The battery passport deadline, explained
What Regulation (EU) 2023/1542 actually requires on 18 February 2027, who is bound, and what each battery needs, cited by article.
On 18 February 2027, a hard rule switches on in the EU: certain batteries can no longer be placed on the market, or put into service, without their own digital battery passport.REG. (EU) 2023/1542, ART. 77(1)
Who is bound
Three battery categories are in scope:
- EV batteries: electric-vehicle traction batteries.
- LMT batteries: light means of transport (e-bikes, scooters, and similar).
- Industrial batteries above 2 kWh: including stationary storage.
Two details catch teams out. First, putting into service counts, not just sale. A battery you install and operate in the EU is bound even if it never crosses a checkout. Second, the obligation attaches per battery placed from the deadline onward, including new units of models you already sell today.ART. 77(1)
What each battery needs
A unique identifier behind a printed QR code, linking to that battery's own passport. Per battery, not per model.ART. 77(3) · ART. 13(6)
The passport carries the Annex XIII data set: roughly ninety attributes across identity, chemistry, carbon footprint, recycled content, performance and durability, and supply-chain due diligence. Some of it is public; some is restricted to regulators and operators with a legitimate interest, so the passport must serve different views to different readers.ANNEX XIII · ART. 77(2)
The parts with long lead times
- Carbon footprint: a declaration per model per manufacturing plant. Collecting the underlying life-cycle data is typically the slowest single item.ART. 7
- Recycled content: documented shares for cobalt, lithium, nickel, and lead, phasing in from August 2028 (LMT from 2033). Supplier data requests move slowly; open them early.ART. 8
- Due diligence: one passport field draws on the supply-chain report. The due-diligence chapter applies from 18 August 2027 and exempts operators under €40M net turnover. Check whether it binds you at all.ART. 52(3) · ART. 47 · REG. (EU) 2025/1561
Where it's filed
Passport identifiers are filed in the European Commission's central registry, so authorities can look a battery up. Registry access and upload testing belong on your plan well before February.ART. 77(10)
What to do this quarter
Confirm scope, map your placement calendar against the deadline, and start the longest-lead items first. The free readiness checker turns those into a prioritized gap report in about three minutes. No signup; answers stay in your browser.
General information, not legal advice. Verify obligations against the cited regulations on EUR-Lex, or with counsel. Citations checked July 30, 2026.