If you sell e-bike and other LMT batteries, electric vehicle batteries or industrial batteries over 2 kWh in the EU, each battery needs its own battery passport from 18 February 2027 under Regulation (EU) 2023/1542.
In practice that means e-bike brands, carmakers and sellers of storage batteries, while a phone or AA battery only gets the QR code every battery carries from that date. Below is which batteries are in and out, who keeps the passport, how to get one ready and when it starts.
Where your company is based decides who keeps the passport.
Is your company established in the EU?
Pick your answer below for the right guidance.
Key facts on the battery passport duty
Below are the six facts the rest of this page builds on.
| Topic | In short |
|---|---|
| The rule | Article 77 of the EU Battery Regulation, Regulation (EU) 2023/1542 |
| Batteries | LMT batteries, electric vehicle batteries and industrial batteries over 2 kWh |
| Starts | 18 February 2027, for each battery placed on the market or put into service from then |
| Who | The company that places the battery on the EU market |
| How to reach it | The QR code on the battery, linked to a unique identifier |
| Last changed | July 2024, when the ecodesign law added the upload to the EU passport registry |
The facts follow EUR-Lex's record of the Battery Regulation in its consolidated version of 13 August 2026. For a short definition of the passport itself, see the glossary entry on the battery passport.
The same battery before and after 18 February 2027
Take one e-bike battery model sold on both sides of the date. The rules it meets on the day it goes on sale are not the same.
- Placed on the market before 18 February 2027. The battery carries its marks and its paper trail, such as the CE marking, the collection symbol and the declaration of conformity. No digital record follows it.
- Placed on the market from 18 February 2027. The same battery must also have an electronic record of its own, the battery passport, opened through the QR code on the battery (articles 13(6) and 77(1)).
The date that counts is when each individual battery is first made available in the EU, not when the model was launched (article 3(1)(16)).
What the passport holds
The passport mixes facts about the battery model with facts about the one battery in your hand, including how it has been used (article 77(2)). Annex XIII sorts them into three levels of access.
- Open to anyone. Label details, chemistry and materials, carbon footprint, recycled content, capacity, expected lifetime and the declaration of conformity.
- Open to those with a legitimate interest. Detailed composition, spare part numbers, dismantling steps and safety measures for repairers, remanufacturers, second-life operators and recyclers, plus the battery's state of health and its charging cycles.
- Open only to the authorities. The test reports that prove the battery complies, for notified bodies, market surveillance authorities and the Commission.
Access is free for everyone, within their access rights (article 78(b)).
Batteries that need a battery passport and batteries that don't
The passport follows the battery category, not the product it sits in. Four sellers show where the line runs.
- An e-bike brand. Its battery is an LMT battery, sealed, 25 kg or less and made to drive a light vehicle. Every battery it sells, loose or fitted to a bike, needs a passport.
- A company selling home storage batteries. A stationary storage battery counts as an industrial battery wherever and by whomever it is used (article 3(1)(15)). Over 2 kWh, it needs a passport.
- A carmaker. The battery that drives an electric or hybrid car, van or truck is an electric vehicle battery and needs a passport, whatever its size.
- A power tool seller. Its battery packs are portable batteries, so they get the QR code but no passport.
The category definitions in article 3 decide each case, and the 2 kWh threshold applies to industrial batteries only.
| Category | Battery passport from 18 February 2027 |
|---|---|
| LMT battery | Yes, every one |
| Electric vehicle battery | Yes, every one |
| Industrial battery over 2 kWh | Yes, including stationary storage |
| Industrial battery of 2 kWh or less | No, QR code only |
| Portable battery | No, QR code only |
| SLI battery (starting, lighting, ignition) | No, QR code only |
For a battery without a passport, the QR code opens its label details, its declaration of conformity and its waste information instead (article 13(6)(b)). A battery built into a product counts like a loose one (article 1(3)).
Who keeps the passport in your case
The duty sits with the economic operator that places the battery on the EU market. That company makes sure the passport is accurate, complete and up to date (article 77(4)).
Established in the EU. If you make batteries or have them made and sell them under your own brand, the passport is yours. If you import them from outside the EU, it is yours as the importer, because the importer is the EU company that places the battery on the market (article 3(1)(64)).
Selling from outside the EU. When an EU importer brings your batteries in, the duty lands on the importer, but most of the data sits with you, the manufacturer.
Agree in the supply contract who builds and hosts the passport. The company responsible may give another operator written authorisation to act on its behalf (article 77(4)).
How to get a battery ready for its passport
The five steps below take a battery model from the drawing board to a passport the QR code can open on 18 February 2027. They are written for the company that places the battery on the market.
Step 1. Sort every battery by category and capacity
Start with the batteries you sell loose and the ones inside your products. Two checks decide whether a passport is needed.
- The category. LMT and electric vehicle batteries always need one, portable and SLI batteries never do.
- The capacity. An industrial battery needs one only above 2 kWh, so note the capacity of each model.
Step 2. Give each battery a unique identifier and a QR code
Each battery gets a unique identifier, a string of characters that also works as a web link to its passport (articles 3(1)(66) and 77(3)). You attribute it yourself.
The QR code on the battery points to that identifier. Both follow the ISO/IEC 15459 series of standards, and the QR code goes on every battery from 18 February 2027 (see the battery QR code in the glossary).
Step 3. Collect the data the passport must show
Much of the data overlaps with what the rest of the regulation already asks for. Ask your cell and pack suppliers for what you do not hold yourself.
- Model data. The label details, composition, carbon footprint, recycled content and performance values, to the extent they apply to the battery's category.
- Battery data. Each battery's performance values, its state of health and its status, from original to repurposed or waste.
- Use data. Charging cycles, negative events such as accidents, and operating conditions such as temperature, recorded over the battery's life.
Step 4. Host the passport and keep it up to date
You store the passport data yourself, or through an operator you authorise. That operator may not sell or reuse the data beyond the service it provides (article 78(c) and (d)).
The data must use open standards, be machine-readable and move between systems without lock-in to one provider (article 77(5)). The passport also has to stay available if your company closes or leaves the EU (article 78(e)).
Step 5. Upload the identifier to the EU passport registry
The company placing the battery on the market uploads its unique identifier to the EU's digital product passport registry (article 77(10)). The same registry serves the digital product passports of other products.
The Commission set out how the registry works in Implementing Regulation (EU) 2026/1778 of 16 July 2026, which names batteries under article 77 as one of the products it covers.
The passport after the first sale
The passport does not stay with the first seller forever. Responsibility moves when the battery changes status.
Each change of status moves the duty to a new company, under article 77(7) and (8).
- Repurposed, remanufactured or prepared for re-use. The company that places the battery on the market again takes over, and the battery gets a new passport linked to the original.
- Waste. The producer takes over, or its producer responsibility organisation (PRO) or a waste management operator selected under the EPR rules.
- Recycled. The passport ceases to exist.
Battery passport dates from 2024 to 2027
The passport itself starts on one date. Three earlier dates set up the system around it.
| Date | What happens |
|---|---|
| 18 July 2024 | The ecodesign law, Regulation (EU) 2024/1781, added the duty to upload each battery's identifier to the EU registry |
| 16 July 2026 | The Commission adopted the rules for the digital product passport registry, which covers battery passports |
| 18 August 2026 | The deadline for the Commission's rules on who has a legitimate interest (article 77(9)). In October 2026 they had not been published on EUR-Lex |
| 18 February 2027 | Every LMT battery, electric vehicle battery and industrial battery over 2 kWh placed on the market needs a passport, and every battery needs a QR code |
The February 2027 date has not moved. The Commission's December 2025 proposal to simplify the Battery Regulation does not touch the passport, and Annex XIII already sets the three levels of access while the legitimate-interest rules are still missing.
Checks and fines for a missing battery passport
The passport is checked like the rest of the battery's marking. On an LMT, electric vehicle or large industrial battery the QR code must open the passport (article 13(6)(a)), and article 13 is one of the rules a battery must meet before sale (article 5(1)).
National market surveillance authorities check batteries on the market. When one does not comply, they can require the company to fix it, withdraw it or recall it (article 79).
The regulation sets no fine of its own. Each EU country lays down its own penalties, which must be effective, proportionate and dissuasive (article 93).
The first step to take today is the sort in step 1. List every battery model you sell from February 2027, with its category and capacity, and you know how many passports you need.
Where Repax fits next to the battery passport
The passport is one part of the EU Battery Regulation requirements. The same batteries also carry extended producer responsibility (EPR), with a producer registration in each country and collection paid for there, as our overview of battery EPR shows.
Repax does not build or host battery passports. It handles the EPR side, the registrations and reports in each market.
Not sure if you are registered in every country you sell in?
We will run a demo on a representative product and discuss your specific EPR mix.
- How many EU markets do you sell into?
- Do you import from outside the EU?
Frequently asked questions about the battery passport
Below are the seven questions sellers ask most about which batteries need a battery passport.
What is a battery passport?
It is an electronic record for one individual battery, required by article 77 of the EU Battery Regulation. It holds facts about the battery model and that battery's own data, such as its state of health, and opens through the QR code on the battery.
Which batteries need a battery passport?
From 18 February 2027, every LMT battery, every electric vehicle battery and every industrial battery with a capacity over 2 kWh placed on the EU market needs one. Portable batteries, SLI batteries and smaller industrial batteries get a QR code but no passport.
When does the battery passport become mandatory?
On 18 February 2027. The duty covers each LMT, electric vehicle and large industrial battery placed on the EU market or put into service from that date. The Commission's December 2025 simplification proposal for the Battery Regulation does not change the date.
Does a home storage battery need a battery passport?
Yes, when its capacity is over 2 kWh. The regulation treats a stationary battery energy storage system as an industrial battery wherever and by whomever it is used, and industrial batteries over 2 kWh need a passport from 18 February 2027.
Do e-bike batteries need a battery passport?
Yes. An e-bike battery is an LMT battery, sealed, 25 kg or less and designed to drive a light vehicle. Every one placed on the EU market from 18 February 2027 needs a passport, whether it is sold loose or fitted to the bike.
Who is responsible for the battery passport?
The economic operator that places the battery on the EU market, usually the EU importer for a battery made abroad. It may authorise another operator in writing, and responsibility moves on when the battery is repurposed or becomes waste.
Does a repurposed battery need a new battery passport?
Yes. A battery that has been repurposed, remanufactured or prepared for re-use gets a new passport linked to the original one. The company that places it on the market again becomes responsible for keeping that passport accurate and up to date.
