Understand / Practical guide
EU battery passport
From 18 February 2027, each light means of transport (LMT) battery, electric vehicle (EV) battery and industrial battery with capacity greater than 2 kWh placed on the market or put into service must have a battery passport under Article 77 of the Batteries Regulation.
Test scope before planning a passport
| Battery category | Article 77 passport scope | Practical check |
|---|---|---|
| LMT | Covered | Confirm the regulatory category, rather than a marketing name. |
| Electric vehicle | Covered | Do not apply the industrial 2 kWh threshold to EV batteries. |
| Industrial | Covered above 2 kWh | Document category and rated capacity evidence. |
| Other batteries | Not automatically covered by Article 77 | Other QR, labelling and information requirements may apply. |
Basis: Regulation (EU) 2023/1542, current consolidated Article 77. Check definitions and current amendments for borderline products.
Data is specific to the battery
The passport combines model information with information about an individual battery, including relevant lifecycle information. Annex XIII and related measures govern content and access. Do not publish every record to the general public: different information classes have different audiences.
The Commission’s August 2026 guidance assembles 71 data points with category-specific applicability. Some are conditional or not required to be displayed at the initial start date. It is a mapping aid, not a new legal requirement or authoritative interpretation. Read the guidance announcement and linked data-point document.
An implementation workstream
- Classify the battery and identify the operator responsible for the passport.
- Map the applicable data points to model, individual battery and lifecycle records.
- Identify measurement methods, supporting evidence and update ownership.
- Connect battery identity, carrier, access service and authorised data views.
- Plan registry interaction against current technical documentation.
- Test access restrictions, continuity and lifecycle handoffs before rollout.
Keep battery information requirements separate from other obligations such as carbon footprint, due diligence and labelling; a shared programme can have several legal schedules.
Responsibilities do not disappear through outsourcing
A platform may store or process data for the responsible operator, but the operating arrangement must preserve the required availability, integrity and rights. Contract for evidence, updates, access controls and service continuity. Battery reuse, repurposing, remanufacturing and recycling can affect passport responsibilities and lifecycle handling. Review Articles 77–78 for your actual operating model.
The consolidated text links battery unique identifiers to the ESPR registry. That technical connection does not make the two legal datasets interchangeable.
Carrier, lifecycle and access details to design explicitly
Article 77 connects the passport through the Article 13 QR code to a unique identifier. Use the specified identifier standards or their permitted equivalents. Treat label-to-battery matching as a production control, not just a website function.
For preparation for reuse, repurposing or remanufacturing, Article 77 provides for changed responsibility and a new passport linked to the original passport or passports. The regulation also states that a passport ceases to exist after recycling. A single “keep everything forever” setting does not model those lifecycle rules.
Separate public data, authority/notified-body access and legitimate-interest access. Article 77(9) provides for further access specifications. The Commission website’s planning material lists a battery access-rights implementing act in Q4 2026; the research for this release did not establish a final adopted instrument for that point. Verify the current act before finalising restricted access rather than treating a legislative target date as proof of adoption. Commission development timeline.
Questions to resolve before going live
| Question | Evidence to retain |
|---|---|
| Who owns each update? | Responsibility matrix for manufacturer, operator and lifecycle partners. |
| Which fields apply now? | Cited field mapping with applicability conditions and unresolved issues. |
| Who can access restricted data? | Access policy and negative test results. |
| What if the provider stops operating? | Continuity arrangement and tested recovery procedure. |
| What happens at lifecycle transfer? | Handoff protocol and change history. |
A readable scan page is only one acceptance test. Test the exact battery record, authorised machine access and the next lifecycle event.
Sources for this guide
- Batteries Regulation — current consolidated text
- European Commission: battery passports
- Commission: battery-passport guidance update, 21 August 2026
- Commission: DPP Registry launch, 20 July 2026
Reviewed 4 October 2026. Check the current legal text and applicable product measures before acting.