Battery passport and Batteries Regulation: what companies must do?
The EU Batteries Regulation introduces new requirements for battery manufacturing and the management of battery information. The main change is the digital battery passport, which will become mandatory from 18 February 2027 for certain batteries placed on the EU market or put into service. The battery passport brings together information about a battery’s characteristics and life cycle.
If your business manufactures or imports
- electric vehicle batteries,
- light means of transport batteries or
- industrial batteries with a capacity greater than 2 kWh,
it is likely that your company should prepare for the battery passport.
In this article, we summarise what the battery passport and Batteries Regulation mean in practice and how your business can prepare for the upcoming requirements.
What is the EU Batteries Regulation?
The EU Batteries Regulation (EU) 2023/1542 regulates the entire life cycle of rechargeable and non-rechargeable batteries. The Batteries Regulation aims to reduce the environmental impacts of batteries and promote the recycling of the materials used to manufacture them. The regulation originally entered into force on 17 August 2023, and its requirements are being introduced in stages.
In principle, the Batteries Regulation covers all categories of rechargeable and non-rechargeable batteries. A business’s obligations depend on the product covered by the regulation and the business’s role. The Batteries Regulation includes requirements relating to, for example:
- battery safety and performance
- restrictions on harmful substances
- carbon footprint information and the use of recycled materials
- battery labelling and the availability of product information
- the collection and recycling of waste batteries
- due diligence obligations for raw material sourcing.
What is a battery passport?
A battery passport is a uniquely identifiable digital product passport (DPP) attached to a battery, containing information required under the Batteries Regulation. Article 77 of the Batteries Regulation sets out the provisions on the battery passport. In practice, the battery passport is a QR code attached to the battery and linked to a unique identifier assigned to it by the operator placing the battery on the market.
The aim of the battery passport is to provide easy access to information about the battery and its characteristics throughout the value chain and ensure that information is not lost during the battery’s life cycle. The information stored in the passport can be used, for example, to support maintenance, decommissioning and recycling.
Which batteries does the battery passport apply to?
Article 77 of the EU Batteries Regulation sets out the battery passport requirement as follows: From 18 February 2027, each light means of transport 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, a battery passport.
In practice, the battery passport applies to the following:
| Battery category | Example |
| Light means of transport batteries, or LMT batteries | Batteries for electric bicycles and electric scooters |
| Industrial batteries (over 2 kWh) | Batteries used in industry (including consumer batteries that fall within this category) |
| Electric vehicle traction batteries | Electric car batteries |
Who is responsible for the battery passport?
The economic operator placing the battery on the market is responsible for the battery passport. The battery passport obligation specifically concerns the finished battery. If a business’s role in the supply chain is to supply components or modules, it may receive requests for information from customers so that the business responsible for the passport can compile the information it needs.
Battery passport data management is based on a decentralised system in which the responsible operator manages and stores the passport data. The battery passport is maintained in a database operated by the economic operator or its chosen digital product passport provider.
The battery passport is registered in the EU DPP registry. Before an organisation can use the registry, it must register and be verified. The DPP registry only stores information needed to identify and access the battery passport, such as the product’s unique identifier and information about the platform where the battery passport is stored. The responsible operator creates the unique identifiers for batteries subject to the battery passport requirement. The format of the unique identifier and the structure and technical implementation of the battery passport have been standardised. The European Commission will also establish a publicly accessible DPP web portal where different stakeholders can search and compare information from battery passports and other digital product passports.
The economic operator placing the battery on the market may authorise another operator, such as a vehicle manufacturer, in writing to update the passport data on its behalf. Responsibility for complying with the battery passport requirements remains with the operator placing the battery on the market.
What information must be included in the battery passport?
The information required for a battery passport depends on the category of the battery concerned. The European Commission has published guidance on the data points to be reported for batteries covered by the Batteries Regulation to support interpretation, listing the reporting requirements by battery category. The table below highlights some of the information to be included in the passport that generally applies to all three battery categories covered by the battery passport requirement.
| Information to be reported | Examples |
| Identifiers and manufacturing information | Unique identifier, manufacturer, place and date of manufacture |
| Battery characteristics | Battery category, weight, capacity and chemical composition |
| Materials and safety | Hazardous substances, critical raw materials and a suitable extinguishing agent |
| Performance | Voltage, power, a safe temperature range for the battery and expected lifetime, where applicable |
| Repair and dismantling | Spare parts information, dismantling instructions and safety measures |
| Compliance | EU declaration of conformity and test results |
Access to battery passport information is restricted according to its intended use. Commercially sensitive information, such as the battery’s detailed composition and instructions for safe dismantling, is only available to operators that need it.
When will the battery passport requirements apply?
The battery passport obligations enter into force on 18 February 2027. The Batteries Regulation itself entered into force in 2023, but its requirements, including the battery passport, enter into force in stages. Due diligence obligations relating to the sourcing of raw materials for batteries will apply from 18 August 2027.
Where should you start when identifying the requirements of the Batteries Regulation?
It is worth preparing as soon as possible for the battery passport obligation to enter into force. Start by identifying your role in the value chain: Are you responsible for compiling the battery passport, or are you only responsible for providing information to another operator?
The most important part of preparing is identifying the information needed for the battery passport and understanding the current situation.
- What information must the battery passports contain for the batteries our business is responsible for?
- Where is this information currently stored?
- Are we missing any of the required information?
- Where or from whom can we obtain the missing information?
It is also important to understand and establish a process for managing the battery passport. What level of implementation are you aiming for? Who is responsible for each type of information? Where will the battery passport be maintained?
Would you like to find out how the Batteries Regulation and battery passport affect your business? Contact Ecobio’s experts for support with implementing the battery passport.
Contact us!