Battery Passport: When Is It Mandatory?

Update July 2026: The EU registry has been live since 20 July 2026; battery registration itself is not yet enabled there. Details: The EU DPP registry is live. Whether a service provider may register on your behalf is still not settled; the dates are in having your battery passport registered.

Quick Check: Is Your Battery Affected?

Not every battery requires a battery passport. The EU Battery Regulation (EU 2023/1542) distinguishes five categories, but only three fall under the battery passport requirement:

Energy storage manufacturers are among those affected, see battery passport for energy storage. For the practical implementation, see battery passport software.

Quick rule: Electric vehicle batteries and LMT batteries need a battery passport regardless of their capacity. Industrial batteries, including stationary battery energy storage systems, need one above 2 kWh. The 2 kWh threshold in Art. 77(1) applies to that one category only.

Deadlines by Battery Type

Art. 77(1) of the EU Battery Regulation sets one and the same date for all three affected battery categories. The table shows it together with the time still remaining:

All three affected categories share the same deadline: 18 February 2027. From this date, batteries of these types may no longer be placed on the EU market without a valid digital battery passport. In addition, the unique identifier of every battery must be findable in the EU Battery Passport Registry from this date. For a detailed timeline of all regulatory milestones, see our article EU Battery Regulation 2027: Timeline and Requirements.

What Does Placing on the Market Mean?

The term placing on the market is critical and often misunderstood. Under EU law, it means the first making available of a battery on the EU market. Specifically:

• Affected: Any battery that is sold, imported, or delivered to a customer in the EU for the first time from 18 February 2027 onwards
• Not affected: Batteries that are already on the market before the deadline, even if they are resold afterwards
• Edge case: Batteries produced before the deadline but sold for the first time afterwards. The date of first sale counts, not the production date

This means: If you produce a battery on 17 February 2027 and deliver it to a customer in the EU on 19 February 2027, you need a battery passport.

Special Case: Importers and Distributors

The battery passport requirement does not only apply to manufacturers. Importers and distributors also bear responsibility:

• Importers must ensure that every battery they bring into the EU has a valid battery passport. They may not import batteries without one.
• Distributors may only sell batteries that comply with the regulation. If they suspect non-compliance, they must notify the relevant market surveillance authority.
• Fulfillment service providers (e.g., Amazon FBA, logistics centers) are also held responsible when they make batteries available on the EU market on behalf of a non-EU manufacturer.

Without a battery passport, an affected battery may not be placed on the EU market from that date.

The other deadlines of the regulation, often overlooked

18 February 2027 is the date for the passport. Other deadlines run alongside it, hit the same business and partly depend on conditions. In order:

• Separate collection symbol, since 18 August 2025: all batteries carry it under Article 13(4) together with Annex VI Part B. This deadline depends on no further act and already applies.
• General labeling, 18 August 2026, but not triggered: Article 13(1) to (3) name 18 August 2026 “or 18 months after the date of entry into force of the implementing act referred to in paragraph 10, whichever is the latest”. That act on the labeling format is missing, so the duty does not yet bite.
• Carbon footprint declaration, staggered and likewise conditional: Article 7(1) names 18 February 2025 for electric vehicle batteries and 18 February 2026 for rechargeable industrial batteries, each “or twelve, respectively 18 months after the date of entry into force” of the delegated act on the methodology and the implementing act on the format. Both are missing; for LMT batteries the regulation names 18 August 2028, for industrial batteries with external storage 18 August 2030.
• Due diligence, 18 August 2027: Article 48 originally applied from 18 August 2025; Regulation (EU) 2025/1561 moved the date by two years. Under Article 47 the chapter does not apply to economic operators with a net turnover below EUR 40 million in the financial year before last, provided they do not belong to a group exceeding that figure on a consolidated basis.

When your own business becomes the one placing on the market

The regulation defines placing on the market as “the first making available of a battery on the Union market”. Who takes that role depends on what happens to the battery, not on the size of the business. Three cases come up again and again:

• Assembling cells into a battery: yes. If you build a new battery from cells or modules and make it available for the first time, you place it on the market and carry the passport duty.
• Installing a finished battery: no. Buying a battery that is already on the market and fitting it into a device or vehicle does not make you the one placing that battery on the market. The duty stays with whoever made it available first.
• Repair or remanufacturing: it depends. A repair changes nothing about the role. But where the battery is prepared for re-use or repurposing, repurposed or remanufactured, Article 77(7) moves the duty to whoever places it on the market afterwards; the battery then needs a new passport linked to the original one.

One edge case: anyone who first uses a battery in the Union without it having been placed on the market before is “putting it into service”; that also triggers the passport duty, see Article 77(1).

What the passport contains: four blocks under Annex XIII

The deadline alone does not tell you what to collect by then. That is in Annex XIII of the Battery Regulation, split into four numbered blocks. Article 77(2) assigns three access levels to those blocks, and that assignment decides who gets to see which line.

The Commission has counted how many individual entries sit behind them: its guidance “data points by category” of 15 August 2026, version 2.0, lists 71 data points and assigns each one its mandatory status per battery category and its reference in Annex XIII. Not every one of these data categories applies to you: which points are mandatory depends on the battery type.

• Annex XIII point 1, public. 19 items from (a) to (s): the information in Annex VI Part A, material composition, carbon footprint, responsible sourcing, recycled content, share from renewable sources, rated capacity, voltages, power capability, expected lifetime in cycles, temperature range, warranty period, round trip efficiency, internal resistance, C-rate of the cycle-life test, labeling requirements, the EU declaration of conformity and the waste-battery information.
• Annex XIII point 2, legitimate interest and the Commission. Detailed composition of cathode, anode and electrolyte, part numbers and spare-part contacts, dismantling information with exploded diagrams and the disassembly sequence, plus safety measures.
• Annex XIII point 3, notified bodies, market surveillance authorities and the Commission. The results of the test reports proving compliance.
• Annex XIII point 4, legitimate interest. The data on the individual battery: performance and durability values under Article 10(1), state of health under Article 14, the status as “original”, “repurposed”, “reused”, “remanufactured” or “waste”, plus charging and discharging cycles, negative events, operating temperature and state of charge.

Two points get mixed up regularly. First, the condition data are not public: cycle count, state of health and operating data sit in point 4, behind the access barrier. From that topic, only the model-level figures in point 1 are public, such as internal resistance and expected cycles. Second, the Article 14 duty on state-of-health data does not apply to every battery. Since 18 August 2024 it applies to the battery management systems of stationary battery energy storage systems, LMT batteries and electric vehicle batteries.

Who counts as a person with a legitimate interest is still open

Article 77(9) obliges the Commission to adopt an implementing act by 18 August 2026 setting out who qualifies as a person with a legitimate interest, which entries in Annex XIII points 2 and 4 they may access, and to what extent they may download, share, publish and reuse that data. As of 22 August 2026, EUR-Lex lists four amending or supplementing acts for the Battery Regulation, and none of them implements Article 77(9). The deadline has passed without the access rules being in place.

For your planning: the four blocks are fixed and so is the assignment of the lines. What is open is which role gets which key. If you sort your data by access level today, you do not have to wait for the act.

Which standards apply, and which do not

For the battery passport, only Annex XIII of the Battery Regulation is binding. It states which information belongs in the passport and who may see it, but it does not define a data structure: no field name, no data type, no format. Specifications and standards fill that gap, and those two are regularly confused with one another.

The DIN DKE SPEC 99100, version 2025-02, sorts the information into seven categories and names attributes, data types and obligation levels. It is not a standard in the narrow sense, however, but a publicly available specification produced under the PAS procedure, drawn up and funded by a consortium in a workshop. Using it is voluntary and does not replace a check against the regulation itself.

Alongside it, the joint committee CEN/CENELEC JTC 24 develops the European standards for the digital product passport. Six of them, EN 18216 to EN 18223, were harmonised by Implementing Decision (EU) 2026/1736, and two more are still in progress. One point matters for placing this correctly: the presumption of conformity from harmonised standards applies under the Ecodesign Regulation, not to the battery passport, which has its own legal basis.

For your preparation this means two things: use the specification as a blueprint for the data structure, and still measure completeness against Annex XIII. Anyone working from DIN SPEC 99100 alone has a clean structure but no evidence to show market surveillance authorities.

Where the data comes from and where it lives

There is no central EU database you upload your battery passport into. Article 78(c) provides that the data is stored by the economic operator responsible under Article 77(4) or (7), or by operators authorised to act on their behalf. The passport stays with you or your service provider, and the EU registry only points to it.

Three further requirements from Article 77(5) and Article 78 shape the choice of tooling:

• Transferable without vendor lock-in. The data must be based on open standards, interoperable, machine-readable, structured and searchable. A provider that will not hand your passport data back in full makes you a prisoner of its format.
• No resale by the provider. Whoever stores or processes the data on your behalf may not, under Article 78(d), sell or reuse it beyond what the storage and processing service requires.
• Available even without you. Under Article 78(e) the passport remains available even if the responsible economic operator ceases to exist or stops operating in the Union.

Data spaces such as Catena-X are an option, not an obligation

In the automotive world, data exchange increasingly runs through Catena-X, the industry data space of Catena-X Automotive Network e. V., whose reference building blocks are open in the Eclipse project Tractus-X. A supplier already connected there will want to carry the passport there too. It is not a legal precondition for the passport obligation: the Regulation requires interoperability and portability, not membership of a particular ecosystem. The same goes for the Asset Administration Shell under IEC 63278-1:2023, discussed as a carrier but nowhere prescribed.

The route out of your own systems

The master data for point 1 is usually already with you: item master and bill of materials in the ERP, product copy and images in the PIM, test reports and design data in the PLM. What is missing is rarely the information itself but the serialisation: the passport attaches to the individual battery, while your ERP normally only knows the model. In practice three routes work, and they do not exclude each other: manual entry for small series, a CSV import from your existing export, or an interface that creates the passport automatically on shipment.

What Happens Without a Battery Passport?

The consequences are clearly defined and severe:

• Market access ban: Batteries without a valid battery passport may not be sold in the EU. No passport = no market access.
• Fines: Art. 93 leaves the amounts to the member states and only requires penalties that are effective, proportionate and dissuasive. In Germany, section 60(3) BattDG sets three tiers, and the top one of up to 500,000 euros covers supply chain due diligence, not the passport, which sits in the remaining cases at up to 10,000 euros; the details are in our article on battery passport penalties.
• Product recalls: Market surveillance authorities can order that batteries already placed on the market be withdrawn.
• Reputational damage: Official reports of violations are publicly accessible and can permanently damage trust with business partners and customers.

Why You Should Not Wait Until 2027

The deadline may sound far away. It is not. Creating a battery passport requires:

• Supplier coordination: Your cell suppliers must provide material composition and origin certificates. This takes months.
• Carbon footprint: Calculating it under the PEF category rules requires data from the entire value chain. This is preparatory work, not a condition for February 2027: the non-binding European Commission guidance of 28 July 2026 lists the carbon footprint declaration and the carbon footprint label as “not to be filled/displayed as of February 2027”.
• Internal processes: Responsibilities, data flows, and approval processes must be defined.

For a practical guide on transitioning to a digital battery passport, see our article From Excel to Battery Passport. An overview of all preparation steps is available in our Battery Passport Checklist 2027.

For a detailed creation walkthrough, see How to Create a Battery Passport: 7-Step Guide. For a breakdown of implementation costs, see Battery Passport Costs.

Who sees what: the three access levels

The deadline brings not only the duty but also a sorting of the data. Article 77(3) splits passport content into three levels. Public, readable through the QR code, are the entries under Annex XIII point 1, the general model data. Authorities only, more precisely notified bodies, market surveillance authorities and the Commission, get points 2 and 3. And points 2 and 4 are seen by persons with a legitimate interest.

Who that covers, the paragraph says itself: access must serve the dismantling of the battery including safety measures and the precise composition of the model, and be necessary so that repairers, remanufacturers, second-life users and recyclers can do their work. Your competitors are not among them.

One point is still open: under paragraph 9 the Commission determines by implementing act who in detail counts as a person with a legitimate interest, and to what extent those persons may download, share, publish and re-use the data. The legal deadline for that was 18 August 2026. Until the act arrives, set your access tiers by the regulation text itself.

Non-EU producers: the authorised representative

Where the producer sits outside the EU, Article 40(1) allows them to appoint an authorised representative, a person established in the Union appointed by written mandate which the representative must accept in writing. Paragraph 2 draws the line: not part of the mandate are the obligations under Article 38(1), the due diligence obligations under Articles 48 to 52, and drawing up the technical documentation. So the representative can keep documents available and deal with authorities, but conformity, the due diligence policy and the technical documentation stay with the producer.

Frequently Asked Questions

Does the requirement apply to batteries under 2 kWh?

For industrial batteries, no, the threshold is 2 kWh. For LMT batteries (e-bikes, e-scooters), however, the requirement applies regardless of capacity. All details for LMT manufacturers are available in our article Battery Passport for E-Bikes and E-Scooters.

What about replacement batteries?

Yes, replacement batteries placed on the market for the first time after 18 February 2027 also require a battery passport, provided they fall into one of the three affected categories.

Does every single battery need its own passport?

Yes. The regulation requires an individual battery passport per battery with a unique identifier and its own QR code, standardized via GS1 Digital Link. Learn more at What is a Battery Passport?.

Can I create the battery passport retroactively?

No, the battery passport must be complete at the time of placing on the market. Retroactive creation for already sold batteries is not provided for.

Who checks whether a battery passport exists?

The market surveillance authorities of the EU member states, in Germany typically the Federal Institute for Occupational Safety and Health (BAuA) or the respective state authorities.