BATTERIES · MANDATORY FROM 18 FEBRUARY 2027
EU Battery Passport Requirements for 2027
From 18 February 2027, electric vehicle batteries, light means of transport batteries and industrial batteries above 2 kWh placed on the EU market or put into service must have a digital battery passport. The legal scope, date and core information requirements are established in Regulation (EU) 2023/1542.
Current position
Battery Passport status at a glance
The Article 77 obligation has a fixed application date for defined categories; implementation details continue to develop.
EU Batteries Regulation 2023/1542
18 February 2027
EV · LMT · Industrial > 2 kWh
Individual battery
Article 77 scope
Does the Battery Passport apply to my product?
Article 77 defines three covered categories for passports from 18 February 2027. Check the Regulation’s definitions and the role of each operator for a specific product.
The Batteries Regulation applies more broadly to other battery categories, but the Article 77 Battery Passport obligation from 18 February 2027 applies specifically to EV batteries, LMT batteries and industrial batteries above 2 kWh.
Electric vehicle batteries
Batteries for traction in electric and hybrid vehicles, as defined in the Regulation.
LMT batteries
Batteries for traction in light means of transport such as e-bikes and e-scooters, subject to the Regulation’s definition.
Industrial batteries above 2 kWh
Industrial batteries with a capacity greater than 2 kWh.
Potentially affected actors
- Battery manufacturers
- Importers
- Economic operators placing covered finished batteries on the EU market
- Operators placing repurposed or remanufactured covered batteries on the market
- Suppliers of battery, material and evidence data
Regulatory sequence
Battery Passport timeline
The binding date, operational infrastructure and pending implementation details are distinct.
2023
Batteries Regulation adopted
Regulation (EU) 2023/1542 establishes the Battery Passport framework and Article 77 obligation.
July 2026
DPP technical framework established
Six harmonised DPP standards are referenced through Commission Implementing Decision (EU) 2026/1736.
20 July 2026Operational
EU DPP Registry: horizontal infrastructure operational
The EU DPP Registry became operational as horizontal infrastructure on 20 July 2026. This does not establish that battery identifiers can already be registered; check battery-specific semantic specifications and operational guidance before attempting submission. Detailed passport data remains decentralised.
Q4 2026Pending implementation detail
Access-right rules delayed — Commission roadmap now Q4 2026
The statutory 18 August 2026 deadline in Article 77(9) for Commission rules on access, download and reuse has passed without adoption of those rules. The Commission roadmap now indicates Q4 2026; this is an indicative target, not a replacement statutory date. The binding 18 February 2027 passport date is unchanged. Check whether the rules have been adopted before configuring access.
18 February 2027Binding
Battery Passport mandatory
From 18 February 2027, the Article 77 obligation applies to the covered categories.
Who is responsible for the Battery Passport?
The economic operator placing the finished covered battery on the EU market is responsible for creating and maintaining its Battery Passport and, under Article 77(4), ensuring the information is accurate, complete and up to date. Article 77(10) separately covers Registry uploads by the operator placing the battery on the market or putting it into service; Article 77(7) transfers the information duty for specified subsequent lifecycle batteries.
Initial market placement
Under Article 77(3), the operator placing the battery on the market attributes its unique identifier; under Article 77(4), that operator ensures passport information is accurate, complete and up to date.
Re-use / repurposing / remanufacturing
Where a covered battery that has undergone preparation for re-use, preparation for repurposing, repurposing or remanufacturing is placed on the market or put into service, the responsible operator must ensure a new Battery Passport is created and linked to the original passport or passports under Article 77(7). The Article 77(4) information duty transfers to the operator placing this battery on the market or putting it into service.
Waste stage
Responsibility follows the waste-management obligations defined in the Regulation.
Recycled battery
The Battery Passport ceases to exist once the battery is recycled.
Binding requirements
What is already required?
Regulation (EU) 2023/1542 establishes these core passport concepts for covered batteries from 18 February 2027.
Individual battery passport
Each covered battery must have its own electronic passport.
Unique identifier
The responsible economic operator associates the passport with a persistent unique identifier.
QR code
Article 77 requires access to the passport through the QR code referred to in Article 13(6), linked to the unique identifier.
Registry registration
Article 77(10) requires the economic operator placing the battery on the market or putting it into service to upload the battery’s unique identifier to the EU DPP Registry. The detailed passport remains decentralised. Check battery-specific submission availability before implementation.
Model + individual battery data
The passport combines model-level information with individual-battery information, including lifecycle and use data where applicable.
Controlled access levels
Annex XIII point 1 is public. Point 2 is accessible both to notified bodies, market-surveillance authorities and the Commission and to persons with a legitimate interest (subject to Article 77(9) rules); point 3 results of test reports proving compliance are accessible to notified bodies, market-surveillance authorities and the Commission, not the legitimate-interest tier. Point 4 individual-battery information is accessible to persons with a legitimate interest, subject to Article 77(9) rules.
Interoperable structured data
Passport data must be interoperable, machine-readable, structured and transferable in line with the EU DPP framework.
Pending implementation detail
What is still being finalised?
As of 25 September 2026, the underlying Battery Passport obligation is binding. These are pending implementation details, not a postponement of the obligation.
- Pending implementation detail
Access and reuse rules
Detailed access, download and reuse rules under Article 77(9).
- Pending implementation detail
Implementation guidance
Final Commission preparation guidance updates.
- Pending implementation detail
Data formats
Reporting and format clarification for individual data points.
- Pending implementation detail
Operational exchange
Practical guidance for data exchange and access.
Passport information and access
What information goes into a Battery Passport?
Annex XIII defines the legal information structure. Current Commission preparation guidance maps it into a detailed implementation dataset. Applicability varies by battery category and by when underlying requirements apply.
A detailed implementation dataset does not mean every battery company must populate the same fields. Applicability depends on battery category, operator role and when the underlying Batteries Regulation requirements become applicable.
Public battery-model information
Examples where applicable: product identity; chemistry and material composition; hazardous substances and critical raw materials; carbon footprint; due diligence; recycled content; capacity, voltage and power; lifetime, performance, conformity and waste-management information.
Restricted model information
Annex XIII point 2 is accessible both to notified bodies, market-surveillance authorities and the Commission and to persons with a legitimate interest (subject to Article 77(9) rules). Examples where applicable: detailed cathode, anode and electrolyte composition, spare parts, dismantling instructions and detailed safety information.
Notified bodies and authorities
Annex XIII point 3: results of test reports proving compliance, accessible to notified bodies, market-surveillance authorities and the Commission where applicable.
Individual battery / lifecycle information
Annex XIII point 4 is accessible to persons with a legitimate interest, subject to Article 77(9) rules. State of health, battery status, cycle and performance history, state of charge, relevant negative events or operating conditions where required, and reused, repurposed or remanufactured status.
Readiness pathway
Five steps to prepare
Plan implementation against the covered products and applicable data, not an assumed universal field list.
Classify your battery portfolio
Determine which products are EV, LMT or industrial batteries >2 kWh under Article 77.
Build the applicable data matrix
Map Annex XIII and Commission implementation guidance to each battery category and product family.
Map systems, suppliers and data gaps
Find required information across ERP, PLM, PIM, BMS, LCA tools, compliance systems, supplier evidence and lifecycle systems.
Design identity, QR, Registry and access flows
Define unique identifiers, QR generation, passport URL and resolution, Registry registration, public versus restricted access and update workflows.
Establish lifecycle ownership and run a pilot
Define who creates, verifies, updates and transfers responsibility for passport data; test on a real product line before February 2027.
Be ready before 18 February 2027
Want help mapping your Battery Passport requirements, data sources and implementation flow? We can work through it with your team.
How Circlepass helps
Turn Battery Passport requirements into an operational data flow
Circlepass supports teams in scoping products, mapping applicable passport information, connecting data from systems and suppliers, structuring identifier and access workflows, and preparing structured passports as EU implementation guidance evolves.
Check your DPP readinessBattery Passport questions
When does the EU Battery Passport become mandatory?
18 February 2027 for the covered Article 77 battery categories.
Which batteries need a Battery Passport?
Electric vehicle (EV) batteries, light means of transport (LMT) batteries and industrial batteries above 2 kWh.
Who is responsible for creating the Battery Passport?
The operator placing the finished covered battery on the EU market creates and maintains the passport and ensures its information is accurate, complete and up to date (Article 77(4)). The operator placing it on the market or putting it into service uploads the unique identifier to the Registry (Article 77(10)); after specified lifecycle operations the information duty transfers to the operator placing that battery on the market or putting it into service (Article 77(7)).
Is the Battery Passport at model, batch or individual-battery level?
Each covered battery has its own passport containing both model-level and individual-battery information.
How much information is required?
Annex XIII and Commission preparation guidance explain the information structure; applicability varies by battery category and timing of the underlying requirements. The guidance does not create separate obligations.
Does all Battery Passport information become public?
No. Annex XIII point 1 is public. Point 2 is accessible both to notified bodies, market-surveillance authorities and the Commission and to persons with a legitimate interest (subject to Article 77(9) rules). Point 3 results of test reports proving compliance are accessible to notified bodies, market-surveillance authorities and the Commission, not the legitimate-interest tier. Point 4 individual-battery information is accessible to persons with a legitimate interest, subject to Article 77(9) rules.
Official EU sources
Regulatory references last checked on 25 September 2026