From 18 February 2027, every light means of transport (LMT) battery, every industrial battery above 2 kWh and every electric vehicle battery placed on the EU market or put into service must have an electronic battery passport. On the same date a QR code becomes mandatory on all batteries, including those outside the passport scope. A manufacturer outside the EU should now settle three things with its importer: a unique identifier per battery, the QR code, and the passport data.
Which batteries are in scope?
Article 77 of the Batteries Regulation, (EU) 2023/1542, sets the scope. The 2 kWh threshold applies to industrial batteries only; LMT and electric vehicle batteries have no capacity threshold.
| Battery | Passport from 18 February 2027 | Where the QR code leads |
|---|---|---|
| LMT | Required | The battery passport |
| Industrial, above 2 kWh | Required | The battery passport |
| Electric vehicle | Required | The battery passport |
| All others | Not required | Label information, declaration of conformity, due diligence report and waste information |
The European Commission's September 2026 FAQ attaches the obligation to the finished battery. Packs sharing a battery management system count as one battery with one passport, and the 2 kWh threshold is assessed the same way.
Who is responsible: the manufacturer or the importer?
The economic operator placing the battery on the market must keep the passport accurate, complete and up to date (Article 77(4)). The regulation defines an importer as a person established in the Union who places a battery from a third country on the market, so for batteries made outside the EU the legal responsibility usually sits with the EU importer.
The manufacturer still has work to do. Three situations come up most often:
- Exporting finished batteries: the importer can authorise the manufacturer in writing to create and update the passport. According to the Commission, this does not turn the non-EU company into an EU manufacturer or importer, and final responsibility stays with the importer. DPP Registry registration also falls to the importer.
- Batteries built into machinery or vehicles: the obligation attaches to the finished battery, and for an imported product it normally falls on the importer.
- Cells, modules and components: parts that are only components need no passport, and the company completing the battery in the EU becomes the manufacturer. That company will still ask suppliers for composition and critical raw material data.
What are the key dates?
- 20 July 2026: the DPP Registry went live.
- 18 August 2026: the date set in the regulation for the implementing act on legitimate-interest access. The Commission's FAQ expects a draft for public feedback in October or November 2026, and its passport page lists the act for the last quarter of 2026.
- 18 February 2027: passport and QR code obligations apply.
- 18 August 2027: due diligence obligations apply, after Regulation (EU) 2025/1561 postponed them by two years. Under Article 47, operators with net turnover below EUR 40 million that are not part of a group exceeding that limit fall outside this chapter.
- 18 August 2028, or 24 months after the relevant delegated act if later: recycled content documentation begins. For LMT batteries the date is 18 August 2033.
The Commission states that carbon footprint, recycled content and due diligence information are not required from February 2027, because each has its own application date.
What data goes into the passport?
Annex XIII divides the information into four groups by access right:
| Access | Content |
|---|---|
| General public | General label information, chemistry, hazardous substances, critical raw materials, capacity, voltage, power, expected lifetime, warranty period, declaration of conformity, waste information |
| Persons with a legitimate interest, and the Commission | Detailed composition, part numbers, sources for spares, dismantling information, safety measures |
| Notified bodies, market surveillance authorities, and the Commission | Test reports showing compliance |
| Persons with a legitimate interest (individual battery) | Performance values, state of health, status, charging cycles, events such as accidents |
Version 3.2 of the Commission's guidance, dated 19 October 2026, sorts 71 data points for the three battery categories into mandatory, optional, conditional, or not to be filled as of February 2027. It is not an official position and creates no new obligations, but it is a practical starting point. Use-related fields may be empty when a new imported battery is registered.
Which decisions does the identifier and QR code require?
The QR code links to a unique identifier assigned by the operator placing the battery on the market. Both must comply with the ISO/IEC 15459 series or an equivalent (Article 77(3)). The regulation does not name GS1. The Commission says identifiers can be generated in-house under those standards or through a commercial service. The identifier is also uploaded to the DPP Registry (Article 77(10)).
On the line and label side, decide:
- Who generates the number: importer or manufacturer? Put the rule in the contract to avoid duplicates.
- Where the code goes: printed or engraved on the battery so it is visible, legible and indelible, or on the packaging and accompanying documents where that is not possible. It must be high contrast and readable by a phone.
- How the record connects: keep the unit identifier with the batch, plant and production date.
- Where data is stored: the responsible operator or an operator it authorises stores the data. The passport must stay available even if the responsible operator ceases activity (Article 78).
- How second life works: a remanufactured or repurposed battery gets a new passport linked to the original.
Does the passport prove a battery is genuine?
Article 78 requires data integrity and fraud avoidance, which protects the record. The QR code leading to it can still be printed on another battery, so the passport alone does not show that the battery in your hands is the one on record. See our article on tracking and verification.
Checklist for the run-up to February 2027
- Classify your products as LMT, industrial above 2 kWh, electric vehicle or other.
- Settle who places the battery on the market and who gets written authorisation.
- Assign an owner to each of the 71 data points.
- Choose an identifier structure and code position per product group.
- Write the data expected from suppliers into their contracts.
- Test code readability and records on a pilot batch.
Where does Spectrace fit?
Tagvex numbers products at batch or unit level, fits the code into the existing label layout and records every change of hands; records can be passed to ERP and warehouse systems through an API. That is the identifier and data preparation layer; it does not replace the battery passport or DPP Registry registration. The wider timeline is in our digital product passport article.
Sources
- EUR-Lex, Regulation (EU) 2023/1542, consolidated text of 13.08.2026
- European Commission, EU Digital Product Passport FAQ for Batteries, 2026
- European Commission, Guidance Document: Digital Batteries Passport, data points by category, version 3.2, 2026
- European Commission, Digital Product Passport, 2026
- Ministry of Trade of Türkiye, Digital Battery Passport (Turkish), 2026
