The EU Battery Regulation and the battery passport – clearly explained.

Overview

The Regulation (EU) 2023/1542 governs batteries across their entire lifecycle – from raw material extraction through design and labelling to collection and recycling. It replaces the old Batteries Directive and, as a regulation, applies directly in all member states.

One of its best-known instruments is the digital battery passport (Art. 77): an electronic record for every single battery, accessible via a QR code. It is the EU's first mandatory digital product passport and a model for further product groups under the Ecodesign Regulation.

Timeline

The regulation enters into force in stages. The key dates:

1. 17.08.2023

   Entry into force

   The regulation enters into force; most obligations follow later.

2. 18.02.2024

   Start of application

   The regulation applies in general; many individual obligations have their own start dates.

3. 18.08.2024

   Performance, durability & safety

   Requirements for performance and durability, safety of stationary storage and data in the battery management system.

4. 18.08.2025

   Producer registration & producer responsibility

   Registration obligation and extended producer responsibility for collection and treatment. In Germany, the Battery Law Implementation Act (BattDG) applies.

5. 18.02.2027

   Battery passport & replaceability

   Passport obligation for LMT, industrial (> 2 kWh) and electric vehicle batteries. At the same time, portable and LMT batteries must be removable and replaceable.

6. 18.08.2027

   Due diligence for raw materials

   Originally planned for 2025, postponed by Regulation (EU) 2025/1561. Applies to companies above the turnover threshold.

7. open

   Carbon footprint & labelling

   The carbon footprint declaration and some labelling obligations depend on delegated or implementing acts that have not yet been fully adopted.

Batteries affected

The regulation distinguishes five categories. Only three of them need a passport:

Not sure? The Obligation check leads you to the answer in a few questions.

Passport contents

Which information belongs in the passport is defined in Annex XIII. Roughly, it can be divided into four groups:

1. General and public information

• Manufacturer, battery category, model and batch identifier, place and date of manufacture, weight
• Chemistry, hazardous substances and critical raw materials
• Performance and durability, e.g. capacity, voltage, power, temperature range, expected lifetime
• Recycled content shares and share of renewable content
• Carbon footprint and due diligence report – as soon as these obligations apply

2. Information for persons with a legitimate interest

• Detailed composition, such as the materials of cathode, anode and electrolyte
• Part numbers of components and sources for spare parts
• Information on disassembly and safety measures

3. Information for authorities and notified bodies

• Results of test reports proving conformity

4. Dynamic information

• State of health and performance data during operation
• Battery status: original, reused, repurposed, remanufactured or waste
• Information on usage and events, such as accidents

For practical implementation, the project consortium “Battery Pass” published a recommendation on the individual data attributes together with DIN DKE SPEC 99100.

Access levels

Not all information is visible to everyone. The regulation provides for tiered access rights:

• Public: all general information – for anyone who scans the QR code.
• Persons with a legitimate interest and the European Commission: additionally the detailed and dynamic information, e.g. for repair, remanufacturing and recycling.
• Notified bodies, market surveillance authorities and the European Commission: additionally the test reports.

Who is responsible

Responsible for the information in the passport is the economic operator placing the battery on the market – usually the manufacturer, or the importer for goods from third countries. They must ensure that the information is correct, complete and up to date. They can delegate maintaining the passport to third parties, but remain responsible.

Distributors who sell batteries under their own name or brand, or modify them substantially, are generally treated as manufacturers themselves.

QR code & unique identifier

Every passport has a unique identifier assigned by the economic operator. A QR code on the battery leads to the passport. The data must be available in an open, interoperable and machine-readable format.

A widely used standard for such codes is GS1 Digital Link: it links a globally unique product identifier with a web address, so that a scan leads directly to the matching passport page.

Lifecycle

• Repair: The passport remains; the events are documented.
• Repurposing or remanufacturing: Responsibility passes to the new economic operator. The battery receives a new passport linked to the original one.
• Recycling: When the battery is recycled, its passport ends.

Norms & standards

• Regulation (EU) 2023/1542: legal basis, in particular Art. 77 and Annex XIII.
• DIN DKE SPEC 99100: recommendation on the data attributes of the battery passport.
• GS1 Digital Link: standard for resolvable QR codes.
• Asset Administration Shell & Catena-X: formats and data spaces for exchange along industrial supply chains.

Batterypass follows these foundations and adapts its validation rules when requirements change.

Checklist for 2027

1. Clarify which of your batteries fall under the passport obligation.
2. Define who is responsible internally – product, quality, procurement.
3. Record which information you have yourself and which comes from suppliers.
4. Anchor data deliveries in your supply contracts.
5. Plan serial numbers and QR labelling into production.
6. Test the process with a pilot model – long before the deadline.

Start the obligation check