Battery passport: the complete overview

Who is affected?

The passport obligation of Article 77 covers exactly three battery categories:

• LMT batteries, i.e. batteries for light means of transport such as e-bikes and e-scooters,
• industrial batteries with a capacity above 2 kWh, which in the regulation's system also includes stationary energy storage,
• EV batteries, i.e. traction batteries for electric vehicles.

What counts is the placing on the EU market from 18 February 2027. Where the battery was manufactured does not matter: responsible for the passport is the economic operator who places the battery on the EU market. This applies to manufacturers based in the EU as well as importers bringing batteries or battery-powered products in from third countries. For other batteries, such as classic portable batteries, Article 77 does not provide for a passport obligation.

Also important: the passport applies per battery, not per model. Every single battery placed on the market needs its own passport with its own identifier, reachable via the QR code on exactly that battery. This makes the battery passport a task for your series production processes, not just for the documentation department.

Details on deadlines and who is affected are in the guide battery passport duty.

Data scope: Annex XIII explained

Annex XIII of the Battery Regulation defines which data belongs in the battery passport and who may see it. There are three access tiers.

Public data

This part of the passport is visible to anyone who scans the QR code: no login, no cost. Which data points are public is listed in Annex XIII point by point; the Commission guidance states the Annex XIII reference and the mandatory status for each of the 71 data points.

View a filled example passport

Restricted data

A second group of fields is accessible only to persons with a legitimate interest and to the Commission. How this legitimate interest is to be demonstrated is meant to be defined in a dedicated implementing act under Article 77(9). This act has not been adopted; the Commission's planning now points to the fourth quarter of 2026. The original deadline of 18 August 2026 has passed; as of 19 August 2026, no act has been published.

Authority data

For authorities, Annex XIII additionally reserves the test reports.

Data that grows with the battery

A second distinction runs across the access levels. Annex XIII point 4 holds data on the individual battery that changes over its life. That covers performance and durability values at placing on the market and at every change of status, the state of health under Article 14 and the status in five stages: original, repurposed, reused, remanufactured or waste. Added to those are the data from use such as charging cycles, negative events, operating temperature and state of charge. For state of health and expected lifetime, Annex VII names the parameters in detail. Since 18 August 2024 the battery management system must keep them current under Article 14(1). The remaining entries, accidents or state of charge for example, are not in Annex VII. They belong in the passport, not necessarily in the battery management system.

These entries belong to the second level. They are not public but reserved for persons with a legitimate interest. Under Article 77(4) the economic operator placing the battery on the market must keep them current. They may authorize others in writing, the responsibility stays with them. How that works in practice is in the guide battery passport software.

Two particularities are worth knowing. First, the Commission guidance of 15 August 2026 (version 2.0) explicitly classifies some prominent data points as “Not to be filled/displayed as of February 2027”, among them the carbon footprint declaration, the carbon footprint label, the responsible sourcing information, the rated capacity in ampere-hours and the material composition. These points are waiting for format or methodology acts and deliberately remain empty at the start. Second, the recycled content shares for cobalt, lithium, nickel and lead are each individually mandatory.

On the carbon footprint in plain terms: the CO2 obligations of the Battery Regulation are not triggered as of today. The fixed dates named in the law have passed, but the start depends on the methodology act and the format act, and both are missing. There is currently no applicable CO2 declaration obligation for the battery passport.

EU registry: the status in August 2026

Alongside the passport itself, the EU requires registration in a central Commission registry. The status today:

Implementing Regulation (EU) 2026/1778 has been in force since 6 August 2026. It describes the registry as a directory: stored are identifiers, commodity code and a hash, not the passport contents themselves. The regulation contains no technical schemas.

A sandbox (acceptance environment) of the registry has been reachable since 20 July 2026, with its own EU login. Trying it out is worthwhile, but with one important limitation: registration of battery DPPs is still blocked on the EU side because the semantic catalogue is missing. This is stated explicitly in the Commission's user guide. The EC helpdesk has announced the semantic catalogue and the registry APIs, including full documentation, for the fourth quarter of 2026.

For registration itself: only a verified economic operator may register. Verification runs through a qualified seal or a qualified signature under eIDAS and is valid for at most three years. Third parties may register on an operator's behalf if they are verified themselves; nobody can take over the economic operator's own verification. A DPP service provider, by the way, is not a defined actor under the Battery Regulation: an official list or recognition procedure for providers does not exist, and the related delegated act is expected around the second quarter of 2027.

From 18 February 2027, registration becomes mandatory: affected batteries must be registered when placed on the market.

How the registry works in detail is covered in the guide EU battery passport registry.

The second life: repurposing, reuse and the new passport

A battery rarely ends where it was sold. A vehicle pack becomes a home storage unit, a faulty module becomes a remanufactured one. The Regulation knows these routes, names them individually and attaches the passport to them.

• Article 3 distinguishes four operations. Point 29 is preparing for re-use, point 30 preparing for repurposing. Point 31 is repurposing itself, point 32 remanufacturing. Repurposing means: the battery is not waste, but is used for a purpose other than the one it was designed for.
• Article 77(7) draws the consequence. It covers batteries prepared for re-use or repurposing, repurposed or remanufactured. For them responsibility passes on. It rests with the economic operator who placed the battery on the market. These batteries need a new passport, linked to that of the original battery.
• The status sits in the passport itself. Annex XIII point 4(c) requires the entry “original”, “repurposed”, “reused”, “remanufactured” or “waste”. Once the battery becomes waste, responsibility passes on. It then rests with the producer, the producer responsibility organisation or the selected waste operator.
• At the end comes deletion. Under Article 77(8) the battery passport is deleted once the battery has been recycled.

For residual value, Article 14(2) is the decisive lever. Anyone who has lawfully acquired a battery gets read access through the battery management system to the parameters in Annex VII, among other things to assess residual value, remaining lifetime and the scope for further use. This duty has applied since 18 August 2024 and covers stationary battery energy storage systems, LMT batteries and electric vehicle batteries.

In practice: do not plan the passport as a one-off handover on the day of sale. Plan it as a record that survives a change of status. It has to connect for the next operator.

What the passport delivers beyond the obligation

The compulsory part is not in dispute. Less discussed is that the same data set answers questions companies already have.

• After-sales and service: the QR code leads to a unique identifier of the individual unit. Seeing version, build state and safety notes at once saves queries and wrong parts.
• A direct line to the end customer: the scan lands on your passport page. Not at a dealer, not at a portal. It is the only channel in the chain that belongs to you.
• Evidence instead of claims: recycled content, carbon footprint and responsible sourcing sit in the public block. Documented properly, you point to a source in a purchasing meeting instead of a brochure.
• Second-hand market: only sight of state of health and usage history makes residual value and further use assessable.

Soberly put: these effects do not arrive on their own. They need maintained data. The passport is a shop window, and an empty one looks worse than none.

Common mistakes in preparation

• Misjudging the CO2 obligation. The carbon footprint declaration is often presented as a duty in force. In fact the carbon duties are not triggered, for lack of a methodology and format act. The Commission guidance classes carbon declaration, carbon label and responsible sourcing as not to be filled for February 2027.
• Trusting a seal or certificate. There is no official certification system for battery passport software or DPP service providers, and no GEFEG or BatteryPass seal either. Read advertising claims with seals accordingly critically and check concrete evidence instead, such as schema validation of the exports.
• Overestimating harmonised standards. Decision (EU) 2026/1736 harmonises six DPP standards, but the presumption of conformity applies only to ESPR product passports. For the battery passport it has no legal effect.
• Promising fixed registry dates. Battery passports cannot be registered in the EU registry yet. The registry APIs and their documentation come in the fourth quarter of 2026. Plan the connection. But do not tie internal promises to EU building blocks that do not exist yet.
• Underestimating identifiers and verification. The UPI requirement with URL format and at most 2000 characters, the eIDAS verification valid for at most three years, and the question of who in your supply chain is the registering economic operator: all of this needs lead time and is not something for the last weeks before the deadline.
• Ignoring the access tiers. Publishing all passport data unfiltered misses the logic of Annex XIII, and holding everything back does too. The separation into public, restricted and authorities belongs in the data model from the start.
• Waiting for full legal certainty before collecting data. Individual points still depend on implementing acts, but the large majority of the 71 data points is settled. Anyone who only starts collecting supplier data in 2027 has hardly any buffer left for coordination.

What implementation can cost and which items to budget for is covered in the guide Battery passport costs.