Which batteries are in scope?
Under Article 77 of Regulation (EU) 2023/1542, from 18 February 2027 a battery passport is required for each light means of transport (LMT) battery, each electric-vehicle (EV) battery, and each industrial battery with a capacity above 2 kWh that is placed on the market or put into service. The regulation covers other battery categories too, but this passport requirement is not a blanket requirement for every battery type.
The battery passport is an electronic record associated with an individual battery through a QR code. The legal text specifies the passport’s information and access approach. Data visibility varies by information type and user role; public access should not be assumed for every field.
What should teams organize now?
Build a product and battery identity model that can distinguish the relevant battery, its manufacturer and its lifecycle status. Bring together information already managed in different systems, such as material and composition data, performance and durability information, carbon-footprint records where applicable, and supporting evidence.
Supplier data is often the hardest part. Identify which values are reported by a supplier, which are calculated internally, and which have independent verification. Record provenance and version history so updates do not silently overwrite the evidence behind an earlier passport value.
- Confirm the battery category and capacity threshold for each product.
- Assign owners for required data and supplier follow-up.
- Test the QR-code journey and role-based access using a controlled pilot.
- Track official guidance and technical standards as they are published.
Avoid the “one QR code means compliance” shortcut
A QR code can provide a convenient link, but it does not create accurate data, establish the right access controls or demonstrate that legal requirements are met. The passport experience depends on reliable records, secure hosting, ongoing maintenance and the rules that apply to the specific battery.
Use the regulation and current Commission guidance as the source of truth. A software platform can help teams organize and publish information, but it cannot decide a company’s legal obligations or certify a battery on its own.
Official sources
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