From 18 February 2027, industrial batteries with a capacity greater than 2 kWh placed on the EU market or put into service must have a digital battery passport. Article 77 of Regulation (EU) 2023/1542 also covers EV and LMT batteries. The regulation has separate implementation dates for different obligations; February 2027 is not its single overall effective date.
The requirement also covers imported batteries and batteries incorporated into equipment. The economic operator placing the battery on the EU market must ensure that the passport is accurate, complete and up to date. Manufacturers, importers and equipment OEMs should agree on responsibilities before shipment.
Quick Answer
A qualifying industrial battery needs an individual electronic record, accessible through a QR code linked to a unique identifier. Prepare model information, unit-level lifecycle data, access controls and supplier evidence. Assess passport, labeling, carbon-footprint and due-diligence obligations separately.
Key Takeaways
Map applicable passport information against Annex XIII and the latest Commission guidance; do not treat a vendor field count as the legal checklist.
The QR code must link to the individual passport and satisfy applicable marking and identifier requirements. Laser engraving is one possible method, not a universal legal requirement.
Battery due-diligence obligations begin on 18 August 2027 for operators within their scope. They are separate from the February 2027 passport deadline.
Classify each product and assign data responsibilities before selecting a passport platform.
Part 1: EU Battery Passport Scope and Timeline
1.1 Which Industrial Batteries Need a Passport?
Article 77 covers industrial batteries greater than 2 kWh, as well as EV and LMT batteries, from 18 February 2027. See the EU Batteries Regulation for the legal requirements.
Assess each battery model and the actual product boundary. A 48 V, 40 Ah pack represents approximately 1.92 kWh, while a 48 V, 50 Ah pack represents approximately 2.40 kWh. These are engineering examples using nominal voltage and rated capacity; confirm the declared energy and regulatory category for the supplied battery.
1.2 Category, Market Role and Other Obligations
Battery categories are defined in Article 3. Industrial batteries include batteries specifically designed for industrial uses and other batteries covered by that definition. Application names alone do not determine classification: document intended use, design and relevant category criteria for robotics, machinery or stationary storage packs.
An industrial battery at or below 2 kWh is outside the industrial-battery passport threshold, but may still face QR-code, labeling, conformity and other obligations. Do not confuse the passport threshold with a general exemption from the Batteries Regulation.
For industrial battery projects, confirm whether the supplied product is an individual battery, a module or a complete battery system. Record the classification decision and coordinate responsibilities between the pack supplier and equipment OEM.
Part 2: Data Requirements in the Digital Battery Passport
2.1 Model Information and Applicable Data Fields
Build two linked records: a controlled model record and a record for each battery unit. Model information includes identity, chemistry and design documentation. Unit records connect the identifier to production evidence, status and applicable information generated during use.
Model information must remain accurate when designs or documentation change. Unit information needs updates appropriate to the applicable data point. A passport does not automatically require continuous cloud streaming or a live internet connection from every battery.
The Commission guidance updated in August 2026 maps 71 data points across battery categories and identifies mandatory, conditional, optional and not-yet-applicable information. Use the current industrial-battery column and legal source for each field. Avoid presenting 32 mandatory and 26 conditional fields as a permanent, universal legal rule.
The Commission guidance updated in August 2026 supports field mapping. It is non-binding and must be read alongside the regulation and applicable delegated or implementing acts.
Carbon-footprint information must follow the applicable Article 7 requirements and relevant implementing measures. Do not substitute an internal estimate or a draft methodology for the required declaration. Maintain links to supplier inputs, manufacturing data and the calculation version, and verify which obligations apply at the launch date.
Article 8 has its own phased requirements for recycled-content documentation and minimum shares. These dates and applicability conditions differ from the passport start date. Distinguish a missing record from information that is not yet legally applicable, and retain evidence for any recycled-content claim.
2.2 SoH, Lifecycle Updates and Access Rights
State of health (SoH) describes degradation and remaining performance; state of charge (SoC) describes the currently available charge. They are not interchangeable. Define each reported parameter, estimation method, operating conditions and update interval so that buyers can interpret it correctly.
Maintain a controlled lifecycle record with identifiable updates, timestamps and supporting evidence. Manufacturing, repair, repurposing and status changes may trigger updates. Audit trails and version control are useful implementation practices; the regulation does not prescribe blockchain or a particular immutable-database architecture.
For applicable operational data, define how the BMS, host controller or service tool supplies information to the passport platform. Validate parameter accuracy and the association with the correct battery identifier. Choose the communication architecture around the equipment and access requirements rather than assuming every pack needs a modem.
The passport distinguishes public information, information for authorities and notified bodies, and information available to persons with a legitimate interest. A public QR scan must not expose all confidential design or operating data. Define authentication, access permissions and change controls.
For industrial projects, establish the applicable data list, responsible owner, evidence source and update process before choosing the platform. Missing supplier information can be a larger implementation obstacle than QR-code generation.
Specify the data available from the battery management system, including units, estimation limits and firmware version. Preserve the connection between operating data and the correct pack serial number.
Part 3: QR Codes, Identifiers and Digital Access
3.1 Standards and Identifier Allocation
Article 13 addresses QR-code marking, while Articles 77 and 78 address identification, access and passport operation. Specify a readable code, a persistent identifier and a maintained digital destination. Validate physical readability and digital access as separate requirements.
Article 77(3) cites the ISO/IEC 15459 series or equivalent standards for the QR code and unique identifier. GS1 Digital Link can be considered as an implementation approach, but it is not the only format named as mandatory by the Batteries Regulation. Confirm identifier allocation and interoperability with the selected provider.
A serial-number label or a QR code linking only to a product brochure is not a complete battery passport. The destination must provide the applicable battery information and appropriate access rights for the identified unit.
3.2 Registry, Hosting and Continuing Availability
Select a standards-based identifier and resolver approach that remains usable throughout the battery lifecycle. Document URL ownership, identifier uniqueness, access permissions, backups and migration procedures. Avoid a platform that prevents export or transfers ownership of essential records away from the responsible operator.
Article 77(10), as amended, requires the operator placing the battery on the market or putting it into service to upload the unique identifier to the registry referred to in the Ecodesign for Sustainable Products Regulation. Confirm the operational submission process against current Commission instructions; registry submission does not replace maintaining the passport.
Articles 77 and 78 require structured, machine-readable and interoperable information without vendor lock-in. Evaluate data export, backups, availability after an operator ceases activity, and the process for transferring responsibilities after repurposing or remanufacturing. Do not make passport availability depend solely on the original platform subscription.
Part 4: Physical Traceability and Supplier Evidence
4.1 Durable Marking and Readability Validation
Article 13(7) requires labels and QR codes to be printed or engraved visibly, legibly and indelibly on the battery. Where this is not possible or warranted because of its nature and size, the regulation provides a packaging and accompanying-document fallback. Do not assume a blanket exclusion of that provision for all industrial batteries.
Select marking materials and processes that maintain legibility under the intended conditions. Durable printed labels are not categorically prohibited. Evaluate abrasion, cleaning chemicals, humidity, temperature and mounting location. Laser marking may be suitable, but the method still needs validation on the actual housing.
Test the installed label or engraving with representative scanners, lighting and contamination. Keep the code away from wear surfaces and service obstructions. Confirm that scanning identifies the right unit after maintenance, label replacement and any authorized repurposing.
4.2 Passport Traceability and Raw-Material Due Diligence
Passport traceability and raw-material due diligence are related but distinct workstreams. Due diligence covers the raw materials listed in Annex X, including cobalt, natural graphite, lithium and nickel, and the associated risk framework. Determine whether the operator is subject to these obligations before defining the required evidence.
Request supplier evidence appropriate to the applicable obligation, including material identity, origin and chain-of-custody records where required. Purchasing contracts should state data responsibilities, verification rights, update triggers and how confidential information will be handled.
Article 77 makes the operator placing the battery on the market responsible for passport information, with written authorization available for another operator to act on its behalf. Chapter VII due diligence has separate scope conditions, including a turnover exemption for qualifying operators below EUR 40 million, subject to group rules. A passport obligation does not by itself prove that every supplier has the same direct due-diligence duty.
Use a controlled link between the pack serial number, cell supplier and lot, production records, bill-of-materials revision and supporting compliance documents. Mineral-origin evidence should follow applicable due-diligence requirements. Do not present a single mining database or universal geolocation workflow as a mandatory solution for every pack manufacturer.
The due-diligence start date is 18 August 2027 under Regulation (EU) 2025/1561. Assess scope, verification and reporting obligations separately from the passport workstream.
Part 5: Preparing an Industrial Battery Project for 2027
5.1 Data Ownership and System Integration
Start with a documented gap analysis covering battery category, rated energy, market role, applicable dates and evidence availability. Assign a data owner for each item and define the acceptance criteria before onboarding a passport provider.
Workstream | Evidence or Acceptance Check |
|---|---|
Product classification | Battery category, declared energy and market role |
Model documentation | Controlled chemistry, specifications and conformity records |
Unit traceability | Unique identifier linked to cell lots, BOM revision and production records |
Lifecycle data | Defined parameters, update triggers and responsible owner |
Digital access | Public and restricted permissions, backups and export test |
Physical marking | Installed code passes readability and durability checks |
Connect ERP, MES, quality records, supplier evidence and applicable BMS data through a controlled data model. Keep source documents and revision identifiers available so that a reported value can be checked. A passport platform should receive validated data rather than conceal missing evidence.
5.2 Pilot, Release Review and Service Changes
Pilot identification and marking on the actual housing. Link the QR code to a test passport, verify public and restricted access separately, and confirm identifier registration and export workflows with the platform provider. Record test results and resolve failures before production release.
Use the remaining preparation period to run a pilot across production, shipment, service and end-of-life scenarios. Include a supplier change, a corrected data entry and a failed-link recovery. These exercises reveal whether the process works beyond initial data entry.
Before launching a qualifying battery after 18 February 2027, verify its individual passport, identifier and QR access, applicable data completeness and ownership, access controls and continuing availability. Review due diligence, carbon footprint and recycled-content workstreams against their own scope and schedules.
For custom battery projects, include traceability, BMS data availability, housing markings and documentation responsibilities in the design review. These requirements affect the bill of materials, software interfaces, supplier qualification and service process.
For custom battery solutions, discuss pack identification, documentation and data interfaces with Large Power early in development. Confirm market-access responsibilities with the economic operator and passport provider. This preparation supports engineering integration without implying that a battery supplier alone certifies the entire passport system.
FAQ
Does the Passport Apply to Batteries Made Outside Europe?
Yes. Manufacturing origin does not remove the passport requirement for an industrial battery greater than 2 kWh placed on the EU market or put into service from 18 February 2027. Confirm which economic operator maintains the passport and supplies supporting information.
Which Data Fields Must an Industrial Battery Passport Include?
Use Annex XIII together with the current Commission data-point guidance. Requirements include applicable model, conformity, sustainability, performance and individual lifecycle information, with different access levels. A fixed vendor field count is not a substitute for an applicability assessment.
Is Laser Engraving or GS1 Digital Link Mandatory?
It must provide access to the individual passport through the required unique identifier and satisfy applicable standards and marking rules. GS1 Digital Link and laser engraving are possible implementation choices rather than exclusive requirements. Test readability and access on the supplied product.
When Do Raw-Material Due-Diligence Obligations Begin?
The relevant battery due-diligence obligations start on 18 August 2027 following Regulation (EU) 2025/1561. Check Chapter VII scope and exemptions separately from the battery passport requirement. Covered materials include cobalt, natural graphite, lithium and nickel.
How Should an Industrial Battery Manufacturer Prepare?
Classify each model, confirm its rated energy, identify the responsible operator and map applicable fields to evidence sources. Pilot the QR code, access controls, record updates and data exports before launch. Keep the passport linked to controlled production and service records.
Regulatory review date: 1 October 2026. Check subsequent amendments and implementing measures before product release.
