How long must a battery passport remain available?
Ten years accessible, calculated from market launch
A digital battery passport remains available for ten years, calculated from the moment the battery in question is placed on the market. This is not a fixed calendar date for all passports together, but a period that begins anew for each battery. A passport created upon delivery in 2027 thus runs through well into the 2030s, and a passport for a battery sold only in 2031 runs for another ten years from that point. The obligation therefore does not rest with the platform or the service provider, but with the battery itself: as long as it can be used, repaired or processed somewhere, the associated data must remain retrievable via the QR code on the battery.
Which batteries this applies to, and which do not
This retention period is part of the digital battery passport as laid down in the Battery Regulation, and that passport applies to EV batteries, batteries for light means of transport (such as e-bikes and scooters) and industrial batteries above 2 kWh. For smaller portable batteries, such as standalone batteries for consumer electronics, this passport obligation does not apply in the same way, and therefore neither does this retention period. It is furthermore a period for the data about the battery, not for the battery itself: nothing is said about how long a battery must function or how long warranty applies. These are two separate things that are related to each other, but are not the same. A battery can thus become defective or be replaced after a few years of use, while the passport for that specimen must remain available for years to come — for example for recycling, reuse or second-life applications.
What applies until 18 February 2027, and thereafter
At present, there is no legal obligation to maintain a battery passport; that obligation takes effect on 18 February 2027. Until that date, there is therefore no retention period running — it only begins to run once a battery subject to the obligation is actually placed on the market. What does happen in the coming period is that parties importing or assembling batteries are already preparing the necessary data, so that it is ready from the effective date. The exact start of the ten years per individual battery has therefore not yet begun; what is established is the effective date of the obligation itself, and the fact that the period for each battery only begins to run once it is placed on the market.
What this means for those importing or selling batteries
For anyone placing e-bikes, scooters or industrial batteries on the market, the first question is whether the product falls under the categories for which the passport becomes mandatory. If so, the next question is not only who compiles the passport, but also who keeps it accessible for ten years via the QR code — even if their own company changes name, changes ownership, or ceases operations during that period. That last point is where many companies face difficulties in practice: a webshop or importer that no longer exists five years later still cannot comply with an obligation that is attached to the battery, not to the company. This is why hosting by a third party that specifically focuses on this retention obligation is often chosen in practice over managing the data oneself on a company's own server or website. In concrete terms, this means for those preparing for this: first determine whether your own products fall under the obligation, then obtain the necessary data from the manufacturer or supplier, and finally arrange a way to keep that data accessible for the entire period, independent of the lifespan of your own company.
This is based on: Article 77 of the Battery Regulation
This retention period follows from Article 77 of Regulation (EU) 2023/1542, the article that governs the digital battery passport. For the precise wording — including any exceptions or special cases mentioned in the regulation itself — the official text of that article is the authoritative source; this page describes the main line as it follows from the regulation, but does not replace the legal text.
Anyone currently importing or selling batteries that will fall under this obligation would be well advised to start by inventorying which products are involved and what data about them is already available from the manufacturer or supplier — so that no backlog needs to be made up at the date of entry 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
A battery passport is not a document that you draft once and then forget about. The passport must remain available and accessible for a certain period — even if the battery has been in use for years, changes hands, or the company that had the passport drawn up no longer exists in its current form. Article 77 of Regulation (EU) 2023/1542 (the batteries regulation) sets out the obligation to maintain the passport, but the precise duration mentioned in the regulation is a detail for which the official text provides the exact wording. What is certain in this context: the obligation rests with the party that brought the passport into being, and that obligation does not cease once the battery leaves the premises.
What is expected of you
Keep the passport accessible after sale
Once a battery is sold, the passport remains in circulation. That means the QR code on the battery, regardless of how old the device containing the battery is, must continue to point to functioning data. For a company with 10 to 100 employees, this primarily means: do not link data storage to a system that will be discontinued or migrated in a few years without ensuring that existing QR codes continue to work. How does the QR code for the battery passport get on the battery? describes where this code is placed on the battery and what that entails — that choice has implications for how long the link remains valid.
Ensure that data remains online, even with system changes
The data itself must be stored somewhere, and that location must continue to exist for as long as the obligation applies. This is a different matter from drawing up the passport itself: it concerns hosting, management and continuity. Where is battery passport data stored online and who manages it explains how that responsibility is handled in practice and where it lies. For a mid-sized company, this is often the point at which a choice is made between hosting in-house or outsourcing to a party for which maintaining this continuity is a core activity.
Maintain the link with unique identification
Each passport belongs to one specific battery, not to a product model in general terms. That link must remain intact, even after years. How do I give each battery a unique identification? describes how that identification is set up — and that setup also determines how robust the link remains over time. A system that reuses identification numbers or does not record them consistently makes it more difficult to maintain the passport linked to the correct battery in the long term.
Take account of business changes
A company with 10 to 100 employees undergoes changes in form more often than a multinational: takeovers, name changes, discontinuation of a product line or complete closure of business occur relatively frequently. The obligation to maintain the passport does not automatically disappear with such a change. What happens to the battery passport if my company stops? addresses what happens to that responsibility when the original party no longer exists.
Where things go wrong in practice
A data provider discontinues the service without transfer. Companies that outsourced the hosting of their passports to a small or one-off service provider run the risk that the service provider will stop at some point — causing QR codes in the field to lead to a dead link.
System migration without preservation of existing links. When switching to a new ERP or inventory system, the link with existing passports is sometimes overlooked, causing old QR codes to no longer point to the correct data. Can I link the battery passport to my ERP or inventory system? is relevant when setting up such a link, precisely to prevent this type of breakdown.
A merger or takeover in which no one assumes the passport obligation. In business takeovers, attention is often paid to inventory, customer database and trademark rights, but less often to the question of who is responsible for existing battery passports after the takeover.
Confusion about responsibility for replacement parts. When a battery is replaced under warranty or as a spare part, it is not always clear whether the original certificate remains valid or whether a new certificate is created. Does a replacement battery get its own battery passport? describes how that situation works.
Assumption that the certificate disappears if the product is no longer sold. Some companies believe that the obligation ceases once a product line is phased out. However, the obligation is linked to the battery already in circulation, not to whether the model is still available.
What you can record
- An agreement with the hosting party setting out what happens upon termination of the service, including an obligation to transfer data to another party.
- An internal indication of responsibility within the company: who is the contact point for certificate continuity, and how is this transferred when staff changes.
- A clause in acquisition or merger documentation stipulating who takes over the existing battery certificates.
- An overview of issued certificates linked to unique identification numbers, so that when questions arise from a supervisory authority or buyer, it is quickly clear which certificate belongs to which battery.
- Arrangements on data portability in the event of a system change, so that existing QR codes continue to refer to the correct, current data.
- A procedure for batteries that are replaced, so that it is established whether the existing certificate remains valid or is replaced — see also the templates on this subject for replacement batteries.
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.