What the battery passport requires and who has to provide it

A battery passport is a digital record of one specific battery, reached through a QR code, that carries its identity and its lifecycle data under Article 77 of Regulation (EU) 2023/1542. It becomes mandatory on 18 February 2027 for electric vehicle batteries, light means of transport batteries and industrial batteries over 2 kWh placed on the EU market. The duty sits with the economic operator placing the battery on that market. The work, though, is spread across everyone who touched the cell, which is why the code on the label is the easy half.

2026-08-05

## Which batteries need one and from when?

The date is 18 February 2027 and the scope names three groups. Electric vehicle batteries are in. Light means of transport batteries are in. If you are unsure whether your vehicle falls inside that category, read the definition in the regulation rather than a vendor page, because the category boundary is where the argument usually is. Industrial batteries are in above a rated capacity of 2 kWh. Below that figure the Article 77 duty does not reach your product, which tells you nothing about whether the rest of the regulation does.

## What data does a passport have to carry?

The field list is set out in the regulation and its annexes. Those were not read at source for this page, so no field list is printed here for you to copy into a data model. The shape of the thing is safe to describe. A passport identifies one battery rather than a product line, so the identity data has to resolve to a single unit. It carries information about what the battery is made of and about how it has been used. Some of that exists before the battery ships. Some of it only exists years later. Anyone selling you a definitive field list should be asked which annex it came from and which version of the text they read.

## Who owns each field?

This is the part that takes months. It is not a legal question at all. Cell identity and cell chemistry data can only come from the cell maker. Pack level identity, the build record and the serial number a QR code resolves to come from whoever assembles the pack. Data about how the battery behaved in service comes from the operator or from the system it sits in, so it arrives long after the sale. End of life data comes from a recycler you may not have chosen yet. Four positions, four different companies, one record.

## Who has to provide it?

The economic operator placing the battery on the EU market. In plain terms that is the company whose name is on the product when it first enters circulation in Europe. If you import finished packs and sell them as your own, the honest working assumption is that the duty is yours until somebody reading your contracts says otherwise. A factory outside the EU can help you fill the record. It cannot carry your obligation for you.

## Is the QR code the passport?

No. The code is the way in. Article 13 puts the labelling and QR code duties on the battery. Where the battery is too small to carry them, they move to the packaging and to the accompanying documents. So the marking system and the label are one purchase. The record behind the code, its hosting and its access rules are another. Buying one and assuming it covers the other is expensive and it is the mistake a marking quote makes easy.

## What is not settled?

The carbon footprint declaration is pending. Its delegated act had not been shown to be in force at the time of writing, so this guide attaches no date to it. Treat any carbon footprint timeline you are shown as a claim to check rather than a deadline to plan against and ask the person showing it to you which act they are quoting.

## How do you prepare without guessing?

Start with the data you already cannot produce. Take one real product, write out its identity fields and try to fill them from the records you hold today. The gaps are your project plan. Then ask each company in your chain, in writing, which of those fields they can give you and in what format. Decide who hosts the record and what happens to it if that vendor disappears, because a passport that stops resolving is worse than no QR code at all. None of that work needs the final field list to begin.

## What this page is built on

The date, the scope and the article number here came from secondary summaries of Regulation (EU) 2023/1542. Nobody on this site has read the Official Journal text for them. Two summaries agreeing is not corroboration either, since they often copy one another. Before you write a data specification or sign a software contract, read Article 77 and the annexes it points to in the published text. Confirm the field list there rather than here.