Digital Product Passports for Batteries: What Companies Need to Know

Executive Summary

The battery passport is the first Digital Product Passport written into binding EU law with a date attached. It is created by Regulation (EU) 2023/1542, the EU Batteries Regulation, and Article 77 of that Regulation states that from 18 February 2027 each light means of transport (LMT) battery, each industrial battery with a capacity greater than 2 kWh, and each electric vehicle battery placed on the market or put into service must have an electronic record, called a battery passport.

That single sentence contains most of what organisations get wrong. It does not cover every battery: portable batteries and starting, lighting and ignition (SLI) batteries are outside the passport requirement. It does not treat the three covered categories identically, because the obligations that feed the passport, such as carbon footprint declaration and recycled content documentation, apply to different categories on different dates. And it is not a labelling task, because the passport is an electronic record reached through a QR code rather than the code itself.

This guide is written for the whole team that ends up owning this: compliance and regulatory affairs, sustainability, product and data, IT and architecture, procurement, and the smaller businesses that have none of those functions as separate roles. It is deliberately vendor-neutral, and it separates four things that are routinely blurred: law, meaning what the Regulation and measures adopted under it require; standards and specifications, which may be referenced but are a different kind of instrument; implementation practice, meaning choices your organisation makes; and tieback educational models, which are teaching frameworks with no legal status whatsoever.

The guide creates no new framework. Batteries are a legally specific application of concepts the library already teaches, and inventing a battery framework would duplicate them. It applies the existing models instead: the Passport Data Origin Model for where the data comes from, the responsibility and enforcement models for who answers for it, and the delivery family for how to actually run the programme.

One caution before starting. Several measures under the Batteries Regulation, including delegated and implementing acts on carbon footprint methodology, recycled content calculation, labelling and access by persons with a legitimate interest, were subject to deadlines that have now passed or are current. Their adoption status changes, and this guide does not assert which have been adopted. Before making any decision with legal consequences, check the current position on EUR-Lex and with the European Commission, or take advice. Nothing here is legal advice.

What Is a Battery Passport?

Definition

Battery passport

An electronic record required by Article 77 of Regulation (EU) 2023/1542 for each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market or put into service from 18 February 2027. It is linked to a unique identifier assigned by the economic operator placing the battery on the market, and is accessible through the QR code required by Article 13(6). Its content is set out in Annex XIII, and different parts of that content are accessible to different audiences: some publicly, some to notified bodies, market surveillance authorities and the Commission, and some to persons with a legitimate interest and the Commission.

Three properties distinguish the battery passport from the general ESPR passport that most readers meet first.

It is already law with a date. Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation, creates a framework under which passport requirements are set later, product group by product group. The Batteries Regulation did not wait: it states the requirement, the categories, the content and the date in the legislative text itself. Batteries are therefore the one sector where a programme can be planned against published law rather than against expectation.

Its content is tiered by audience, not just by topic. Annex XIII does not present one list. It presents information that is publicly accessible, information available to notified bodies, market surveillance authorities and the Commission, and information available to persons with a legitimate interest and the Commission. Some of that last category is at the level of the individual battery rather than the model.

It has both model-level and item-level content. Composition and declared carbon footprint describe a battery model. Performance and durability values, state of health and usage data describe one physical battery and change over its life. A design that cannot hold both will fail, and that is a data modelling decision made long before publication.

Tip

If you take one structural decision away from this guide, take this one: decide early, per data point, whether it belongs to the battery model or to the individual battery. Retrofitting item-level data onto a model-level design is the most expensive rework in a battery passport programme.

Which Batteries Require a Battery Passport?

Article 77(1) names three categories. Two other categories defined by the Regulation are not named, and that omission is the point.

Category	Article 3 definition, in outline	Battery passport under Article 77(1)?
Portable battery	Sealed, 5 kg or less, not designed for industrial use, and not an EV, LMT or SLI battery	No
SLI battery	Designed to supply power for starting, lighting or ignition, and usable for auxiliary or backup purposes in vehicles or machinery. No weight threshold	No
LMT battery	Sealed, 25 kg or less, designed to power the traction of wheeled vehicles, including type-approved category L vehicles	Yes, at any capacity
Industrial battery	Specifically designed for industrial use, including after repurposing, or any other battery over 5 kg that is not an EV, LMT or SLI battery	Yes, only where capacity exceeds 2 kWh
Electric vehicle battery	Designed for traction in hybrid or electric category L vehicles over 25 kg, or for traction in category M, N or O vehicles	Yes, at any capacity

Three consequences follow, and each of them catches organisations out.

Classification is a legal exercise before it is a data exercise. Whether a battery is industrial, LMT or portable turns on the definitions in Article 3, not on how the sales catalogue describes it. A company with a broad range may find that some product lines are in scope for the passport and others are not, and the boundary can run through what marketing treats as a single family.

The 2 kWh threshold applies to industrial batteries, not universally. It is an applicability trigger inside specific obligations, not a general cut-off. An LMT battery below 2 kWh is still in scope of Article 77. An industrial battery at or below 2 kWh is not.

Being out of scope for the passport does not mean being out of scope for the Regulation. Portable and SLI batteries remain subject to other duties under Regulation (EU) 2023/1542, including labelling, information and waste management requirements. The passport is one obligation among many.

Common Mistake

Assuming all battery categories have identical requirements

They do not, at three separate levels. The passport applies to three categories and not to two. The obligations that feed the passport, such as carbon footprint declaration, apply to different categories on different dates. And within the covered categories, some Annex XIII content is only relevant to particular battery types, such as the capacity threshold for exhaustion, which the Annex associates with electric vehicle batteries.

When Does the Battery Passport Become Mandatory?

Four kinds of date are involved, and conflating them produces both false panic and false comfort.

Entry into force. Regulation (EU) 2023/1542 was published in the Official Journal on 28 July 2023 and entered into force on the twentieth day following publication, which is 17 August 2023. Entry into force means the instrument legally exists. It does not mean every obligation applies.

General date of application. Article 96 sets 18 February 2024 as the general application date, with a series of staggered dates for particular provisions and chapters. Reading the Regulation without reading Article 96 will produce the wrong answer about almost any deadline.

The passport-specific date. Article 77(1) is explicit: from 18 February 2027, each battery in the three covered categories placed on the market or put into service must have a battery passport. The date attaches to placing on the market or putting into service, so it is a forward-looking duty rather than a retrofit of stock already placed on the market.

Dates of the obligations that feed the passport. These are the ones programmes underestimate, because the passport publishes information that other articles require you to have produced first.

Feeding obligation	Provision	Application timing, in outline
Carbon footprint declaration, EV batteries	Article 7	18 February 2025, or 12 months after the later of the relevant delegated and implementing acts
Carbon footprint declaration, rechargeable industrial batteries over 2 kWh, excluding those with external storage	Article 7	18 February 2026, on the same conditional basis
Carbon footprint declaration, LMT batteries	Article 7	18 August 2028, on the same conditional basis
Carbon footprint declaration, industrial batteries with external storage	Article 7	18 August 2030, on the same conditional basis
Recycled content documentation, cobalt, lead, lithium and nickel	Article 8	18 August 2028 for industrial batteries over 2 kWh excluding external storage, EV and SLI batteries, or 24 months after the relevant delegated act; 18 August 2033 for LMT batteries
Minimum recycled content shares	Article 8	From 18 August 2031, tightening from 18 August 2036
State of health and expected lifetime parameters	Article 14	From 18 August 2024 for stationary battery energy storage systems, LMT and EV batteries
Supply chain due diligence obligations	Articles 48 to 53	18 August 2027. The original date was 18 August 2025, postponed by two years by Regulation (EU) 2025/1561 of 18 July 2025, which amended the date in Article 48(1)

Three cautions belong with that table. First, several Article 7 and Article 8 timings are expressed conditionally, running from the adoption of the relevant delegated or implementing acts, so the operative date can move. Second, the Regulation set deadlines for the Commission to adopt several measures, including an implementing act under Article 77(9) concerning persons with a legitimate interest and their access rights, an implementing act on harmonised labelling specifications under Article 13(10), and methodology acts under Articles 7 and 8. This guide does not assert which of those have been adopted, because that position changes; check EUR-Lex and the Commission’s registers for the current state.

Third, the due diligence postponement is narrower than it is often reported to be. Regulation (EU) 2025/1561 of the European Parliament and of the Council of 18 July 2025, published at OJ L, 2025/1561, 30.7.2025, is a two-article instrument. Its only substantive provision amends Article 48 of Regulation (EU) 2023/1542, replacing the date 18 August 2025 in Article 48(1) with 18 August 2027, and replacing 18 February 2025 in Article 48(5) with 26 July 2026 for the Commission’s due diligence guidelines. It changes nothing in Articles 49 to 53 themselves, which continue to define what the due diligence obligations consist of once they apply, and it makes no change to Article 77 or to the 18 February 2027 battery passport date. The recitals give the reason: designation of notified bodies for third-party verification was taking longer than expected, and due diligence schemes eligible for recognition still needed development. Read the amendment as moving one trigger date, not as relieving the substance.

Best Practice

Build your internal timeline backwards from 18 February 2027, then overlay the feeding obligations, then subtract supplier lead time. For most organisations the binding constraint is not the passport date at all. It is how long it takes to obtain verifiable carbon footprint and material data from suppliers who have never been asked for it, which is routinely measured in quarters rather than weeks.

Who Is Responsible?

Article 77(4) places responsibility on the economic operator that places the battery on the market or puts it into service: that operator must ensure the information in the passport is accurate, complete and up to date. The same provision allows that operator to authorise another operator in writing to act on its behalf. Authorising someone to do the work does not move the duty.

The general treatment of roles, including manufacturer, importer, distributor, authorised representative and fulfilment service provider, is set out in Who Is Legally Responsible for a Digital Product Passport? and is not repeated here. What matters in the battery context is how that general treatment lands.

Manufacturers established in the EU that place their own batteries on the EU market are normally the responsible operator, and are usually also the origin of most of the passport content.

Importers are frequently the responsible operator in practice, and this is the single most underestimated exposure in the sector. An importer placing a battery from a non-EU manufacturer on the EU market can find itself answerable for information it does not hold, cannot measure and must obtain contractually. Buying a compliant-looking product is not the same as being able to substantiate its passport.

Distributors normally do not carry the Article 77(4) duty, but they operate under general obligations to act with due care in relation to the applicable requirements, including checking that required marking, information and documentation are present before making a battery available.

Operators that repurpose, remanufacture or prepare batteries for reuse take on a distinct position. Article 77(7) provides that responsibility transfers to the operator that places the modified battery on the market or puts it into service, with a new passport linked to the original, and that when a battery becomes waste, responsibility passes to the producer or producer responsibility organisation, or to the waste management operator selected. Article 77(8) provides that the passport ceases to exist once the battery has been recycled.

Common Mistake

The technology provider becomes legally responsible for the product

It does not. A passport platform, hosting provider or consultancy performs work. The economic operator placing the battery on the market remains the party the Regulation addresses, and Article 77(4) contemplates written authorisation of another operator precisely because delegation of the work is expected and delegation of the duty is not.

What Information Goes Into a Battery Passport?

Annex XIII organises the content by who can see it, and Article 77(2) maps those groups to access rights. The four groupings below follow the Annex. Descriptions are summaries; the Annex itself is the authority, and it may be amended by delegated act under Article 77(2).

Publicly accessible, at battery model level. Information required by Annex VI Part A, which covers identification of the manufacturer, battery category, model, place and date of manufacture, weight, capacity and chemistry among other items; material composition including chemistry, hazardous substances and critical raw materials; the carbon footprint information required under Article 7; responsible sourcing information reflecting the due diligence report under Article 52(3); recycled content documentation under Article 8; the share of renewable content; technical characteristics including rated capacity, voltage range, power capability, expected lifetime expressed in cycles, the capacity threshold for exhaustion for electric vehicle batteries, temperature range, warranty period, round trip efficiency, internal resistance and c-rate; marking requirements under Article 13(3) and (4); the EU declaration of conformity; and waste prevention and management information under Article 74(1).

Accessible to persons with a legitimate interest and the Commission, at battery model level. Detailed composition of cathode, anode and electrolyte; part numbers and sources for spare parts; dismantling information including diagrams, disassembly sequence, fasteners, tools and hazard warnings, and cell layout; and safety measures.

Accessible to notified bodies, market surveillance authorities and the Commission. Test report results demonstrating compliance with the requirements of the Regulation.

Accessible to persons with a legitimate interest, at individual battery level. Performance and durability values under Article 10(1), both at the point of placing on the market and on change of status; state of health data under Article 14; the status of the battery, expressed as original, repurposed, reused, remanufactured or waste; and usage data including charge and discharge cycles, negative events and accidents, and periodic operating conditions such as temperature and state of charge.

Three distinctions are worth holding onto while reading that list.

Required by legislation. The Annex XIII content itself, and the underlying obligations in Articles 7, 8, 10, 13, 14 and 52 that produce much of it.

Dependent on battery or product context. Several items apply only to certain categories or configurations. The capacity threshold for exhaustion is associated with electric vehicle batteries. Carbon footprint duties reach categories on different dates. Individual-level performance and state of health presuppose a battery with the relevant management capability.

Dependent on subsequent measures or standards. How the carbon footprint is calculated and declared, how recycled content is calculated and verified, how labelling is specified, and who qualifies as a person with a legitimate interest and with what rights, are matters the Regulation directed to delegated and implementing acts. The detailed implementation of those items follows those measures.

Where Does the Data Come From?

This is the section that decides whether the programme succeeds, and it is where the library’s existing model does the work. The Passport Data Origin Model teaches that passport information is assembled rather than stored in one place, and that every element has four properties worth stating separately: its origin, its authoritative source, its evidence, and the fact that publication does not transfer authority. The table below applies that model to representative battery passport content. It is an application of an existing model, not a new one.

Read each row across: this information, originating here, authoritative here, supported by this evidence.

Information	Typical origin	Authoritative source	Typical evidence
Unique identifier for the battery	Identifier allocation and serialisation process of the operator placing on the market	The operator placing the battery on the market	Internal control and allocation records
Manufacturer and economic operator information	Corporate and legal entity records, commercial registration	Legal and regulatory affairs function	Registration records, internal control
Battery model, category and technical characteristics	Engineering specifications and product master records	Engineering specification owner	Specification, design records, type test results
Manufacturing information, including place and date of manufacture and batch or cell identity	Production records at the cell and pack manufacturing sites	The production site	Batch and quality records
Material composition, chemistry, hazardous substances and critical raw materials	Cell and material supplier submissions, bills of materials	The supplying organisation for purchased materials, the specification owner otherwise	Supplier declarations, material specifications, analytical reports
Carbon footprint declaration	Footprint calculation performed under the applicable methodology, drawing on supplier and site data	The party that performed the calculation, subject to the applicable methodology and verification requirements	The calculation, its scope, assumptions and data sources, and any verification
Recycled content of cobalt, lead, lithium and nickel	Material and cell supplier declarations, purchasing and input records	The supplying organisation, subject to the applicable calculation methodology	Supplier declarations, chain of custody or certification where used, input records
Responsible sourcing and due diligence information	Due diligence policy, risk assessment and reporting process	The operator carrying the due diligence obligation	The due diligence report and its supporting records
Performance and durability values	Testing performed at type or unit level, and battery management system outputs	The testing party for measured values, the specification owner for declared values	Test reports, measurement records
State of health and usage data	The battery management system, and the systems that collect from it in the field	The party that observed and recorded the data	The record itself and its provenance
Conformity and compliance information, including the EU declaration of conformity	Compliance and regulatory affairs records, conformity assessment outputs	The economic operator carrying the legal duty	The declaration of conformity, technical documentation, test reports, notified body outputs where applicable
Dismantling, safety and spare part information	Engineering and technical service documentation	The manufacturer	Internal technical documentation, controlled revisions

Four observations follow directly from reading the table as a whole, and they are worth more than any individual row.

Most of the hard content originates outside the responsible operator. Composition, recycled content and much of the footprint input data belong to cell manufacturers, material producers and their suppliers. The responsible operator publishes it and answers for it.

Two rows behave completely differently from the rest. State of health and usage data are per-item, time-stamped and continuously changing. Everything else in the table is comparatively stable and model-level. This is the model-level versus item-level split, expressed in law.

Authority is not the same as origin. A supplier originating a recycled content figure does not make the supplier answerable for the published passport. The general principle is set out in What Is a System of Record?, and it applies here without modification.

The evidence column is not optional decoration. For batteries it is the column that market surveillance is most likely to test, because Annex XIII itself contemplates test report results being available to authorities.

Explanatory article diagram, not a tieback frameworkFrom battery to battery passport, and onward through its life

A delivery view that synthesises existing tieback models rather than introducing a new one. Each stage names the contributors that feed it. The references in each card point to the framework that already explains that stage in full.

Suppliers and external parties
Internal enterprise systems
Testing, certification and treatment

01
Battery or product
Establish the physical scope: which batteries, which categories, what capacity and configuration, and where each one is placed on the market.
- Product and engineering records
- Cell suppliers
02
Regulatory applicability
Classify under Article 3, determine whether Article 77 applies, and identify the feeding obligations and their dates for that category.
Law: Regulation (EU) 2023/1542
- Compliance and regulatory records
03
Information requirements
Derive the Annex XIII content that applies, split it into model level and individual battery level, and assign each element to its access tier.
Law: Annex XIII and Article 77(2)
- Engineering specifications
04
Data origins and supplier evidence
Map every element to origin, authoritative source and evidence, then collect what is not held internally across multiple supplier tiers.
Models: TBF-042, TBF-032, TBF-034
- Cell and material suppliers
- Upstream tiers
- PLM, ERP, production records
- Laboratories and certification bodies
05
Validation and assurance
Check completeness, consistency, plausibility and evidence sufficiency before publication, and assure the end to end result rather than individual fields.
Models: TBF-033, TBF-035
- Validation controls
06
Passport publication
Assign the unique identifier, apply the QR code required by Article 13(6), publish the tiered content and enforce access rights per audience.
Law: Articles 13(6), 77 and 78
- Publication service
- Identifier and resolution
07
Lifecycle operation
Keep the record current as usage and state of health accumulate, as status changes, and as responsibility transfers, until the passport ceases on recycling. Change feeds back to stage four.
Law: Article 77(7) and 77(8). Model: TBF-036
- Field and telematics collection
- Service and repurposing operators
- Waste management operators

How to read this

Stages two, three and six are governed by law. Stages four, five and seven are governed by the organisation, using the tieback models named in each card. The flow is a loop rather than a line, because a battery in service keeps producing information after publication.

Supplier Data and Evidence

Battery supply chains are deep, and the passport reaches through them. A pack assembler buys cells. A cell manufacturer buys cathode and anode active materials, electrolyte, separators and casings. Those material producers buy refined metals. The refined metals come from mines and from recycled feedstock. Recycled content and carbon footprint figures are properties of that chain, not of the assembly step, which is why they cannot be produced by looking harder at your own records.

Three specific difficulties recur, and none is solved by a better questionnaire.

Tier depth exceeds contractual reach. The responsible operator normally has a contract with its direct supplier and none with the tier beyond. Information about a refining route or a recycled feedstock share must therefore be passed down a chain of relationships, each of which can refuse, delay, or claim confidentiality.

Commercial sensitivity is genuine. Cathode formulation is competitive information. Suppliers will resist disclosing it in a form they consider exposed, which is one reason Annex XIII places detailed cathode, anode and electrolyte composition in the legitimate-interest tier rather than the public one. Designing the access tiers correctly is part of getting suppliers to participate at all.

A declaration is not automatically sufficient evidence. A supplier statement is an origin with an owner. Whether it is sufficient depends on the claim, its legal basis and the assurance the applicable measures require. A declaration covering a different material grade, a different plant or an earlier period supports nothing, however genuine it is.

The disciplines for both problems already exist in the library and are not restated here: How to Prepare Suppliers for Digital Product Passports covers segmentation, engagement, contractual mechanisms and the reality that supplier readiness is a programme rather than a mailing, and How to Manage Evidence for Digital Product Passports covers evidence scope, validity, expiry and renewal.

Best Practice

Put passport data obligations into supplier contracts at the next renewal, not at the point you need the data. Specify what must be provided, in what form, with what evidence, on what refresh cycle, and what happens when a formulation or a source changes. A change of cathode supplier that nobody reported is how a published carbon footprint becomes wrong without anyone touching the passport.

Identifiers, Data Carriers and Access

Four things sit in a chain, and collapsing any two of them causes confusion.

The battery is the physical item. The unique identifier is the code assigned by the economic operator placing it on the market, which names that battery unambiguously. The data carrier is the QR code required by Article 13(6), which carries the identifier on or with the product. The passport resource is the electronic record that is reached by using them.

Article 77(3) requires the passport to be accessible through that QR code and linked to the unique identifier, and provides that the QR code and the unique identifier are to comply with the ISO/IEC 15459 series covering unique identification, or equivalent standards, with power for the Commission to update those references by delegated act. Article 78 sets essential requirements for the passport itself, including interoperability with other Union digital product passports, access free of charge according to access rights, use of open standards, machine readability and the avoidance of vendor lock-in.

The general concepts, and the differences between them, are covered in What Is a Product Identifier?, What Is a Data Carrier? and QR Codes vs GS1 Digital Link.

One point requires care, because it is stated incorrectly in a great deal of commentary. The Batteries Regulation requires a QR code and a unique identifier meeting the referenced standards. It does not, in the provisions described here, mandate any particular commercial identification scheme. GS1 keys such as a GTIN, GS1 Digital Link syntax and EPCIS event data are widely used, interoperable and often a sensible implementation choice. They are an implementation choice nonetheless, and adopting them does not by itself establish compliance.

Access is the other half of this section, and it is unusual. Most product information is either public or private. The battery passport is neither: Article 77(2) defines who sees what, with a public tier, a tier for notified bodies, market surveillance authorities and the Commission, and a tier for persons with a legitimate interest and the Commission. The Regulation directed the Commission to specify, by implementing act, who qualifies as a person with a legitimate interest and what they may do with the information. Until that position is settled and confirmed, a sound design is one that can enforce tiered access and can adjust the definition of the tiers without redesigning the publication.

Common Mistake

A battery passport is just a QR code

The QR code is the carrier. The passport is the tiered electronic record it leads to, populated with Annex XIII content, kept accurate and up to date under Article 77(4), and subject to access control. A QR code with nothing governed behind it is a sticker.

Battery Passport Architecture

The architectural question is not which system will hold the passport. It is how information from several systems and several organisations is assembled, governed, published and kept current, with authority left where it belongs. That question is answered in full by Building an Enterprise Digital Product Passport Architecture, and this section only says what is specific to batteries.

Three battery-specific pressures shape the design.

Item-level volume. State of health and usage data are per battery and continuous. A design that happily holds a few hundred battery models will not necessarily hold millions of individual records with a growing history each. Decide early what is stored, what is referenced, what is aggregated and what is retained.

A long and mutating life. Batteries are repurposed, remanufactured and eventually recycled, and Article 77(7) moves responsibility with them, requiring a new passport linked to the original. The architecture must express relationships between passports, not just passports.

Tiered access as a first-class requirement. Access control is not a feature bolted onto publication; it is part of what the Regulation requires the passport to do.

For larger organisations, the practical shape is usually the one the reference architecture describes: engineering specifications remain authoritative in product lifecycle management, production and batch data in manufacturing and production systems, commercial and entity data in the enterprise resource planning system, compliance records in the compliance repository, supplier submissions in a governed collection layer, and a publication layer that assembles and serves the tiered record. The common failure is building a new master database and copying everything into it, which adds a version without adding authority.

For smaller organisations, none of that software is a legal prerequisite. A small pack assembler or importer can hold specifications in controlled documents, supplier declarations in a structured folder with scope and expiry tracked, production and batch records in a simple register, and use a passport service for identifier assignment, tiered publication and access control. What cannot be skipped is the governance: one current version, a named owner per data point, known evidence, and a review cycle. The smaller organisation often does this better, because the answer is one person rather than a committee.

Data Quality and Validation

Publication is a commitment. Under Article 77(4) the responsible operator must ensure the information is accurate, complete and up to date, which makes validation a compliance control rather than a quality nicety.

The control model is set out in How to Validate Digital Product Passport Data, supported by What Is Product Data Quality?. Applied to batteries, the checks that earn their place are these.

Completeness against the applicable Annex XIII subset, category by category, rather than against a generic field list. A missing item in a category that does not apply is not a defect; a missing item in one that does is.

Internal consistency. Declared chemistry, composition and technical characteristics should agree with each other and with the declaration of conformity and technical documentation. Contradiction between the passport and the compliance record is the finding that matters most in an inspection.

Plausibility. Capacities, voltages, cycle life, footprint values and recycled content shares should fall in credible ranges for the chemistry and format. Implausible values are usually unit errors, misapplied methodology, or a supplier answering a different question.

Evidence sufficiency. Every claim that needs support should have identified support, in scope and in date, before it is published.

Identifier integrity. One battery, one identifier, resolvable, unique, and correctly linked when a repurposed battery gets a new passport related to the original.

Common Mistake

Publication proves the information is correct

Publication proves only that something was published. Correctness comes from validated inputs, substantiated claims and controlled change. The passport is the most visible surface of your product data, which means it exports your data quality problems to regulators, customers and competitors at the same time.

Assurance and Evidence

Two different activities are often called verification, and the distinction matters here more than in most sectors.

Evidence management is holding, tracking and renewing the documents that support claims: test reports, supplier declarations, certificates, calculation records and their scope and validity. See How to Manage Evidence for Digital Product Passports.

Assurance is testing that the whole passport works end to end before and after it goes live: that the carrier resolves, that the right audience sees the right tier, that the content is the content you intended, that updates propagate, and that the result matches the compliance record. See How to Test and Assure a Digital Product Passport.

Neither is the same as conformity assessment under the applicable legislation, which is a legal procedure described in How Conformity Assessment Works for Digital Product Passports. Internal assurance carries no statutory conformity status. Where the Regulation or a measure adopted under it requires verification of a particular claim, that requirement is met on its own terms and not by an internal review.

Tip

Test the access tiers with real personas before launch: an anonymous member of the public, an authority-style reviewer, and a legitimate-interest party such as a recycler. Tiered disclosure is the most battery-specific part of the design and the least exercised by generic passport testing.

Keeping the Passport Current

The battery passport is unusual among passports because it is expected to change after the product is sold. Individual-level performance, state of health, usage data and status all evolve. Article 77(4) requires the information to be kept up to date, and Article 77(7) moves responsibility as the battery is repurposed, remanufactured or becomes waste, with the passport ceasing to exist once the battery has been recycled under Article 77(8).

That turns the passport from a project deliverable into an operated service, which is what How to Operate a Digital Product Passport Programme describes. The battery-specific triggers for change are worth listing explicitly, because they are usually discovered rather than planned:

a supplier, formulation or plant change that alters composition, recycled content or footprint;
a new production batch with different inputs from the last;
a correction to a published value, which needs a controlled change path and a record of what changed;
adoption of a delegated or implementing act that changes methodology, content or access definitions;
a status change to repurposed, reused, remanufactured or waste, and the transfer of responsibility that accompanies it;
accumulating state of health and usage data over the operating life.

Common Mistake

Passport creation is a one-time project

For batteries this is not merely inefficient, it is structurally wrong. The Regulation contemplates a record that changes hands and changes content over a life measured in years, and ends only at recycling. Staffing it as a launch project and then disbanding the team leaves an obligation with no owner.

Enforcement and Legal Responsibility

Both topics have dedicated articles and are not restated here. How Digital Product Passports Will Be Enforced covers the enforcement lifecycle, the role of market surveillance authorities, the mechanics of checks and corrective action, and the general place of penalties. Who Is Legally Responsible for a Digital Product Passport? covers the allocation of duties across economic operator roles.

Three battery-specific points are worth adding.

The passport itself is an inspection surface. Annex XIII expressly makes test report results available to notified bodies, market surveillance authorities and the Commission, so the record is not only a consumer-facing artefact.

Inconsistency is discoverable at scale. A published passport can be compared with the declaration of conformity, with labelling, with other batteries in the same range, and with what competitors publish, without anyone visiting a factory.

Responsibility follows the battery. Where a battery is repurposed or becomes waste, Article 77(7) moves the duty. An organisation entering the second-life or treatment market is taking on obligations, not just inheriting a product.

Practical Implementation Roadmap

How to Build a Digital Product Passport Implementation Roadmap sets out the general delivery model. What follows is that model applied to batteries. It adds no new framework; it fixes the general stages to battery specifics and to the 18 February 2027 date.

Stage 1: Establish applicability. Classify every battery in the portfolio against the Article 3 definitions. Identify which fall under Article 77(1), including the 2 kWh test for industrial batteries. Record the answer per product line with a reason, because you will be asked to justify exclusions. Identify the feeding obligations that apply to each category and their dates. Output: a defensible scope statement.

Stage 2: Derive the information requirement. Turn the applicable Annex XIII content into a working list per battery category. Mark each element model-level or item-level, and assign its access tier. Output: a content specification that a data team can act on.

Stage 3: Map origins. Apply the Passport Data Origin Model to each element: origin, authoritative source, evidence, responsible owner. Output: a map that shows precisely which elements you already hold, which need a supplier, and which need a test or calculation that has not yet been performed.

Stage 4: Close the supplier gap. Segment suppliers by the criticality of what only they can provide. Engage the critical few first. Put obligations into contracts. Expect this stage to be the longest, and start it before the internal work is finished, not after.

Stage 5: Build the data and publication capability. Assemble, validate and publish, with tiered access and identifier assignment. Reuse existing authoritative sources rather than replacing them.

Stage 6: Validate and assure. Run the completeness, consistency, plausibility and evidence checks, then assure the end to end result including the carrier and the access tiers.

Stage 7: Publish and operate. Go live for batteries placed on the market from the applicable date, then run it as a service with a named owner, a change process and a monitoring routine for new measures.

Best Practice

Sequence by dependency, not by comfort. Most teams start with the publication technology because it is visible and tractable, and reach the supplier gap last, where the lead time actually is. Stage 4 should begin in parallel with Stage 2.

Worked Example

Example

Hypothetical: a 12 kWh commercial energy storage battery

Everything in this example is hypothetical and illustrative. The company, product and values are invented for teaching purposes and must not be read as guidance about any real product or as a statement of what any particular organisation must publish.

The situation. A mid-sized European company assembles a 12 kWh lithium iron phosphate battery system for commercial premises. It buys cells from a non-EU manufacturer, assembles packs in its own plant in the EU, and sells across several member states. It has around forty staff, an accounting and inventory system, engineering specifications in controlled documents, and no product lifecycle management or manufacturing execution system.

Step 1, applicability. The battery is not portable, not SLI, not LMT and not an EV battery. It is an industrial battery, and its capacity of 12 kWh exceeds 2 kWh, so Article 77(1) applies. The company also checks which feeding obligations apply to rechargeable industrial batteries over 2 kWh and on what timing, and notes that state of health requirements under Article 14 are relevant to stationary storage.

Step 2, information requirement. The team writes out the applicable Annex XIII content and marks each element. Composition, chemistry, technical characteristics, declared footprint and recycled content are model-level and mostly public tier. Dismantling and detailed electrode composition are model-level, legitimate-interest tier. Performance values, state of health, status and usage data are item-level. Test report results are for authorities.

Step 3, origins. Applying the origin model produces an uncomfortable but useful picture. Identity, model characteristics, place and date of manufacture, batch identity, dismantling information and the declaration of conformity are internal. Cell chemistry, detailed electrode composition, cell-level carbon footprint contribution and recycled content of cobalt, lithium and nickel are not: they depend entirely on the cell manufacturer and its upstream suppliers. State of health data depends on the battery management system and on whether the company can collect from units in the field at all.

Step 4, supplier evidence. The company asks its cell supplier for composition, recycled content and footprint inputs, with supporting evidence. The first response is a marketing datasheet, which supports nothing. The second, after escalation and a contract discussion, is a declaration with a defined scope and a test report for the chemistry. The recycled content figure is still unavailable because it depends on the supplier’s own upstream refiners. The company records the gap explicitly, with an owner and a date, rather than publishing a number it cannot support.

Step 5, validation. Checks find two defects. A capacity value in the sales catalogue disagrees with the engineering specification, and a chemistry description in the draft passport does not match the wording in the technical documentation. Both are corrected at source, not in the passport, so the correction survives the next publication.

Step 6, publication. Each pack receives a unique identifier at end of line, recorded against its batch. A QR code is applied to the pack. The public tier shows identity, characteristics, composition, waste information and the declaration of conformity. Dismantling and detailed electrode data sit in the legitimate-interest tier. Test reports are made available to authorities.

Step 7, operation. The company sets a quarterly review of supplier data, a change trigger for any cell source or formulation change, a route for site engineers to report state of health readings from installed systems, and a watch on new measures affecting methodology and access. When a customer later has a pack repurposed by a third party, the company notes that responsibility for the new passport moves to the operator placing the repurposed battery on the market.

What the example demonstrates. A forty-person company with no enterprise software can do this. The work is not software; it is classification, information mapping, supplier pressure, honest gap recording, and a routine that survives after launch. The hardest single item is the recycled content figure, and no amount of internal effort produces it.

Common Mistakes

A battery passport is just a QR code. The code is the carrier. The passport is the tiered, maintained electronic record behind it.

All battery categories have identical requirements. Portable and SLI batteries are outside Article 77. Industrial batteries are in scope only above 2 kWh. The feeding obligations reach different categories on different dates.

Supplier declarations automatically constitute sufficient evidence. A declaration is a statement by its author, with a scope and a date. Sufficiency depends on the claim and on what the applicable measures require.

The passport should become the master database. It is a governed publication. Copying everything into it without designating authority creates one more version of the truth rather than fewer.

Publication proves the information is correct. It proves only that it was published. Accuracy comes from validated inputs, substantiated claims and controlled change.

Using GS1 automatically creates compliance. GS1 keys, Digital Link and EPCIS are widely used and often a good choice. The legal requirements are the ones in the Regulation, and adopting a standard is an implementation decision.

The technology provider becomes legally responsible for the product. The economic operator placing the battery on the market carries the duty under Article 77(4), including where it authorises another operator in writing to act on its behalf.

Passport creation is a one-time project. Battery passports change with usage, status and responsibility, and end only at recycling.

Compliance can start when the delegated and implementing acts are final. Some detail does depend on those measures. Classification, information mapping, supplier engagement and data quality do not, and they are the parts with the longest lead time.

Preparation Checklist

Scope and legal position

Classify every battery in the portfolio against the Article 3 definitions, and record the reasoning.
Determine Article 77(1) applicability per line, including the 2 kWh test for industrial batteries.
Identify your role for each product: manufacturer, importer, or other, and confirm who is the economic operator placing on the market.
List the feeding obligations that apply and their dates, and mark which depend on measures not yet settled.

Information and data

Write out the applicable Annex XIII content per category.
Mark each element model-level or item-level.
Assign each element to an access tier.
Map origin, authoritative source, evidence and owner for every element.
Identify the elements you cannot produce today, with a named owner and a target date.

Suppliers

Identify which suppliers hold data you cannot obtain elsewhere, particularly cell and material suppliers.
Assess how deep into the chain each required item actually sits.
Add passport data and evidence obligations to contracts, including notification of formulation and source changes.
Agree formats, refresh cycles and escalation routes.

Systems and publication

Decide how identifiers are assigned, recorded and applied at end of line.
Decide where the published record is assembled and served, and how tiered access is enforced.
Decide how item-level state of health and usage data are captured and retained.
Confirm the design can relate a repurposed battery’s new passport to the original.

Quality, evidence and assurance

Define completeness, consistency, plausibility and evidence checks, and run them before publication.
Track evidence scope, issuer, validity and expiry.
Test the carrier and every access tier with realistic personas.

Operation

Name a permanent owner for the passport after launch.
Define change triggers and the correction path for published values.
Monitor delegated and implementing acts, and standardisation work, for changes to methodology, content and access.

Frequently Asked Questions

What is a battery passport?
An electronic record required by Article 77 of Regulation (EU) 2023/1542 for certain batteries, linked to a unique identifier, accessible through a QR code, containing the information set out in Annex XIII, with different parts available to the public, to authorities, and to persons with a legitimate interest.

When is the battery passport mandatory?
From 18 February 2027 for each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market or put into service, under Article 77(1).

Which batteries need a battery passport?
LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries. Portable batteries and SLI batteries are not covered by the Article 77 passport requirement, although other duties under the Regulation still apply to them.

Do portable batteries need a battery passport?
No. The Article 77(1) requirement does not extend to portable batteries.

Who is responsible for the battery passport?
The economic operator that places the battery on the market or puts it into service, under Article 77(4). That operator may authorise another operator in writing to act on its behalf, which delegates the work and not the duty.

Are importers responsible for battery passports?
An importer that places a battery on the EU market can be the responsible operator, which is why importers frequently carry more exposure than they expect and need contractual routes to information they do not hold.

What information goes in a battery passport?
Annex XIII sets it out, grouped by access. It includes identification and technical characteristics, material composition and hazardous substances, carbon footprint, recycled content, responsible sourcing information, the declaration of conformity, waste management information, dismantling and safety information, test report results, and at individual battery level performance, state of health, status and usage data.

Where does battery passport data come from?
From several places: internal engineering and production records, cell and material suppliers and their upstream tiers, laboratories and certification bodies, compliance records, and the battery management system for item-level data. Much of the hardest content originates outside the responsible operator.

Does the battery passport require a QR code?
Article 77(3) provides that the passport is accessible through the QR code required by Article 13(6) and linked to the unique identifier, with the QR code and identifier complying with the ISO/IEC 15459 series or equivalent standards.

Does the Batteries Regulation require GS1 identifiers?
The provisions described here require a unique identifier and a QR code meeting referenced standards. They do not, on that basis, mandate a particular commercial identification scheme. GS1 keys are a common implementation choice, not an automatic legal answer.

What is state of health data and does it go in the passport?
State of health describes the condition of an individual battery relative to its original condition. Article 14 requires parameters determining state of health and expected lifetime for stationary battery energy storage systems, LMT and EV batteries, and Annex XIII places state of health among the individual-level information available to persons with a legitimate interest.

How does the battery passport relate to the ESPR passport?
They are separate legal instruments with a shared concept. The Batteries Regulation creates the battery passport directly; Regulation (EU) 2024/1781 creates a framework under which passport requirements are set per product group. Article 78 requires interoperability with other Union digital product passports.

Do small companies have to comply?
The obligations attach to the battery and the role, not to the size of the company. A small importer placing an in-scope battery on the EU market carries the duty. What differs is the tooling, not the requirement.

What happens to the passport at end of life?
Article 77(7) transfers responsibility on repurposing, remanufacturing or when the battery becomes waste, and Article 77(8) provides that the passport ceases to exist once the battery has been recycled.

Are the delegated and implementing acts finalised?
The Regulation directed the Commission to adopt several measures, including on carbon footprint methodology, recycled content calculation, labelling specifications and access by persons with a legitimate interest. Their adoption status changes over time and this guide does not assert it. Check EUR-Lex and the Commission’s registers for the current position.

Key Takeaways

The battery passport applies from 18 February 2027 under Article 77(1) of Regulation (EU) 2023/1542, to LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries. Portable and SLI batteries are outside that requirement. - The categories are not interchangeable, and neither are the feeding obligations. Carbon footprint, recycled content, performance and state of health duties reach different categories on different dates, several of them conditional on measures adopted later. - The economic operator placing the battery on the market carries the duty under Article 77(4). It may authorise another operator in writing to do the work, which never moves the responsibility. - Annex XIII is tiered by audience, not just by topic, and includes both battery model information and individual battery information such as state of health, status and usage data. Design for both from the start. - Most of the hardest content originates outside the responsible operator, in cell and material suppliers and their upstream tiers. Supplier lead time, not the publication technology, is the binding constraint in almost every programme. - A supplier declaration is an origin, not automatic evidence. Sufficiency depends on the claim, its scope and validity, and what the applicable measures require. - The QR code is a carrier and the unique identifier is a key. The passport is the governed, tiered record they lead to, and adopting any particular identification scheme is an implementation choice rather than compliance. - A battery passport is an operated service, not a project. Responsibility moves on repurposing and at waste stage, and the passport ceases to exist only once the battery has been recycled.

References

Regulation (EU) 2023/1542 concerning batteries and waste batteries, Official Journal of the European Union, OJ L 191, 28.7.2023: https://eur-lex.europa.eu/eli/reg/2023/1542/oj
Regulation (EU) 2025/1561 of the European Parliament and of the Council of 18 July 2025 amending Regulation (EU) 2023/1542 as regards obligations of economic operators concerning battery due diligence policies, OJ L, 2025/1561, 30.7.2025: https://eur-lex.europa.eu/eli/reg/2025/1561/oj
Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for sustainable products (ESPR): https://eur-lex.europa.eu/eli/reg/2024/1781/oj
Regulation (EU) 2019/1020 on market surveillance and compliance of products: https://eur-lex.europa.eu/eli/reg/2019/1020/oj
Regulation (EU) 2018/858 on the approval and market surveillance of motor vehicles: https://eur-lex.europa.eu/eli/reg/2018/858/oj
Regulation (EU) No 168/2013 on the approval and market surveillance of two- or three-wheel vehicles and quadricycles: https://eur-lex.europa.eu/eli/reg/2013/168/oj
European Commission, batteries policy and the EU Batteries Regulation: https://environment.ec.europa.eu/topics/waste-and-recycling/batteries-and-accumulators_en
European Commission, Digital Product Passport: https://single-market-economy.ec.europa.eu/single-market/goods/european-standards/harmonised-standards/digital-product-passport-dpp_en
EUR-Lex, register of delegated and implementing acts, for the current adoption status of measures under Regulation (EU) 2023/1542: https://eur-lex.europa.eu/homepage.html

About This Article

Last Reviewed: 2026-08-09
Next Scheduled Review: 2027-08-09
Article Version: 1.0

tieback Knowledge is a continuously maintained reference library covering Digital Product Passports, product traceability, product compliance and related regulations. Articles are reviewed regularly as legislation, standards and implementation guidance evolve.

Executive Summary

Table of Contents

What Is a Battery Passport?

Which Batteries Require a Battery Passport?

When Does the Battery Passport Become Mandatory?

Who Is Responsible?

What Information Goes Into a Battery Passport?

Where Does the Data Come From?

Supplier Data and Evidence

Identifiers, Data Carriers and Access

Battery Passport Architecture

Data Quality and Validation

Assurance and Evidence

Keeping the Passport Current

Enforcement and Legal Responsibility

Practical Implementation Roadmap

Worked Example

Common Mistakes

Preparation Checklist

Frequently Asked Questions

Key Takeaways

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Related Glossary Terms

References

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