A battery passport is the electronic record required by Article 77 of the EU Battery Regulation for specified battery categories. Its deadline and access rules differ from other battery compliance obligations.
Passport scope and deadline
Battery Regulation 2023/1542 Article 77 requires a battery passport from 18 February 2027 for each LMT battery, each industrial battery with capacity greater than 2 kWh, and each electric-vehicle battery placed on the market or put into service. Article 13(6) links the passport through a QR code. This is distinct from phased carbon-footprint, labelling and other battery obligations; a battery exactly at 2 kWh does not meet the stated industrial threshold.
Information, access and implementation
The passport is an electronic record containing model-level and individual-battery information specified in Annex XIII. Article 77 distinguishes public data from information reserved for authorised roles or persons with a legitimate interest; it is not an unrestricted database. It links to a unique identifier for the individual battery, not simply to a generic batch label. The responsible economic operator must address accuracy, updating, access and continuity. In preparation, map suppliers and evidence owners, separate public and restricted fields, and test that the QR link resolves to the correct battery record.
CE and separate phased obligations
CE marking and the battery passport have different application dates. Under Article 96(2)(c), Article 17 and Chapter VI of Regulation 2023/1542 apply from 18 August 2024, subject to the specific exception for Article 17(2). Do not postpone CE marking for portable batteries to February 2027. Other requirements have separate dates and dependencies on implementing or delegated acts; Regulation 2025/1561 postponed battery due-diligence obligations to 18 August 2027.
Practical checklist
- Identify the product, intended use, market and applicable legal scope.
- Record the exact legal provisions, dates and applicable standard editions, including restrictions.
- Select the permitted assessment route and document the evidence needed.
- Link risk assessment, tests, product versions and declarations in the technical documentation.
- Assign responsibility for changes, support and responses to authorities.
This checklist supports planning; the applicable legal requirements determine the final assessment.