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The Battery Passport Guide (2027)
The battery passport mandatory from 18 February 2027 under EU Battery Regulation 2023/1542 — scope, Annex XIII data fields, access tiers and how to prepare.
The battery passport is the European Union's first mandatory digital product passport. Its basis is not ESPR but the EU Battery Regulation (EU) 2023/1542, and its date is fixed: 18 February 2027. From then on, every EV battery, LMT (light means of transport) battery and industrial battery above 2 kWh placed on the EU market needs a passport reachable through a QR code.
Scope
| Battery type | Passport required? |
|---|---|
| Electric vehicle (EV) battery | Yes |
| LMT battery (e-scooter, e-bike) | Yes |
| Industrial battery > 2 kWh | Yes |
| Industrial battery ≤ 2 kWh | No |
| Portable / consumer battery | No |
| SLI battery | No |
Data requirements: Annex XIII
Article 77 of the Battery Regulation governs the passport, Article 78 its technical design and Annex XIII its data content. The Battery Pass Consortium mapped roughly 90 mandatory data attributes (~107 data points in its own model). Access is tiered:
Public (anyone scanning the QR)
- Battery identity: model, category, chemistry
- Manufacturer name and location, manufacturing date
- Weight, capacity, voltage
- Carbon footprint value and performance class (kg CO2e/kWh)
- Recycled content shares for cobalt, lithium, nickel and lead
- Critical raw materials and hazardous substances
- Performance and durability parameters (rated capacity, expected cycle life)
- End-of-life collection and recycling information
Legitimate interest holders (repairers, remanufacturers, second-life operators, recyclers)
- Detailed material composition
- Disassembly information and safety precautions
- Unit-level dynamic data: state of health (SoH), battery status, usage-derived performance
Authorities, notified bodies and the Commission
- The deepest access, including detailed test results and conformity documentation
See Annex XIII data fields and state of health and dynamic data.
Phasing nuances
Not every Annex XIII field has to be populated on day one:
- Due diligence report: August 2028 at the latest. Battery due diligence obligations were pushed back two years to 18 August 2027 by Regulation (EU) 2025/1561.
- Carbon footprint fields: follow Article 7's application dates. The EV battery carbon footprint methodology delegated act has not been adopted, so the declaration duty slips with it.
- Recycled content fields: follow Article 8.
A field may stay empty while its underlying obligation is not yet in application — but the passport itself must exist on 18 February 2027.
The access rights implementing act
Article 77(9) requires the Commission to adopt implementing acts defining "legitimate interest" and download and reuse rights. The legal deadline was 18 August 2026; current expectation is Q4 2026. This act will settle who reaches the restricted tiers and on what terms. See access rights and roles.
The technical ecosystem
Batteries have the most mature technical ecosystem in the DPP space:
- BatteryPassDataModel (Battery Pass Consortium, CC-BY-4.0): a canonical RDF/Turtle model with generated JSON Schema, OpenAPI, AAS XML and JSON-LD contexts, aligned with DIN DKE SPEC 99100.
- Catena-X CX-0143: passports published as digital twin submodels in the automotive dataspace, transferred over EDC connectors.
- IDTA AAS submodel templates (02035-1..7): Digital Nameplate, Product Carbon Footprint, Material Composition, Circularity and others.
See AAS and Catena-X and the data model guide.
A readiness plan
- Scope test: which of your products meet the EV/LMT/>2 kWh definition?
- Data gap analysis: how many of the ~90 mandatory attributes exist in your systems today?
- Data agreements with cell and module suppliers: chemistry, origin and recycled content usually sit with the cell maker.
- Dynamic data architecture: how will SoH and usage data flow from the BMS into the passport?
- Serial-level identifier and QR: batteries are serialised per unit, so marking durability matters.
- Access tier policy: which role sees which field?
See what a battery passport is and running a DPP pilot.
Frequently asked questions
Has the battery passport date been delayed?
No. 18 February 2027 was reconfirmed in the Commission's May 2026 implementation update. What was delayed was battery due diligence (to 18 August 2027).
Is the battery passport part of ESPR?
No, it comes from a separate regulation. But the EU DPP Registry is designed to serve multiple regimes, and battery passports will use that infrastructure.
Do I really have to publish live state-of-health data?
Annex XIII opens unit-level dynamic data to legitimate interest holders. In practice this means writing BMS data into the passport periodically; a real-time stream is not required.
I export batteries or packs into the EU. Does it apply to me?
Yes, if the product is placed on the EU market. The legal addressee may be the importer, but the manufacturer is the party expected to supply chemistry, origin and carbon data.
Is the 2 kWh threshold per cell or per pack?
It applies to the rated energy of the industrial battery placed on the market — that is, at pack or system level.
