EU Battery Passports Become Mandatory in February 2027 - Is Your Business Ready?

On 18 February 2027, the EU battery passport becomes mandatory for three important groups of batteries placed on the European Union market or put into service.

These are light means of transport batteries, industrial batteries with a capacity greater than 2 kWh and electric vehicle batteries.

The same date also brings a wider QR-code requirement for batteries generally.

Those two points are often merged into one sentence, which is where the confusion begins.

Not every battery will need the full electronic battery passport described in Article 77 of the EU Batteries Regulation. From February 2027, however, all batteries are expected to carry a QR code linking to the information required for their category, with the specified larger and mobility batteries linking to a full passport.

For businesses in scope, the passport is much more than a label change.

It combines product identity, material and technical data, sustainability information, compliance records and, for individual batteries, information that can change during use.

A company that waits until January 2027 to ask its supplier for that information may find that the difficult part is not creating the QR code. This is exactly the gap a battery-focused DPP Readiness Assessment is intended to expose while there is still time to act.

It is obtaining the data behind it.

Who Does This Apply To?

Electric Vehicle and Battery Manufacturers: Electric vehicle traction batteries are directly included in the full passport requirement.

E-Bike, E-Scooter and Light-Mobility Brands: LMT batteries include sealed batteries up to 25 kg that are designed to provide traction power for qualifying wheeled vehicles and are not classed as electric vehicle batteries.

Industrial and Energy-Storage Businesses: Industrial batteries with a capacity greater than 2 kWh are within the passport scope. This can include stationary storage and batteries used across industrial equipment and infrastructure, subject to the Regulation’s category definitions.

UK Brands Exporting Battery Products to the EU: A business outside the EU may rely on an EU importer or another economic operator, but the product data and commercial responsibilities still need to be agreed before market placement.

Private-Label and Own-Brand Importers: Where the battery is produced by another company, the brand needs enough access to technical, material, testing and lifecycle information to support the passport and the wider compliance file.

Manufacturers of Equipment Containing Batteries: Batteries incorporated into products are not automatically outside the Batteries Regulation. Businesses should identify and classify the battery rather than focusing only on the finished appliance or vehicle.

Repurposing and Remanufacturing Businesses: A battery that changes status through re-use, repurposing or remanufacturing can require updated information and a new linked passport under the Regulation.

Software, BMS and DPP Providers: The passport can contain individual-battery data generated during use, so technical teams may need to connect product, battery-management and regulatory systems.

Portable batteries such as ordinary consumer cells are not included in the Article 77 full-passport categories simply because they are batteries.

They are still affected by the February 2027 QR-code requirement and other provisions of the EU Batteries Regulation.

What Does This Mean in Practice?

First, Confirm Which Battery Category Applies

The classification comes before the platform.

The full passport is required for:

• Each light means of transport battery
• Each industrial battery with a capacity greater than 2 kWh
• Each electric vehicle battery

Those categories are defined in the Batteries Regulation. A product name used by the sales team or supplier may not match the legal category.

For example, an industrial battery is not limited to something installed in a factory. The definition can include batteries specifically designed for industrial use and other batteries over 5 kg that do not fall within the EV, LMT or SLI categories.

That is why a battery schedule should record its intended use, weight, capacity, construction and relevant product category rather than just the chemistry and supplier code.

The Passport Covers the Model and the Individual Battery

The battery passport is an electronic record connected to the battery through a QR code and unique identifier.

It contains information about the battery model, but it can also include data that relates to the individual battery and its use.

That makes it different from uploading one static technical datasheet for an entire product range.

A business may need to control information at several levels:

• Model-level information shared across batteries with the same technical characteristics
• Manufacturing or product-instance information linked to the individual battery
• Lifecycle information that changes as the battery is used, repaired, repurposed or becomes waste

The product hierarchy and identifiers need to be decided early. Trying to create that structure after thousands of batteries have been manufactured can be extremely difficult.

Some Information Is Public and Some Is Restricted

The Regulation divides passport information according to who should be able to access it.

Public model information can include areas such as:

• Battery identity and general label information
• Chemistry, material composition and certain hazardous or critical raw materials
• Carbon-footprint information where the relevant requirements apply
• Responsible-sourcing and recycled-content information where applicable
• Capacity, voltage, power capability and expected lifetime information
• The EU Declaration of Conformity and relevant waste-management information

Other information is intended only for authorities, notified bodies or people with a legitimate interest, depending on the data and purpose.

This can include detailed composition, component and spare-part information, dismantling instructions, safety measures, compliance test reports, state-of-health information, battery status and use data.

A single public web page is therefore unlikely to be enough on its own.

The system needs access controls that match the legal information categories.

Every Battery Will Need a QR Code, but Not Every Battery Gets the Same Destination

From 18 February 2027, the EU Batteries Regulation requires all batteries to be marked with a QR code, subject to the rules on where it can be placed where marking the battery itself is not possible or warranted.

For LMT batteries, industrial batteries over 2 kWh and electric vehicle batteries, the code provides access to the battery passport.

For other battery categories, it provides access to the information specified for those batteries under the Regulation rather than turning them automatically into full Article 77 battery passports.

This distinction should be reflected in artwork and product-data planning.

The Economic Operator Remains Responsible for the Information

The economic operator placing the battery on the market must ensure that the passport information is accurate, complete and up to date.

Another operator may be given written authorisation to act on its behalf, but outsourcing the technical work does not make the underlying product responsibility disappear.

For a UK brand, this means the agreement with the EU importer, battery supplier, product manufacturer and passport provider needs to cover more than who pays the software invoice.

It should establish who supplies the data, who verifies it, who registers the passport, who can make updates and who responds if an authority identifies an error.

The Passport Must Work Beyond the First Sale

The Regulation expects passport information to use open standards, remain interoperable and avoid vendor lock-in.

It also expects the passport to remain available if the responsible economic operator stops trading or ceases its EU activity.

That makes continuity planning part of compliance.

A platform may work perfectly while the supplier relationship is healthy. The important question is what happens to the data and identifiers if the provider is acquired, withdraws its service or the business changes importer.

The Passport Does Not Replace the Rest of Battery Compliance

A registered battery passport is not a substitute for conformity assessment, technical documentation, the EU Declaration of Conformity, CE marking, labelling, safety obligations or producer-responsibility arrangements.

It is one part of a much wider Batteries Regulation compliance programme.

This is worth stating because a polished passport can create false confidence.

The information behind it still needs to come from a product that meets the applicable requirements.

Common Mistakes Businesses Make

1. Assuming the Battery Supplier Will Handle Everything

The cell or pack supplier will hold much of the technical information.

It may not understand the final EU market structure, the brand’s product identifiers, the importer agreement or the way the battery is incorporated into the finished product.

Data ownership and regulatory responsibility should be mapped rather than passed down the supply chain in one sentence.

2. Applying the 2 kWh Threshold to Every Battery

The capacity threshold applies to industrial batteries within the passport provision.

LMT batteries and electric vehicle batteries are separately listed. They do not escape the passport requirement simply because their capacity is below 2 kWh.

3. Assuming Every QR Code Is a Full Battery Passport

All batteries face a QR-code requirement from the same date, but the linked information differs by category.

Businesses should not overstate the passport status of ordinary portable or SLI batteries where Article 77 does not apply.

4. Collecting Only Static Model Data

A technical specification is an important starting point.

It does not address individual-battery information such as status, state of health and certain use-related data where required and accessible to the relevant parties.

Hardware, BMS and data teams may need to be involved much earlier than the artwork team expects.

5. Waiting Until the Packaging Deadline

The QR code is visible, so it attracts attention.

The harder gaps are usually buried in supplier records: material composition, carbon-footprint data, sourcing evidence, test reports, dismantling information and lifecycle parameters.

Those requests can take months, especially where several tiers of suppliers are involved.

6. Giving the Passport to a Software Provider Without an Exit Plan

A provider may generate identifiers, host data and manage access perfectly well.

The contract should still explain data export, service continuity, backups, provider change, security incidents and what happens if either party ceases trading.

7. Forgetting the Battery Can Change Status

A battery may later be prepared for re-use, repurposed or remanufactured.

The passport system needs to support those lifecycle changes and the links between the original and new records.

A static product page created at manufacture will not manage that on its own.

What Does a Battery DPP Readiness Assessment Cover?

A battery DPP Readiness Assessment looks beyond the visible QR-code deadline and tests whether the business can support the full information, responsibility and lifecycle requirements behind the passport.

For a manufacturer, importer or own-brand business, the assessment can cover:

• Battery category, intended use, weight and capacity classification
• Identification of products requiring a full Article 77 passport and products subject only to the wider QR-code requirement
• EU market route and the economic operator responsible for the passport information
• Model, batch and individual-battery identifier structure
• Annex XIII data mapping across public, restricted and lifecycle information
• Material, chemistry, critical raw material and hazardous-substance evidence
• Performance, lifetime, carbon-footprint, sourcing and recycled-content data where applicable
• Technical file, test report and Declaration of Conformity matching
• Supplier contracts, questionnaires and missing-data requests
• BMS, state-of-health and individual-battery data capability where relevant
• QR-code, hosting, Registry, access-control and service-provider readiness
• Continuity, repair, repurposing, remanufacturing and passport-update processes

The result is a written gap assessment and implementation roadmap. It shows which battery products are in scope, which data can be supported now, what needs to come from suppliers or internal systems, and which actions should be completed first.

That is much more useful than discovering the missing information after the label artwork and production schedule have already been fixed.

Your Battery Passport Readiness Checklist

Category: Have you classified each battery as portable, LMT, SLI, industrial or electric vehicle?

Capacity and Weight: Are the rated energy capacity, weight and intended use recorded for scope decisions?

EU Placement Date: Will the battery be placed on the EU market or put into service on or after 18 February 2027?

Economic Operator: Which company will be responsible for placing the battery on the EU market?

Supplier Agreement: Does the contract require the manufacturer to supply and maintain all data needed for the passport?

Model Structure: Can batteries with shared technical characteristics be grouped under a controlled model identifier?

Individual Identity: Can each in-scope battery be linked to its own persistent unique identifier?

Material Data: Do you hold reliable chemistry, composition, hazardous-substance and critical-raw-material information?

Sustainability Data: Can applicable carbon-footprint, responsible-sourcing and recycled-content information be supported?

Technical Performance: Are capacity, voltage, power, lifetime, efficiency and other required performance data available?

Compliance Evidence: Are test reports, the technical file and EU Declaration of Conformity linked to the correct battery model?

Dismantling and Safety: Can legitimate repair, second-life and recycling operators access the required instructions and safety measures?

State of Health: Where applicable, can individual-battery health, status and use information be generated and updated?

Access Control: Have public, authority-only and legitimate-interest data been separated?

QR Code: Has the marking location, durability, readability and destination been planned for each battery category?

Registry: Is the responsible organisation enrolled, verified and ready to register passports in the EU DPP Registry?

Hosting and Backup: Will the passport remain available if the brand, importer or service provider changes?

Lifecycle Updates: Who updates the passport after repair, repurposing, remanufacturing or a change in battery status?

Wider Regulation: Have the passport and QR project been connected to labelling, CE marking, technical documentation and producer-responsibility work?

The list is longer than most businesses expect.

That is precisely why preparation should begin with a scoped data and responsibility review rather than a last-minute packaging project.

How Conformity Services Can Help

For the full service scope, see our Digital Product Passport Readiness Assessment, including battery-specific readiness support.

Conformity Services offers a battery-focused DPP Readiness Assessment for manufacturers, importers and growing brands preparing for the February 2027 requirements.

We start by classifying the battery, confirming the EU market route and responsible economic operator, and reviewing the information already held within the technical file, supplier network and any battery-management systems.

Our support can include:

• Battery DPP Readiness Assessment with a written gap report and implementation roadmap
• Battery category, capacity and product-portfolio mapping
• EU economic-operator and responsibility reviews
• Annex XIII information gap assessments
• Supplier data and evidence questionnaires
• Technical documentation and Declaration of Conformity reviews
• QR-code and unique-identifier compliance planning
• DPP Registry and service-provider readiness support
• Pilot battery-passport projects
• Change-control, lifecycle and continuity planning
• Wider EU Batteries Regulation compliance support

For a business with one battery model, the first project may be a focused DPP Readiness Assessment covering the product, supplier evidence, identifier structure and Registry route.

For a brand with several mobility, storage or industrial ranges, the assessment can begin with a portfolio map identifying which products require a full passport, which are affected by the wider QR-code rules, which data gaps repeat across the range and which suppliers create the greatest risk to the February 2027 timetable.

The objective of the assessment is not to recommend the most elaborate passport system.

It is to give the business a clear, defensible route towards a maintainable passport that matches the battery actually being placed on the market.

Final Thoughts

February 2027 is close enough that battery-passport preparation should already be under way.

The visible requirement will be the QR code.

The difficult requirement will be the information behind it: the correct battery classification, reliable supplier data, controlled identifiers, appropriate access rights and a process for keeping the record current throughout the battery’s life.

Businesses that start with those foundations will be in a much stronger position when the final artwork and Registry submissions are prepared.

Businesses that begin with the QR code may discover that they have created a doorway before building the room behind it.

Sources and official guidance

Regulatory position checked against official EU sources on 5 August 2026. Product-specific requirements and implementation dates should always be confirmed for the batteries concerned.

• Regulation (EU) 2023/1542: Batteries and waste batteries
• European Commission: Digital Product Passport for batteries
• European Commission: DPP Registry