Which data on collection and recycling belong in the battery passport?

Collection and recycling instructions and data belong in the product passport

The battery product passport contains information that supports the collection and processing of a battery at the end of its life: where and how the battery is to be returned, which materials it contains that are relevant for disassembly and recycling, and which safety aspects apply. This is not a separate chapter added afterwards, but a fixed part of the data set prescribed by Annex XIII to the Battery Regulation. The underlying idea is that a recycler, collector or dismantler does not need to open or test the battery to know what it contains — that information is already available via the QR code on the battery.

Who this applies to and which data are excluded

This data obligation applies to the batteries for which the product passport becomes mandatory: EV batteries, batteries for light electric vehicles (such as e-bikes and scooters) and industrial batteries above 2 kWh. For these categories, Annex XIII describes which data on composition, hazardous substances and treatment belong in the product passport. This concerns information relevant to the waste phase — i.e. on disassembly, storage and processing — not the operational collection systems themselves. The actual collection points, collection rate targets and the organisation of take-back schemes are regulated in Articles 59 to 62 of the Battery Regulation, and these two tracks run in parallel: the product passport documents the battery, Articles 59-62 regulate the system in which that battery is collected. Data on the individual collection route of one specific battery (which producer is registered with which municipality, for example) do not belong in the product passport itself, but in the administration of producer responsibility.

When this becomes mandatory

The battery product passport becomes mandatory from 18 February 2027. Until that date, there is no obligation to make this information available via a digital product passport with QR code, although manufacturers and importers can start doing so now. The underlying collection obligations from Articles 59 to 62 have their own regime and do not automatically align with the product passport date — anyone wishing to prepare for this would be well advised to follow both tracks separately rather than assume that one obligation replaces the other.

What this means for compiling the product passport

When drawing up the product passport, it is practical to collect the data on the waste phase in the same order as a recycler needs it. First the material composition: which substances are in the battery that are relevant for disassembly or that could pose a risk if handled incorrectly, such as certain metals or electrolytes. Then the physical information: how the battery is constructed, whether there are instructions for safe disassembly, and what warnings apply to storage and transport in the waste phase. Then the administrative layer: under which producer responsibility scheme the battery falls and via which system collection takes place, insofar as this is requested in Annex XIII. For e-bike and scooter importers, this concretely means that this data is usually already available from the manufacturer — in product documentation, safety data sheets or technical specifications — and that compiling the product passport is mainly a matter of arranging this existing information according to the structure prescribed by Annex XIII. Anyone who puts this data in order now will not have to do so under time pressure when the obligation takes effect.

Where this is laid down: Annex XIII and Articles 59 to 62

The content of the battery passport, including data relating to the end-of-life phase, follows from Annex XIII of Regulation (EU) 2023/1542 (the battery regulation). This annex lists which information categories must be included in the passport, including data on materials and treatment relevant to recycling. The broader obligations concerning the collection of waste batteries — apart from the passport — are laid down in Articles 59 to 62 of the same regulation. For the precise wording and the complete list of mandatory data categories, the text of the regulation itself is the designated source.

For those already working with an e-bike or battery assortment, the first concrete step is to inventory the documentation that the manufacturer already provides on materials, hazardous substances and disassembly instructions. Batpas.eu converts this data into the structured form required by the passport and provides the QR data carrier and hosting for the mandatory period, so that the information is ready for use when the obligation comes into force.

What this is based on

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

Include information on separate collection

The battery passport contains data that tells the user and the subsequent processor how a battery must be separately collected at the end of its life. This is not merely a symbol on a label: Annex XIII of Regulation (EU) 2023/1542 links the passport to the collection obligations set out in Articles 59 to 62 of that regulation. For an importer of e-bike batteries or a trader in industrial batteries, this means that the data already collected for the passport — chemistry, composition, origin — are also used to indicate via which channel and under what conditions the battery should be collected at the end of its life. This connects to the question what data about the materials in a battery do I need to provide exactlybecause the material composition also determines which collection and processing route is appropriate.

Make disassembly and processing information available

In addition to collection data, Annex XIII calls for information relevant to disassembly and treatment: how the battery is removed from a product, which components are involved and what precautions a processor must take. For a machinery manufacturer that integrates battery packs into its own equipment, this means that the construction of the pack — how cells, housing and connections are related — must be documented and accessible to recycling companies. This information overlaps with what is already recorded at which hazardous substances must I report in the battery passportbecause hazardous substances are often precisely determinative of how a disassembly can proceed safely.

Link with data on recycled material

The Battery Regulation gives attention to the proportion of recycled material in new batteries, and those data are not separate from the recycling information in the passport. A company placing batteries on the market takes into account, when building the passport, the relationship between what is recovered at the end of life and what goes into the beginning of a new battery. For those without an established process yet, a starting point can be found at how do I demonstrate the proportion of recycled cobalt, lithium, nickel and lead.

Keep data current until the waste stage

A passport hosted for ten years must contain usable information throughout that entire period — also at the moment a battery is actually scrapped. This requires a maintenance schedule: data entered when the passport is first created can become outdated after years of use, for example if the battery has been repaired or its composition has changed. Companies that have not yet put this process in place will find a starting point at how often must I update the data in the battery passport.

Arrange accessibility for collectors and processors

Recycling data only have value if the party that actually collects or processes the battery can also access it. This raises the question of who may view which data from the passport, and whether all information must be visible to everyone or whether certain data should remain restricted for commercially sensitive parts. This distinction is further explained at who may view which data from the battery passport.

Where things go wrong in practice

An importer of scooter batteries supplies the passport with only the data available at the time of import, without taking into account what a processor will need years later to safely disassemble the battery. The result: the passport lacks practical disassembly information that only becomes relevant in the waste stage, even though that information was already known to the manufacturer at the time of compilation.

A machinery manufacturer integrates battery packs into its own equipment and assumes that the recycling obligation lies with the battery supplier, because that party supplied the passport. In practice, the passport proves not to be adapted to the specific installation situation, so disassembly information about how the pack is attached in the machine is missing.

A battery trader works with intermediate stocks and sells batteries without checking the digital product passport for recycling data, assuming this has already been handled at first market introduction. When a batch of batteries is disposed of years later, the collection information proves to be outdated or incomplete, without anyone in the supply chain having noticed.

A company maintains data on recycled material and data on collection in two separate systems without aligning them. During an inspection, it emerges that the digital product passport states a share of recycled material that does not match the way the battery is collected at end of life.

An importer assumes that the QR data carrier is sufficient as the sole source of information for recycling facilities, without verifying whether the data behind that QR code actually match what a processor needs to treat the battery correctly.

What you can record

An overview of the disassembly instructions per battery type, including the location of hazardous components and the way cells, housing and connections are interrelated.
A fixed contact point or process to update recycling data when a battery is repaired, modified or changes ownership during its service life.
A document stating which data from the digital product passport are specifically intended for collectors and processors, and which data are intended for other parties — with a reference to the agreements on who may view which data from the battery passport.
An internal agreement on how data on recycled material are recorded and linked to the recycling information in the digital product passport, so that both are aligned.
A checklist that is ticked off upon delivery of the digital product passport, based on the data that Annex XIII requests, with a reference to the overview of which data must be in the battery passport as a basis for the completeness of that overview.
A documented agreement with suppliers or customers about who is responsible for keeping recycling data up to date during the service phase of the battery.

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 2026-08-22. Is something wrong? Let us know — corrections take priority.