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Batteries and electronics Manufacturer · Importer 5 min read

A customer asks about the battery passport

Under Article 77 of the Battery Regulation (EU) 2023/1542, each LMT battery, every industrial battery above 2 kWh and every electric vehicle battery placed on the market from 18 February 2027 needs a battery passport, an electronic record reached through a QR code. The operator placing the battery on the market keeps it accurate and up to date. Other batteries get a QR code with label and conformity information.

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Reviewed 4 October 2026 by the Conphora compliance team · Not legal advice

Why this happens

The battery passport is the Battery Regulation's (EU) 2023/1542 digital record for the larger batteries. From 18 February 2027, each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market or put into service must have an electronic record, the battery passport (Article 77(1)). It contains information on the battery model and on the individual battery, including information resulting from its use, as set out in Annex XIII (Article 77(2)).[1]

The passport has three audiences. Part of the information is accessible to the general public: the label information, the material composition, the carbon footprint information, responsible sourcing as stated in the due diligence report, recycled and renewable content, capacity, voltage, power, expected lifetime and other performance values, the EU declaration of conformity and the waste information (Annex XIII, point 1). Part is reserved for persons with a legitimate interest and the Commission, such as detailed composition, part numbers, dismantling information and safety measures (point 2), part, the results of test reports, for notified bodies, market surveillance authorities and the Commission (point 3), and the data on the individual battery, such as its state of health, status and use, for persons with a legitimate interest only (point 4; Article 77(2)). The Commission was to specify by implementing acts, by 18 August 2026, who counts as a person with a legitimate interest and what they may access (Article 77(9)).[1]

The obligations fall on the economic operator placing the battery on the market. It attributes a unique identifier, reached through the QR code that Article 13(6) requires on the battery (Article 77(3)); ensures that the information is accurate, complete and up to date, and may authorise another operator in writing to act on its behalf (Article 77(4)); and uploads the unique identifier to the registry set up under Regulation (EU) 2024/1781 (Article 77(10)). The passport must be interoperable with other digital product passports, free of charge to access according to access rights, secure, and must remain available even after the responsible operator ceases its activity in the Union (Article 78).[1]

Batteries outside Article 77 are not left without a digital link. From 18 February 2027, all batteries are marked with a QR code; for those without a passport, it gives access to the labelling information, the EU declaration of conformity, the report on the battery due diligence policy and the waste prevention and management information (Article 13(6)).[1]

How to solve it

  1. Check whether your battery needs a passport at all

    The passport is required for LMT batteries, industrial batteries with a capacity greater than 2 kWh and electric vehicle batteries placed on the market or put into service from 18 February 2027. A portable battery in a consumer product does not need one; it needs a QR code giving access to its labelling information, declaration of conformity and waste information.

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  2. Map the data Annex XIII asks for

    List the public information on the battery model (label data, material composition, carbon footprint, responsible sourcing, recycled content, performance and durability values, the declaration of conformity, waste information), the model information for persons with a legitimate interest and the Commission (detailed composition, part numbers, dismantling and safety measures), the test-report results reserved for notified bodies, authorities and the Commission, and the data on the individual battery (performance values, state of health, status, use) reserved for persons with a legitimate interest (Annex XIII, points 1 to 4). Note who in your supply chain holds each item.

  3. Decide who operates the passport for you

    The operator placing the battery on the market attributes a unique identifier, ensures the information is accurate, complete and up to date, and may authorise another operator in writing to act on its behalf. A service provider that stores the data may not sell, re-use or process it beyond the service.

  4. Prepare the QR code, the identifier and the registry upload

    The QR code must link to the unique identifier and comply with the ISO/IEC 15459 series or equivalent. The operator must upload the unique identifier to the digital product passport registry set up under Regulation (EU) 2024/1781.

  5. Follow the implementing acts and answer the customer from the text

    The Commission specifies by implementing act who counts as a person with a legitimate interest and what they may access. Tell the customer what the regulation requires for your battery category and by which date, and do not promise data fields before they are settled.

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Work through the steps in the platform with your own product.

What you need to show

DocumentWhere it comes fromLegal ground
The battery passport (electronic record)The economic operator placing the battery on the market, or an operator it authorises in writingBattery Regulation Article 77(1) and 77(4)
The QR code and unique identifierThe economic operator placing the battery on the marketBattery Regulation Articles 13(6) and 77(3)
The EU declaration of conformity, accessible through the passportThe battery manufacturerBattery Regulation Annex XIII, point 1(r)

If you do nothing

No passport, no lawful placing on the market

From 18 February 2027, each LMT battery, industrial battery above 2 kWh and electric vehicle battery placed on the market or put into service shall have a battery passport (Battery Regulation Article 77(1)); a non-compliant battery can be required to be brought into compliance, withdrawn or recalled (Article 79(1) where it presents a risk; otherwise Regulation (EU) 2019/1020, Article 16).[1]

Inaccurate data is your responsibility

The operator placing the battery on the market must ensure that the passport information is accurate, complete and up to date, even where another operator acts on its behalf (Battery Regulation Article 77(4)).[1]

Penalties under national law

Member States lay down effective, proportionate and dissuasive penalties for infringements of the regulation (Battery Regulation Article 93).[1]

Questions about this problem

Does a power bank or a phone battery need a battery passport?

Not under Article 77, which covers LMT batteries, industrial batteries above 2 kWh and electric vehicle batteries. From 18 February 2027 all batteries need a QR code; for other batteries it gives access to the labelling information, the declaration of conformity, the due diligence report and waste information (Article 13(6)(b)).

Who can see what is in the passport?

Part is public, part is reserved for persons with a legitimate interest and the Commission, part for notified bodies, market surveillance authorities and the Commission, and the data on the individual battery, such as its state of health and use, for persons with a legitimate interest only (Battery Regulation Article 77(2) and Annex XIII, points 1 to 4).

What happens to the passport if the battery is repurposed?

The operator that places the repurposed or remanufactured battery on the market takes over responsibility, and the battery gets a new passport linked to the original one (Article 77(7)). A passport ceases to exist after the battery has been recycled (Article 77(8)).

Is the battery passport the same as the digital product passport?

It is a separate record under the Battery Regulation, but it must be fully interoperable with other digital product passports required by Union law on ecodesign (Article 78(a)), and its unique identifier goes into the registry under Regulation (EU) 2024/1781 (Article 77(10)).

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Sources

  1. Regulation (EU) 2023/1542 concerning batteries and waste batteries (consolidated text of 13 August 2026) EUR-Lex · accessed 4 October 2026
  2. Regulation (EU) 2023/1542 concerning batteries and waste batteries (Official Journal L 191, 28.7.2023) EUR-Lex · accessed 4 October 2026

About this page

Reviewer
Conphora compliance team
Reviewed
4 October 2026
Cite this page
Conphora (2026). A customer asks about the battery passport. Retrieved 13 October 2026 from https://www.conphora.com/solutions/problem/battery-passport/
Reviewed
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