How long does it take to get the battery passport in order?

What you need to do concretely

What is expected of you

The time it takes to get a battery passport in order cannot be captured in a single figure — but its structure can. There are a few obligations that together determine how much work is involved, and for most companies with 10 to 100 employees these are manageable if tackled in time.

Collect and organize data

Article 77 of Regulation (EU) 2023/1542 (Battery Regulation) describes what information must be included in the passport: data on composition, origin, performance and what must be done with the battery at the end of its life. For a company that imports or trades batteries, this mainly means a search: what data has the manufacturer already provided, what is missing, and who must it be requested from. With an assortment of a couple of models this is straightforward; with dozens of variants and changing suppliers this can grow faster than expected. Those entering this for the first time often find that searching for the right data takes more time than filling in the passport itself.

A working passport per model or batch

The passport must be linked to a specific product and be accessible via the QR data carrier on the battery. This means that for each model — or per batch, depending on how the data differs — a passport must be compiled and published. For a company with a limited number of models this is a matter of days to weeks once the data is complete. With a broad or rapidly changing assortment it is advisable to allow for the fact that this process must be repeated per product line, and that the first time usually takes longer than subsequent times.

Testing before the passport goes live

A passport that exists but cannot be properly consulted via the QR code effectively does not meet the purpose of Article 77. Before a passport is put into use, it is customary to check whether the QR code is readable, whether the data is displayed correctly and whether the passport remains accessible after sale. Those who want to know how this is checked in practice will find more information in how do I check if my battery passport works correctly before I go live. This step is often overlooked in planning, even though it takes just as much time as compiling the data.

Ten years of hosting and ensuring accessibility

The passport must not only be correct at the time of sale, but must remain accessible throughout the entire period it is required to be consulted. This is not a one-off task but an ongoing obligation: those who host the passport themselves must find a way to continue doing so over the years, even with changes in the company, the website or the platform provider. This part takes little time to set up, but does require a structural arrangement — something that must not be forgotten at the end of the process.

Where things go wrong in practice

In practice, delays usually do not occur with the passport itself, but with what must come before it.

An importer discovers that the manufacturer in Asia does not provide all requested data as standard, and it takes weeks before the right contact person responds. A wholesaler finds that batteries already in stock present a different question than new purchases — that stock falls under a different regime, as described in what do I do with batteries already in stock, and this requires a separate process alongside the ongoing purchase.

A machinery manufacturer that installs batteries in their own equipment underestimates how much time it takes to determine whether the rules apply to their situation — a question that actually needs to be answered first, before time is spent on the rest of the process, see does the battery passport apply to my batteries.

An e-bike importer with a small assortment assumes that a small batch does not need a passport, and later discovers that quantity is not an exemption ground — which means preparation only begins at a time when there is little time left. More on this can be found in can I also create a battery passport if I only sell a few hundred units.

And in companies where the passport is drawn up internally by someone doing this alongside other tasks, the deadline often slips further back — not because the task itself is so demanding, but because it never rises to the top of the priority list until time really starts to tighten.

What you can record

To keep track of the lead time, it helps to document a number of matters in writing — not as a formality, but to prevent the process from stalling midway due to ambiguity.

• An overview of models and batches that require a passport, with the status of data collection per model.
• Contact agreements with manufacturers or suppliers on who supplies which data and within what timeframe — especially relevant when the origin lies outside the EU.
• A plan for existing stock, separate from the process for new procurement, as explained in what do I do with batteries already in stock.
• A step-by-step plan with sequence and responsibilities, for example structured according to how do I approach the battery passport step by step, so that it is clear which step must be completed when.
• A test moment before going live, documented as a fixed step in the process rather than a loose check afterwards.
• An agreement on long-term hosting, including who is responsible if the platform or supplier changes.
• A cost estimate per model, so that budget does not become a delaying factor once the data is ready — see also what does a battery passport cost.

Those who get these points down on paper early usually discover that the actual delay is not in the passport itself, but in the steps that come before it — and that those steps, provided they are started in time, can easily be completed well within the remaining time until 18 February 2027.