as a machinery manufacturer, do I also need to arrange a battery passport for the battery in my machine
For an industrial battery above 2 kWh, the answer is usually yes
If a machine manufacturer installs a battery with a capacity above 2 kWh, that battery falls under the category of industrial batteries, and the passport requirement applies to it. The machine itself does not need a passport — this concerns the battery inside it. Whoever installs the battery becomes the point of contact for the passport in most cases, even if the battery was purchased from a supplier. What is precisely established about that 2 kWh threshold and why that threshold exists is detailed on the page about what the 2 kWh threshold means for industrial batteries.
Which machines and batteries this applies to — and which it does not
This applies to machines with a built-in or supplied battery above 2 kWh: think of electrically powered tools, transport equipment for internal use, generator sets with battery buffering, or stationary installations supplied as part of a machine. This concerns the battery specifically, not the machine as a whole — the machine manufacturer therefore does not simply receive a CE-like obligation for the entire product, but an obligation that is linked to the energy storage element within it.
A battery below 2 kWh falls outside this regulation: it counts as a portable battery, and different rules apply to it than the passport — see the page about portable batteries and the battery passport. An LMT battery (for a light transport vehicle such as an e-bike or scooter) also follows a different path, even if it happens to be incorporated in an industrial product — what exactly constitutes an LMT battery is detailed on the page about batteries for light transport vehicles. And a machine that is only prepared for a battery but is supplied without a battery has no passport requirement at the time of delivery — this becomes relevant as soon as the battery is actually installed or placed on the market.
From 18 February 2027, with an implementation process already underway
The obligation for the battery passport enters into force on 18 February 2027. Until that date, there is no legal requirement to already have a passport, but the obligations of market participants under the Battery Regulation — such as keeping technical documentation and information about the battery — are already in effect through Articles 38 to 44 of Regulation (EU) 2023/1542. If a manufacturer places a machine with an industrial battery on the market now, it is practically advisable to have that information in order, because these are the same data that will later go into the passport. More about how that entry date is precisely structured is detailed on the page about when the battery passport becomes mandatory.
What this concretely means, in the order in which it usually applies
First, it is important to establish what role the machine manufacturer plays in relation to the battery: is the battery purchased and installed unchanged, or is the battery itself assembled or modified before it goes into the machine? This distinction determines who acts as a market participant for that battery according to the regulation — the battery manufacturer, the importer, or the party that installs the battery and places the combined product on the market.
After that, it is useful to check whether the battery indeed exceeds the 2 kWh threshold, as this determines whether it is an industrial battery or another category with different rules. Subsequently, the question is who holds the data about the battery: cell chemistry, material origin, performance, and the other information that must be included in a passport. For a purchased battery, this information usually lies with the supplier or manufacturer, and this information must then be transferred to whoever ultimately assembles and publishes the passport.
Finally, it is practical to determine who applies the QR data carrier to the product and who keeps the battery passport available for ten years. This is a role that a machinery manufacturer can outsource, but the responsibility that a correct passport exists remains linked to the party acting as a market participant for that battery. Anyone who is uncertain whether a specific battery in a machine falls under this scheme can check that against the broader explanation on the page about whether the battery passport applies to their own batteries.
Where this appears: article 77 and the articles on market participants
The obligation to have a battery passport for batteries falling under it is laid down in article 77 of Regulation (EU) 2023/1542. Who in the chain is responsible for meeting that obligation — manufacturer, importer, or the person who incorporates the battery and places it on the market — follows from articles 38 to 44 of the same regulation, which describe the obligations of market participants. Together, these articles determine not only that a passport must exist, but also who is responsible for ensuring that it is provided and correct.
What to do now
A logical first step is to determine which battery is in the machine, what its capacity is, and which party supplied the battery — with that information it can be determined whether the passport is required and who the point of contact will be for it. batpas.eu compiles the passport on the basis of the data supplied by the manufacturer or importer, hosts it for ten years, and supplies the QR data carrier to be applied to the product.
What this is based on
- Regulation (EU) 2023/1542, Articles 38 to 44 (obligations of economic operators)
- Regulation (EU) 2023/1542, Article 77 (battery passport)
The Regulation itself is on EUR-Lex. We refer for each statement; you need not believe us.
What you need to do concretely
What is expected of you
Machinery manufacturing is one of the sectors where the battery is often not the end product but a component of it. A forklift, an AGV, mobile work lighting, an agricultural machine with electric drive: the battery is in it, but the customer buys the machine. This changes who bears which obligation, but it does not automatically free the machinery manufacturer from every obligation. Regulation (EU) 2023/1542, articles 38 to 44 divides obligations among market participants according to the role they play: manufacturer of the battery, importer, distributor, or manufacturer of the product into which the battery is incorporated. For machinery manufacturers, this latter role is particularly relevant.
Determining whether the incorporated battery falls under the regulation
The first step is not legal but technical: what type of battery is in the machine, and above what capacity. Industrial batteries above 2 kWh are subject to a different regime than smaller industrial batteries or LMT batteries. For machines with a built-in battery pack, it is therefore first a matter of measurement, not interpretation. What the 2 kWh threshold precisely means for industrial applications is set out on the page about what the 2 kWh threshold means for industrial batteries, and which categories of batteries the regulation distinguishes are set out on the page about which batteries fall under the Battery Regulation.
Determining who in the chain is the manufacturer of the battery
Machinery manufacturers rarely manufacture battery cells themselves. The pack comes from a supplier, often outside the EU. That supplier is in most cases the party designated as the manufacturer of the battery, with the corresponding obligations from articles 38 to 44. The machinery manufacturer who incorporates the pack does not automatically acquire the same role, but does become the party to whom the end customer turns if something is missing. For a pack purchased outside the EU without an EU importer being designated, the machinery manufacturer may themselves be designated as an importer — with the obligations that entails.
Determining whether the incorporated nature changes anything about the passport obligation
A battery that is permanently installed in a machine is still a battery for the purposes of the regulation. The fact that the end user never holds the pack loose in their hands does not change whether a passport is needed. What does change is the question of who compiles and offers the passport: the party that first places the battery on the market in the EU, which in practice is often the supplier and not the machine manufacturer. This division is described on the page about who makes the passport when the battery is built into a product.
Ensuring that the correct data from the supplier are requested
Even when the machine manufacturer is not the one who draws up the passport, it is their responsibility to be able to demonstrate that the battery in the machine meets the requirements. This means: when purchasing the pack, record who provides the passport, under which number, and whether that number is supplied with each machine delivery. For a company with 10 to 100 employees, this is typically a task assigned to purchasing or engineering, not to legal or compliance departments which often do not exist at that scale.
Determining when this applies to your own range
Not every machine with a battery falls immediately under the obligation. The date on which the passport becomes mandatory and which categories it applies to first is explained on the page about when the battery passport becomes mandatory. For machine manufacturers with a long inventory cycle, this is relevant to determine from which production date or delivery the requirement applies to your own range.
Where things go wrong in practice
A recurring problem is that the supplier of the battery pack is located outside the EU and does not offer a passport themselves, because that party assumes that "the customer will take care of that". The machine manufacturer in turn assumes that the supplier does so. Between those two assumptions, the obligation falls through.
A second situation: the machine manufacturer builds machines with different battery packs side by side — sometimes from the same supplier, sometimes varying by project or by customer request. Without fixed registration per pack variant, it becomes unclear which passport belongs to which machine, especially with repeat orders or spare parts years later.
A third situation arises with in-house assembly: some machine manufacturers assemble cell modules themselves into a customised pack. This shifts the role from "installer of a ready-made pack" to something closer to battery manufacturer, with a different set of obligations under articles 38 to 44.
A fourth: when exporting machines outside the EU, it is sometimes assumed that the passport is not needed. However, the obligation is related to placing on the market within the EU, not to the final destination of the machine — this deserves to be checked on a case-by-case basis in the official text, not applied as a fixed rule.
A fifth situation applies to machines that are sold both as a separate part and as an integrated whole, for example a replacement battery pack that is also available as a separate part. That pack can then come on the market both within the machine construction and separately, possibly with a different obligation per sales form.
What you can record
- An overview per battery pack variant: supplier, whether a passport is offered, and under which number.
- Procurement terms that include that the supplier delivers the passport (or the underlying data) with each shipment.
- A fixed link between the machine serial number and the passport number of the installed pack, so that this can also be found years later during maintenance or replacement.
- Documentation of your own role in the chain (installer, importer, or assembler of the pack) — this role can vary per product line and is not automatically the same for the entire range.
- A fixed check for new battery pack suppliers or new machine variants, linked to the question of whether the battery falls under the regulation — see the page about whether the battery passport applies to your own batteries as a starting point in case of doubt.
This is not legal advice. This page provides general information about the legislation that this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-09-05. Is something incorrect? Let us know — corrections take priority.