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 affected parties, including all questions of scope, are covered in the guide Battery passport obligation: from when and for whom?

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.

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.

Two particularities are worth knowing. First, the Commission guidance of 28 July 2026 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:

The registry implementing regulation (EU) 2026/1778 has been applicable 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 register works in detail is covered in the guide EU battery passport registry.

Common mistakes in preparation

• Misjudging the CO2 obligation. The CO2 declaration is often presented as an applicable obligation. In fact, the CO2 obligations are not triggered for lack of the methodology and format acts, and the Commission guidance explicitly classifies CO2 declaration, CO2 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 DPPs cannot yet be registered in the EU registry, and the registry APIs including documentation are only coming in the fourth quarter of 2026. Plan the connection, but do not tie internal commitments to EU building blocks that do not yet exist.
• Underestimating identifiers and verification. The UPI requirement with URL format and at most 50 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.