My product needs multiple product passports — how does that work together?
One product, multiple components, multiple passports possible
A product may require multiple digital passports if it consists of several components that each fall separately under the regulations. An e-bike, for example, consists of a frame, a motor and a battery — and that battery has, independently of the rest of the bike, its own passport obligation under the Battery Regulation. The passport of the battery and any future passport of the end product (the e-bike itself) are then two separate documents, each with their own regulatory basis, their own content and their own QR code. They do not replace each other and they are not automatically merged: the battery passport remains in existence, even if that battery is built into a larger product.
For whom this matters: components with their own passport obligation
This subject is relevant to anyone placing a product on the market that contains a battery which itself already falls under the Battery Regulation — think of EV batteries, batteries for light electric vehicles such as e-bikes and e-scooters, and industrial batteries above 2 kWh. For those batteries, the passport obligation of Article 77 of Regulation (EU) 2023/1542 applies, regardless of whether the battery is sold separately or built into a larger device. This does not apply to small batteries that do not fall under the mentioned categories, nor does it automatically apply to the end product in which the battery is installed. Whether that end product itself requires a passport is a different question, answered by the ecodesign regulation (Regulation (EU) 2024/1781) — and that regulation works differently from the Battery Regulation: it is a framework regulation that is only filled in with supplementary rules per product category.
Battery passport mandatory from 18 February 2027, rest of framework yet to be filled in
For the battery itself, the date is fixed: the passport is mandatory from 18 February 2027, as laid down in Article 77 of the Battery Regulation. For the question of whether and when the surrounding product — the e-bike, the scooter, the machine — also receives its own digital product passport, it is different. The ecodesign regulation (Regulation (EU) 2024/1781) is the framework within which this can happen, but this regulation does not itself determine per product category what exactly is required, when it comes into force and which data are mandatory. That is worked out separately per product category. For light electric vehicles and comparable products, on the basis of the sources mentioned here, no date or concrete obligation can be named — anyone who needs certainty about this for a specific product would be best advised to check the official texts or contact the authority responsible for supervising the ecodesign regulation.
What this means: address the battery first, the rest follows separately
In practice, this means that attention is primarily focused on the battery passport, because there is a concrete date and a concrete article for it. The first step is to check whether the battery in the product is above 2 kWh, or falls under the category of EV or LMT battery — that determines whether Article 77 applies. The second step is to collect the data needed for that battery passport, from the manufacturer or importer, and have them compiled and hosted in time. The third step is to monitor whether an additional passport obligation comes into force for the end product itself (the e-bike, the scooter, the machine) via the ecodesign regulation — this does not happen per regulation as a whole, but per product category, via separate implementations that are yet to follow. If both passports are needed in due course, it is advisable to keep the two separate in your own administration: different data, different QR code, different legal basis, even if both are physically in the same product.
Where this is set out: Article 77 and the framework regulation on ecodesign
The passport requirement for batteries follows directly from Article 77 of Regulation (EU) 2023/1542 (Battery Regulation), which applies specifically to batteries and already contains concrete requirements and a date. The broader possibility that other products may also receive a digital passport follows from Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products), which serves as a framework regulation for product groups that are subsequently designated and specified separately. These two regulations exist alongside each other: the Battery Regulation is the specific regulation for batteries, the Ecodesign Regulation is the general framework within which comparable passport requirements can emerge for other products. This coexistence is the reason why a single composite product containing a battery can potentially be subject to two different regulations.
If you already know that a product falls under the Battery Regulation, it is best to start by getting that battery passport in order, given the fixed date of 18 February 2027. For the question of whether the end product itself will also need a passport, it is advisable to continue monitoring developments around the Ecodesign Regulation via the official source, since the concrete specifications for each product group have yet to be determined.
What this is based on
- Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products)
- 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
An e-bike consists of a frame, a motor, a control system and a battery — and with the rise of the digital product passport, multiple obligations can rest on it, each with their own rules. The battery falls under the Battery Regulation, Article 77 of Regulation (EU) 2023/1542. The product as a whole — or other components of it — may additionally become subject to the broader framework for ecodesign set out in Regulation (EU) 2024/1781, which provides for digital product passports for all kinds of product groups to be designated per product group. This raises a practical question: how do those passports relate to each other, and who is responsible for what?
What is expected of you
Keep the battery passport separate and complete
The battery receives its own passport with its own data: chemical composition, capacity, origin, repair history and more, as prescribed in Article 77 of Regulation (EU) 2023/1542. That passport stands apart from any other passports on the same product. For a company of 10 to 100 employees, this means that battery data does not mix with data about the frame, the motor or other components — even if those will shortly receive their own passport under the ecodesign regulation. Two passports, two datasets, each with its own QR code and its own life.
Distinguish between what is mandatory and what is still to come
Regulation (EU) 2024/1781 is a framework regulation: it governs how digital product passports for products in general work, but which product groups must actually have a passport and from when is worked out separately per product group. For the battery this is already concrete: Article 77 of the Battery Regulation makes it mandatory, with a fixed date. For the product as a whole — the e-bike, the scooter, the machine — it depends on whether and when that product group is designated under the ecodesign regulation. In practical terms, this means that a company can now focus on the battery passport as a fixed obligation, and can follow developments around the broader product passport without attaching a deadline that does not yet exist.
Ensure that the passports do not contradict each other
If a product has multiple passports in future, it is important that data appearing in both — such as weight, manufacturer, or a unique product code — do not diverge. A company that draws up both a battery passport and a product passport would be well advised in practice to source the basic data from a single source, so that a change in one system is not forgotten in the other. This is mainly a matter of internal data discipline: who manages which field, and where is the "truth" about a piece of information that appears in multiple passports.
Place the correct QR code with the correct component
A product with multiple passports may also need multiple QR codes — one pointing to the battery passport, and possibly one pointing to a broader product passport. For the battery itself, it is established how the QR code for the battery passport appears on the battery is placed and where it must be located on the battery. For an assembled product such as an e-bike, it is important for the end user that those two QR codes do not get mixed up: a code on the frame pointing to the battery passport — or vice versa — leads to confusion and possibly to an unwarranted suspicion of non-conformity.
Know which unique identification belongs to which passport
Each passport works with its own unique identification. How that identification is set up for the battery is described in how each battery obtains a unique identification. For a product with multiple passports, it is important that the battery identification code is not confused with any identification code of the product as a whole — these are two different objects with, probably, two different lifespans. A battery can be replaced while the product remains; the passports must be able to track that distinction.
Where things go wrong in practice
An importer of e-bikes has the battery passport compiled by the battery supplier, but upon arrival affixes its own sticker with QR code to the frame — without checking whether that code points to the correct dataset. The end user scans the code on the frame and expects battery information, but sees nothing relevant.
A machinery manufacturer integrates an industrial battery of above 2 kWh into a larger system and incorrectly assumes that one passport suffices for the entire system. The battery, however, has its own passport obligation, separate from whatever else happens with the system.
A company uses an ERP system in which product data and battery data are mixed together, because they were once placed in a single table for convenience. When setting up the battery passport, it becomes unclear which weight, which manufacturer and which code belong to the battery and which belong to the product. Anyone who thinks about this in advance can examine how the passport can be linked to their own ERP or inventory system without the datasets becoming mixed.
A dealer in light electric vehicles expects that the designation of a product category under Regulation (EU) 2024/1781 automatically also includes the battery, and postpones preparation of the battery passport until there is more clarity on the product passport. The obligation for the battery is separate and has its own, already established date.
A company thinks that replacing a battery in a product also entails a new product passport, and spends unnecessary time on it. What happens to the passport when a battery is replaced is described at whether a replacement battery receives its own battery passport — and this is a question that is answered separately from any product passport.
What you can record
- An overview per product category of which passport obligations apply: battery passport always for the relevant batteries, product passport as soon as and if the product category is designated under Regulation (EU) 2024/1781.
- An internal agreement on which system or which department manages the "single source of truth" for data that appears in multiple passports, such as manufacturer, weight or product code.
- A diagram of which QR code is on which part of the product, including a check upon receipt of goods that the correct code ends up in the correct place.
- An established link between the unique identification of the battery and that of the product in which it is installed, so that battery replacement remains traceable without disrupting the product passport.
- Documentation on where the battery passport data is hosted and who is responsible for it, something that is also important once a second passport is added and the question arises whether it is hosted by the same party.
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.