EU Battery Passport: Requirements, Data and Deadlines

Short answer

The EU battery passport is a mandatory electronic record for each EV battery, light means of transport battery and industrial battery above 2 kWh placed on the EU market from 18 February 2027. Required by the Batteries Regulation (EU) 2023/1542, it holds composition, carbon footprint, due diligence, performance and end-of-life information, accessed through a QR code.

Key takeaways

The battery passport applies from 18 February 2027 at individual battery level and is the first mandatory EU Digital Product Passport.
Access rights differ by audience: the public, notified bodies and authorities, and persons with a legitimate interest such as repairers and recyclers.
Carbon footprint declarations are not yet mandatory because the calculation methodology delegated act had not been adopted by summer 2026.
Due diligence obligations were postponed to 18 August 2027 by Regulation (EU) 2025/1561.

Which batteries need a passport?

Article 77 of Regulation (EU) 2023/1542 requires a battery passport for every:

electric vehicle battery
light means of transport (LMT) battery, such as e-bike and e-scooter batteries
industrial battery with a capacity above 2 kWh

The passport applies per individual battery, so each unit needs a unique identifier. The economic operator placing the battery on the market is responsible for the passport, including when a battery is repurposed or remanufactured, in which case a new passport is linked to the original. The QR code requirement in Article 13 applies to all batteries from the same date, 18 February 2027. As the first mandatory passport, it serves as a reference case for the wider Digital Product Passport under ESPR. The passport must be accessible through the QR code printed or engraved on the battery, which links to a unique identifier. Battery identifiers are also recorded in the EU DPP registry launched in July 2026, so customs and market surveillance authorities can check passport availability.

What data does the battery passport contain?

Annex XIII sets the content and divides it by access level.

Access level	Examples of data
Public	Manufacturer, battery category, model, weight, capacity, chemistry, hazardous substances, critical raw materials, carbon footprint, recycled content share, due diligence report, declaration of conformity, separate collection information
Notified bodies, market surveillance, Commission	Test reports demonstrating compliance
Persons with a legitimate interest (repairers, remanufacturers, recyclers)	Detailed composition, cathode, anode and electrolyte materials, part numbers, disassembly and dismantling instructions, safety measures
Battery-specific dynamic data	State of health, state of charge, usage and incident history

When a battery changes status, for example through repurposing or remanufacturing, the passport must be updated and linked to the new record.

Which parts are still pending?

Several obligations depend on secondary legislation that was delayed. At the latest information reviewed (October 2026):

Carbon footprint declaration: Article 7 applies 12 months after the delegated act setting the calculation methodology enters into force. That act had not been adopted by summer 2026, so the declaration for EV batteries is not expected before late 2027. Industrial and LMT batteries follow later.
Access rights: the implementing act on access to passport data, due in August 2026, was scheduled for Q4 2026.
Standards: six harmonised DPP standards were cited in July 2026, with standards on access rights and data integrity still in draft.
Due diligence: supply chain due diligence obligations were postponed from 2025 to 18 August 2027 by Regulation (EU) 2025/1561.

The Environmental Omnibus proposed on 10 December 2025 would suspend certain EPR authorised representative rules under the Batteries Regulation. Industry associations have lobbied for a passport postponement, though no formal Commission or Council proposal to move the 18 February 2027 date had been made at the latest update reviewed (16 October 2026).

How battery passport data maps to PLM

Battery passports combine static design data with item-level manufacturing data and dynamic in-use data. A practical split looks like this:

PLM: model definition, bill of materials, cell chemistry, material composition, critical raw materials, recycled content calculation, disassembly instructions
Compliance and LCA tools: hazardous substances, carbon footprint per manufacturing plant and model
MES and ERP: serial number, manufacturing date and place, batch links to supplier material lots
Battery management system: state of health and usage data
Passport platform: identifiers, QR code, access control and registry connection

Data ownership between the cell supplier, the pack assembler and the vehicle or equipment manufacturer needs to be agreed contractually, because the operator placing the battery on the market carries responsibility for passport content it did not create. Serialisation is the main architectural shift. Most PLM systems manage models and revisions, while the passport needs records per serial number linked back to the model revision and to supplier lots. This connection runs through PLM integration architecture with MES. Enterprise vendors such as Siemens Teamcenter, PTC Windchill and SAP PLM address this through traceability and integration with manufacturing systems, frequently in combination with dedicated passport providers.

Frequently asked questions

When is the EU battery passport mandatory?

The battery passport is mandatory from 18 February 2027 for EV batteries, light means of transport batteries and industrial batteries above 2 kWh placed on the EU market. The QR code requirement for all batteries applies from the same date. At the latest update reviewed in October 2026, no formal proposal to postpone the passport date had been made, despite industry requests.

Is the battery carbon footprint declaration already required?

No. Article 7 makes the declaration mandatory 12 months after the delegated act on the calculation methodology enters into force. That act had not been adopted by summer 2026, so EV battery declarations are not expected before late 2027. Companies are still collecting plant-level and model-level footprint data now, because the passport will need it once the obligation applies.

Does every battery need its own passport?

Yes, for the covered categories the passport is linked to each individual battery through a unique identifier as well as to the battery model. Static model data can be shared across units, while serial-specific data such as manufacturing date and place and state of health is recorded per battery. Portable batteries outside the covered categories need a QR code but no passport.

Sources

Reviewed 16 October 2026 by the PLM Vendors editorial team. Regulatory dates and vendor details change; check the sources for the latest position.