an e-bike battery in the bicycle trade
From February 2027, a manufacturer of frame batteries supplies every battery with a QR code. The passport at individual item level states the cell chemistry, capacity, date of manufacture and recycled content; workshops additionally see the state of health and the dismantling instructions. The bicycle retailer, who sells the battery in store and in the online shop, checks in accordance with the retailer obligations of the regulation that labelling and QR code are present before offering the battery. The Batteries Regulation contains no obligation to link the battery passport on the product page of the shop. Many retailers do so anyway, because the Ecodesign Regulation will prescribe exactly this accessibility before purchase in distance selling for textiles, tyres and other product groups, and the battery passport is the opportunity to practise the process with real data. What this looks like in Shopware is described in the article implementing the digital product passport in Shopware.
Battery passport and digital product passport: connection and differences
The battery passport is a digital product passport, but with its own legal basis. Article 9(4) of the ESPR allows product groups to be exempted from the ESPR passport if other EU law already provides for an equivalent system; this is exactly the case with batteries. Three practical differences follow from this. First, the date is fixed, while the ESPR passports are still waiting for their delegated acts. Second, the data catalogue is already fixed in Annex XIII. Third, battery passport law lacks some of the ESPR's retailer obligations, such as advance accessibility in distance selling and the manufacturer's obligation to supply retailers with a copy of the data carrier within five working days. Companies that serve both worlds should therefore align their data model with the stricter ESPR framework.
Other obligations of the Batteries Regulation at a glance
- Carbon footprint declaration for electric vehicle batteries, rechargeable industrial batteries and LMT batteries, staggered by battery category and dependent on the associated delegated acts; later performance classes and maximum values.
- Due diligence obligations in the raw material supply chain for cobalt, lithium, nickel and natural graphite, with certification by notified bodies.
- Minimum recycled content for cobalt, lead, lithium and nickel in new batteries from 2031, tightened from 2036.
- Replaceability: from 2027, portable batteries must be easy for the end user to remove and replace.
- Collection targets for waste batteries, including a separate rate for LMT batteries.
Why the battery passport is central to the circular economy
Batteries are the product for which the benefit of a digital passport pays off fastest. They contain critical raw materials whose recovery is only worthwhile if recyclers know the cell chemistry before they open a battery. They age individually, so that second use as stationary storage can only be calculated with reliable condition data. And they are a safety risk if they are dismantled or stored incorrectly. For all three cases, the passport supplies the information on the object itself, not in a database that nobody can find any more after ten years. That is why the EU introduced the battery passport before all other product passports, and that is why it serves the Commission as a reference for the technical standards that now apply to the digital product passport as a whole.
Frequently asked questions about the battery passport
From when is the battery passport mandatory?
From 18 February 2027 for LMT batteries, industrial batteries over 2 kWh and electric vehicle batteries that are placed on the market or put into service from that date.
Do smartphone or power tool batteries need a battery passport?
No. Portable batteries are exempt from the battery passport but are subject to other obligations of the regulation, such as replaceability and labelling.
Who creates the battery passport?
The economic operator that places the battery on the market, i.e. the manufacturer or importer. Retailers check that labelling and QR code are present.
Do online shops have to show the battery passport on the product page?
The Batteries Regulation does not explicitly require this. For product passports under the Ecodesign Regulation, on the other hand, accessibility before purchase in distance selling will become mandatory, which is why linking it is already recommended now.
What happens to the passport in second-life use?
If a battery is remanufactured or repurposed, the operator that places it on the market again takes over responsibility for the passport and supplements it. After recycling, the passport is deleted.