Published by Vera, which makes product identity tags, certificates and software. Vera's own role is set out under 'Where Vera fits'.
This explainer summarises the law for general information. It is not legal advice.
5 min read, Reviewed 23 October 2026
The EU battery passport: what is required from 18 February 2027
Batteries are the first products in the EU with a mandatory digital passport and a fixed date. It covers light means of transport batteries, industrial batteries over 2 kWh and electric vehicle batteries.
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Law
Regulation (EU) 2023/1542, Article 771
Mandatory from
18 February 20271
Way in
A QR code on the battery1
Moved by the 2025 omnibus?
No2
Scope
Which batteries need a passport
From 18 February 2027, every battery in three categories that is placed on the EU market or put into service must have an electronic record, the battery passport: batteries for light means of transport, such as e-bikes and e-scooters; industrial batteries with a capacity above 2 kWh; and electric vehicle batteries.1
The obligation sits in Article 77 of the Batteries Regulation, (EU) 2023/1542, adopted on 12 July 2023. It is a separate law from the Ecodesign for Sustainable Products Regulation (ESPR), but the two are designed to meet: the battery passport must be fully interoperable with the passports ESPR introduces, and ESPR's registry, operational since 20 July 2026, stores battery identifiers too.1,4,5
Status
Did the 2025 simplification move the date?
No. Regulation (EU) 2025/1561, adopted on 18 July 2025 as a "stop-the-clock" measure, amends a single article of the Batteries Regulation: the due diligence obligation in Article 48, which moves from 18 August 2025 to 18 August 2027. The battery passport article is not touched.2
A further simplification proposal, COM(2025) 981 of 10 December 2025, is still in the legislative process. As published, it proposes no change to the battery passport article. We read its text on 30 September 2026; if the final law differs, this page will change with it.3
Timeline
The 2025 changes moved due diligence, not the passport
In lawIndicative
Battery passport, Article 77
In the Regulation adopted on 12 July 2023; mandatory from 18 February 2027, unchanged.
Due diligence, Article 48
Moved from 18 August 2025 to 18 August 2027 by Regulation (EU) 2025/1561, adopted on 18 July 2025.
Simplification proposal, COM(2025) 981
Of 10 December 2025, still in the legislative process. As published, it proposes no change to the passport article.
A timeline from 2023 to 2027 with three lanes. The battery passport, Article 77 of the Batteries Regulation adopted on 12 July 2023, is mandatory from 18 February 2027, and that date is unchanged. Due diligence, Article 48, was moved from 18 August 2025 to 18 August 2027 by Regulation (EU) 2025/1561, adopted on 18 July 2025. The simplification proposal COM(2025) 981, of 10 December 2025, is still in the legislative process and, as published, proposes no change to the passport article.
The physical link
A QR code, linked to a unique identifier
Where ESPR leaves the carrier to each product group, the Batteries Regulation names it. The passport is reached through the QR code every battery must carry from 18 February 2027, which links to a unique identifier assigned by the business placing the battery on the market. Both must follow the ISO/IEC 15459 standards or equivalents.1
That business must keep the passport accurate, complete and up to date, and may authorise another operator to act for it. The data must use open standards in an interoperable, machine-readable format, transferable without vendor lock-in, and consumers and businesses reach it free of charge according to their access rights.1
Contents
What the passport holds, and who sees it
Annex XIII of the Regulation splits the passport into four tiers of access. The same passport shows different things to different people.1
- Public, about the battery model
- Material composition, including chemistry, hazardous substances and critical raw materials; carbon footprint; responsible sourcing; recycled and renewable content; capacity, voltage and power; expected lifetime in cycles; warranty period for calendar life; the declaration of conformity; and waste prevention and collection information.1
- Persons with a legitimate interest, about the model
- Detailed composition of cathode, anode and electrolyte; part numbers and sources for spares; dismantling information, from exploded diagrams to the tools required; and safety measures.1
- Notified bodies, market surveillance and the Commission
- Test reports proving the battery meets the Regulation's requirements.1
- Persons with a legitimate interest, about the individual battery
- Performance and durability values, state of health, status as original, repurposed, re-used, remanufactured or waste, and data from use: charge cycles, negative events such as accidents, operating temperature and state of charge.1
Who counts as a person with a legitimate interest is left to an implementing act, which the Regulation required the Commission to adopt by 18 August 2026. The Commission's timeline now plans it for the fourth quarter of 2026.1,5
Framework
Who sees what in a battery passport
The public
Who may see it
Legitimate interestWhat it describes: The battery modelWho may see it: The public
Composition and sourcing
Chemistry, hazardous substances and critical raw materials; carbon footprint; responsible sourcing; recycled and renewable content
Performance and conformity
Capacity, voltage and power; expected lifetime; warranty; the declaration of conformity
What it describes: The individual batteryWho may see it: The public
What it describes: The battery modelWho may see it: Legitimate interest
Detailed composition and spare parts
Cathode, anode and electrolyte; part numbers and sources for spares
Dismantling and safety
From exploded diagrams to the tools required, and safety measures
What it describes: The individual batteryWho may see it: Legitimate interest
State of health and status
Performance and durability values; original, repurposed, re-used, remanufactured or waste
Data from use
Charge cycles, negative events such as accidents, operating temperature and state of charge
The battery modelThe individual battery
What it describes
A two-by-two framework of who sees what in a battery passport. Across: what the data describes, the battery model or the individual battery. Up: who may see it, only persons with a legitimate interest or the public. About the battery model, the public sees material composition, including chemistry, hazardous substances and critical raw materials, the carbon footprint, responsible sourcing, recycled and renewable content, capacity, voltage and power, expected lifetime, warranty and the declaration of conformity. About the model, persons with a legitimate interest also see the detailed composition of cathode, anode and electrolyte, part numbers and sources for spares, dismantling information and safety measures. About the individual battery, persons with a legitimate interest see performance and durability values, state of health, its status as original, repurposed, re-used, remanufactured or waste, and data from use: charge cycles, negative events such as accidents, operating temperature and state of charge. The quadrant for the public and the individual battery is empty: nothing about the individual battery is public. A fourth tier, test reports, is for notified bodies, market surveillance authorities and the Commission.
Second life
A passport that follows the battery's status
The battery passport is not written once at the factory. When a battery is prepared for re-use, repurposed or remanufactured, responsibility for its passport passes to the business that puts it back on the market, and the battery gets a new passport linked to the passport of the original battery or batteries.1
When a battery becomes waste, responsibility passes to the producer, its producer responsibility organization or the waste management operator. The passport ceases to exist once the battery has been recycled. It must also stay available if the business responsible for it ceases to exist.1
That shape, an item-level record whose owner and status change over a long life, is the part of the battery passport most worth studying for brands in other categories. It is the same shape as a record that follows a product from the day it is made through every owner.
Process
A passport that follows the battery's status
Placed on the market
The business placing it keeps its passport accurate and up to date.
A second life
Re-used, repurposed or remanufactured: a new passport, linked to the original.
Waste
Responsibility passes to the producer, its organisation or the waste operator.
Recycled
The passport ceases to exist.
A four-step process for a battery passport. First, the business placing the battery on the market keeps its passport accurate, complete and up to date. Second, when the battery is prepared for re-use, repurposed or remanufactured, it gets a new passport linked to the original, and responsibility passes to the business that puts it back on the market. Third, when the battery becomes waste, responsibility passes to the producer, its producer responsibility organization or the waste management operator. Fourth, once the battery has been recycled, the passport ceases to exist.
Where Vera fits
The item-level record, for luxury and collectible categories
The Batteries Regulation is precise about the way in and the contents. The passport is reached by a QR code and must carry the Annex XIII data, from chemistry and carbon footprint to state of health.1
Vera's work is the item-level record for products in luxury and collectible categories: a tag on the object and a certificate that follows each owner. If your products fall under ESPR rather than the Batteries Regulation, the Digital Product Passport guide and the textile passport guide are the relevant reading.
Sources (5)
Questions
Battery passport questions
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