From 18 February 2027, most rechargeable batteries that matter to industry — electric-vehicle batteries, batteries for light means of transport such as e-bikes, and industrial batteries above 2 kWh — can only be placed on the EU market with a battery passport: a structured electronic record for the individual battery, reachable through a QR code. The duty comes from Article 77 of Regulation (EU) 2023/1542, the EU Batteries Regulation, and it is the first Digital Product Passport obligation to take effect in Europe. This page sets out what the law requires, who carries the obligation, and what to prepare.

The deadline: 18 February 2027

Article 77(1) is short and unambiguous: “From 18 February 2027 each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market or put into service shall have an electronic record (‘battery passport’).” Three battery categories are in scope:

  • Electric vehicle (EV) batteries — traction batteries for electric road vehicles;
  • LMT batteries — batteries for light means of transport, such as e-bikes and e-scooters;
  • Industrial batteries with a capacity greater than 2 kWh — including stationary energy-storage batteries used in private or domestic environments, which the Regulation counts as industrial batteries.

Portable batteries and starter (SLI) batteries are outside the passport duty as the Regulation now stands — but the passport is designed to be interoperable with the Digital Product Passports arriving under the ESPR, so the architecture a company builds for batteries should not be a dead end.

Who has to comply

The obligation sits with the economic operator that places the battery on the market — the manufacturer, or the importer bringing batteries into the Union. Article 77(4) makes that operator responsible for ensuring the passport information is accurate, complete and up to date; it may authorise another operator in writing to act on its behalf, but the responsibility does not move. The Regulation applies to batteries produced in the EU and to imported batteries alike. If a battery is prepared for re-use, repurposed or remanufactured, the operator placing it back on the market takes over the duty, and the battery receives a new passport linked to the passport of the original battery (Article 77(7)).

What the passport must contain

The passport holds information about the battery model and about the individual battery, including data generated by its use (the full list is in Annex XIII of the Regulation). Access is layered, so a single record can serve the public, professionals and authorities without exposing commercially sensitive data:

Battery passport — data at a glance

  • Public layer: identification of the battery and of the manufacturer, battery category, place and date of manufacture, composition — including raw materials and hazardous chemicals — carbon footprint information, recycled content, durability and performance data, and end-of-life information;
  • Legitimate-interest layer: detailed composition, dismantling and safety information, and the battery’s state of health — reserved to repairers, remanufacturers, second-life operators, recyclers and purchasers who need it to work on or value the battery;
  • Authorities layer: compliance and test information reserved to notified bodies, market surveillance authorities and the Commission.

Article 77(9) required the Commission to adopt implementing acts specifying exactly which persons count as having a legitimate interest and what they may access, download and re-use — the access model is therefore a legal feature of the passport, not an optional extra.

How access works: the QR code

The passport is accessed through the QR code marked on the battery, which links to a unique identifier attributed by the operator placing the battery on the market. Both must comply with the ISO/IEC 15459 series of standards. Under Article 78, all passport information must be based on open standards, in an interoperable, machine-readable format, transferable without vendor lock-in; access is free of charge for consumers, operators and authorities according to their access rights. The passport must remain available even if the responsible operator ceases to exist, and it ceases to exist itself only once the battery has been recycled.

What companies should do now

  • Map your scope: list every battery model you place on the EU market and check it against the three categories above.
  • Assemble the data: composition, carbon footprint and recycled content live with suppliers and cell manufacturers — start collecting them in passport-ready form now, not in February 2027.
  • Fix identifiers and access: adopt unique identifiers under the ISO/IEC 15459 series and design the public / professional / authority access layers before you print a single QR code.
  • Plan for the battery’s whole life: updates, state-of-health data, hand-over at repurposing and deletion at recycling must all be handled by the system you choose.

How Ledger Consortium helps

Ledger Consortium aggregates the product data held by you and your suppliers, anchors each passport record on a governed blockchain — so every version is timestamped and tamper-evident — and keeps the record updated as the rules and the battery evolve. Two things we state plainly, because they matter legally: anchoring proves a record existed and has not been altered; it does not certify that the data a client supplied was true — accuracy remains the responsibility of the operator placing the battery on the market, exactly as Article 77(4) provides. Costs are predictable, there is no token and no crypto exposure, and the platform is GDPR- and eIDAS-aligned. You can see a working passport in our live demo, and read how batteries fit into the wider ESPR timeline here.