The EU Digital Battery Passport: Requirements, Data and Traceability Explained

Reviewed 7 November 2026. A guide to the digital battery passport introduced by Regulation (EU) 2023/1542.

What is the EU battery passport?

The EU digital battery passport is one of the most significant innovations introduced by Regulation (EU) 2023/1542.

It creates a digital record for individual batteries, allowing relevant information about their identity, materials, sustainability, performance and lifecycle to be accessed throughout their working life.

Think of it as a digital identity for a battery.

Rather than relying entirely on paperwork held by different manufacturers, suppliers and operators, the battery passport provides a structured way to access information associated with a specific battery.

Its purpose is to improve transparency, support responsible battery management and make it easier to repair, reuse, repurpose and recycle batteries.

1. Which batteries need a digital passport?

From 18 February 2027, the requirement applies to relevant batteries placed on the EU market or put into service.

• Electric vehicle batteries: yes.
• Industrial batteries above 2 kWh: yes.
• Light means of transport batteries, including e-bike and e-scooter batteries: yes.
• Ordinary portable household batteries: not under Article 77.
• Conventional automotive starter batteries (SLI): not under Article 77.

The industrial-battery threshold is strictly greater than 2 kWh. The EV and LMT categories do not have that same threshold.

2. Who is responsible for creating the passport?

The economic operator placing the battery on the EU market or putting it into service is responsible for ensuring that the required passport exists.

Depending on the circumstances, this may involve:

• Battery manufacturers
• Importers
• Businesses placing batteries on the market under their own names
• Businesses repurposing or remanufacturing batteries

A third-party technology provider can create or maintain a passport on behalf of the responsible operator through written authorisation.

However, using an external software provider does not automatically transfer the operator's legal responsibilities.

3. What information must the battery passport contain?

The Regulation establishes different categories of information under Annex XIII.

Battery identification

Manufacturer information, battery model, identification numbers and relevant technical characteristics.

Sustainability information

Carbon footprint declarations, recycled material content and responsible sourcing information where the relevant requirements apply.

Performance and durability

Rated capacity, voltage, relevant durability information and battery-specific performance data.

Safety and circularity

Information supporting safe handling, dismantling, repair, reuse, repurposing and recycling.

Battery lifecycle information

Relevant information about battery condition, use, and changes such as repurposing or remanufacturing.

The European Commission has published guidance organising battery passport information into 71 data points. However, not all 71 data points are mandatory for every battery from February 2027.

For example, carbon footprint, recycled-content and due diligence information follow their own regulatory application dates.

4. Public and restricted passport information

A battery passport does not make every piece of information publicly available. The Regulation establishes different access levels:

• Public: information available to consumers and other interested parties.
• Regulatory authorities: information accessible to designated authorities and bodies.
• Legitimate interest: certain additional data for authorised parties such as repairers, recyclers and second-life operators.

Access controls matter because some battery information may be commercially sensitive or relevant to safe handling.

A compliant system must therefore do more than store information. It must also apply the appropriate access rights.

5. How the battery passport improves traceability

The battery passport links information to an individual battery through a unique identifier, accessible using a QR code.

As the battery moves through its lifecycle, relevant information can help establish its history. For example:

Manufacturing → First use → Maintenance → Repurposing → Second life → Recycling

This is especially valuable when batteries move between businesses.

A second-life operator assessing a used battery may need reliable evidence of its technical characteristics, previous condition and remaining usable capacity.

Under Article 77(7), a passport created after qualifying repurposing or remanufacturing must be linked to the original passport.

6. The role of real-time battery monitoring

A battery passport and a battery management system (BMS) serve different purposes.

The passport provides structured identity and lifecycle information.

The BMS provides measurements that may include:

• State of charge
• State of health
• Battery voltage and current
• Temperature
• Charging and discharging cycles
• Cell-level measurements

When reliable operational measurements are collected and interpreted correctly, they can help maintain relevant battery lifecycle records.

For example, a recorded state-of-health estimate supported by operational evidence may help a second-life operator assess a battery's condition.

However, not every BMS reading is required in a battery passport, and not every battery provides enough data for an accurate health estimate.

The distinction between measured values, calculated estimates and manufacturer declarations must be preserved.

7. How does the battery passport connect with the EU Digital Product Passport?

The battery passport is part of the EU's broader transition towards Digital Product Passports.

The Ecodesign for Sustainable Products Regulation (ESPR) establishes a common technical framework intended to support digital passports across multiple product categories.

Battery passport requirements originate in the EU Batteries Regulation, while their technical architecture is designed to work with the wider DPP ecosystem.

This promotes interoperability in areas such as:

• Product identification
• Structured data exchange
• Digital access methods
• Data accessibility
• Information security
• Compatibility with other digital product passports

The goal is to avoid creating entirely disconnected passport systems for different industries.

8. How should businesses prepare?

Businesses should begin preparing before the February 2027 requirement takes effect. A practical starting point is to:

1. Identify which battery categories require passports.
2. Establish the responsible economic operator.
3. Collect available manufacturer and technical information.
4. Identify missing regulatory data.
5. Establish reliable battery identification.
6. Determine which data must be public or restricted.
7. Prepare for lifecycle updates and passport linking.
8. Check current EU registry and verification requirements.
9. Test the accuracy and accessibility of passport information.
10. Assign responsibility for maintaining the records.

Conclusion

The EU digital battery passport is intended to make battery information more accessible, consistent and useful throughout a battery's lifecycle.

For manufacturers, it introduces new information-management responsibilities. For battery operators, it creates opportunities to maintain better lifecycle records. For repair, repurposing and recycling businesses, it can improve access to information needed to assess and handle batteries responsibly.

The real value of the battery passport goes beyond the QR code. It lies in the reliability of the information associated with the battery and the ability to maintain that information as the battery's condition and use change.

Official sources

• EU Battery Regulation 2023/1542 — Article 77 and Annex XIII
• European Commission — Digital Product Passport for batteries
• European Commission — Battery passport FAQ
• European Commission — Battery passport data guidance

Editorial notice: this article is for general educational purposes and does not constitute legal advice. It is reviewed quarterly, and whenever new implementing legislation or official guidance is published.