EU battery passport: requirements and checklist for 2027
Last updated: November 5, 2026.
From February 18, 2027, every EV battery, every LMT battery, and every industrial battery above 2 kWh placed on the EU market needs a digital battery passport under Regulation 2023/1542, Article 77. The passport is an individual, QR-accessible record of the battery's identity, materials, carbon footprint, performance, and circularity data.
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The battery passport applies from February 18, 2027
Who is covered, from when
The battery passport applies to every EV, LMT, and industrial battery above 2 kWh placed on the EU market from February 18, 2027, at individual battery level.
It covers batteries sold on their own and batteries installed in products. An e-bike placed on the EU market contains an LMT battery that needs its own passport. Responsibility sits with whoever first places the battery on the EU market; the work can be delegated in writing, the legal responsibility cannot.
The six data areas a battery passport joins
Product identity and manufacturer · materials and components, including critical raw materials · supply chain and origin · performance and durability, including state of health · carbon footprint and environmental information · documentation, certificates, and dismantling and recycling instructions. Roughly ninety data points in total, some public, some restricted to regulators and operators with a legitimate interest.
The requirements checklist
| Requirement | What it means in practice |
|---|---|
| Unique identifier + QR code | Each battery carries a QR code resolving to its own passport; persistent, ISO-compliant identifier |
| Individual battery level | Model-level records are insufficient; serialization is required |
| Defined data attributes | The regulation's categories, from carbon footprint class to recycled content and state of health |
| Tiered access | Public attributes for anyone who scans; restricted attributes for authorities and legitimate-interest operators |
| Updates over the battery's life | State of health and ownership-phase data keep the passport current after sale |
| Verifiability | The record must be trustworthy; cryptographic signing makes it checkable |
How many of these can you check off today? The readiness check takes 3 minutes and sends you a detailed gap report by email.
Check your readinessThe timeline
Delegated and implementing acts refine technical details, but the obligation and the date are fixed in law. Battery is the first product group with a hard passport deadline; further product groups follow in waves through 2030.
From your existing data to a registered passport
The data a battery passport needs already exists in most companies, spread across ERP, PLM, supplier declarations, test reports, and certificates. The path: connect those sources into one product model, validate against the battery data requirements, sign, publish at a unique URL behind the QR code, and keep it updated as the battery lives. That is the seven-step lifecycle the Data Graphs platform runs.
Data Graphs' Digital Product Passport solution turns the ERP, PLM, and spec-sheet data manufacturers already have into registry-ready passports. Solution Partner for GS1 Germany and GS1 Switzerland.
Want to see what a DPP could look like with your data?
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FAQ
Do we need GTINs first?
No. The product model manages unique identifiers with or without GTIN; GS1 identifiers can be added when you are ready.
What changes when delegated acts update?
The passport views adapt on the existing product model; changing requirements become configuration, never a rebuild.
We buy packs from Asia under our own brand. Whose problem is this?
Yours: the importer placing the battery on the EU market carries the obligation.
See what a Battery passport looks like with your data
A short, personalized session with our DPP expert. No preparation or data upload required.
Sources: Regulation (EU) 2023/1542 (EUR-Lex)Article 77, battery passport