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Does a replacement battery get its own battery passport?

Yes, a replacement battery is a separate product with its own passport

A replacement battery that is placed on the market independently — that is, sold separately as a replacement for a battery that is broken, worn out or at the end of its service life — generally receives its own battery passport. The obligation under Article 77 of the Battery Regulation is linked to the placing on the market of a battery that falls within the designated categories (EV batteries, batteries for light means of transport, industrial batteries above 2 kWh), not to the device in which that battery was originally installed. If such a battery is replaced by a new specimen that is sold or supplied separately, then that new specimen is in itself again a battery being placed on the market — with everything that entails, including the passport.

Which batteries this applies to, and which do not

This applies to the categories for which the passport is already mandatory: EV batteries, batteries for light means of transport (e-bikes, scooters) and industrial batteries above 2 kWh. If it is a replacement battery within such a category, it counts as a standalone product as soon as it is placed on the market separately. The situation is different for batteries that do not fall within these categories — think of small portable consumer batteries — these fall outside the passport requirement anyway, whether replacement or not. There is also a relevant distinction: if it is a matter of repair or reuse of the original battery itself, without a new battery being placed on the market, then there is no question of a new product and therefore not automatically a new passport obligation for that specimen. The passport of the original battery remains relevant, not a new passport. Article 11 of the Regulation concerns the possibility of removing and replacing batteries in devices — that article provides that a battery must be interchangeable, and thereby implicitly confirms that a battery is regarded as a standalone, replaceable component. This is precisely why a replacement specimen is treated as a separate product as soon as it is placed on the market.

When this applies

The general date on which the battery passport becomes mandatory is 18 February 2027, still 181 days away. This date follows from Article 77 and applies to batteries within the designated categories that are placed on the market from that date onwards — including replacement batteries that come to market as separate products from that date. For batteries that have already been placed on the market before that date, other transitional rules apply which are not addressed here; anyone specifically affected by this is well advised to consult the official text of the Regulation on that point. Until 18 February 2027, the passport obligation does not yet apply, not even for replacement specimens — but anyone who now supplies replacement batteries that are still on the market after that date is well advised to start collecting the necessary data in good time.

How this works in practice

For those supplying replacement batteries — for example, a dealer in e-bike batteries or an importer offering standalone industrial batteries as replacements — the first step is to determine whether the replacement battery itself falls within one of the three designated categories. If it does, the next step is to check whether that battery is placed on the market as an independent product, separate from the device in which it is installed. If that is confirmed, the same approach applies to that replacement battery as to a battery supplied for the first time: the data of the manufacturer or importer are collected, a passport is compiled, and a QR data carrier is attached to that battery. That passport is separate from any passport of the original battery being replaced — it is a new product with its own passport, even if it serves the same function in the same device. Anyone in doubt as to whether a specific replacement is considered "placing on the market" is well advised to check this against the definition in Article 77 and Article 11 of the regulation itself.

Where this follows from: Article 77 and Article 11

The link between "placing on the market" and the passport obligation is established in Article 77 of Regulation (EU) 2023/1542. That article regulates the battery passport for the designated battery categories and ties the obligation to the moment at which a battery as a product enters the market. Article 11 of the same regulation concerns the possibility of separation and replacement of batteries in devices, and emphasizes that a battery is considered as a separate, interchangeable component — a starting point that is directly relevant to the question of whether a replacement unit counts as its own product.

Anyone supplying a replacement battery within one of the three designated categories is well advised to now check what data from the manufacturer or importer are available, so that the passport can be compiled in time once the obligation takes effect.

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

An e-bike breaks down due to the battery, not the frame. The importer or dealer supplies a replacement battery, separately, as a component. The question that arises: does that replacement battery count as a new product with its own passport, or is it linked to the passport of the original battery being replaced?

The answer that follows from Article 77 and Article 11 of Regulation (EU) 2023/1542 (Battery Regulation) is: a battery placed on the market as a replacement is, for the purposes of obligations, a battery like any other. Article 77 links the obligation to provide a battery passport to the placing on the market of a battery that falls within the scope — not to the question of whether that battery is an original or a replacement unit. Whoever supplies a replacement battery is, in practice, placing a battery on the market, and that triggers the same obligation as in an initial supply.

Article 11 is relevant in this regard because it governs the possibility of removing and replacing a battery — that is, taking a cell or pack out of a device and exchanging it. That article says something about the technical and physical possibility of replacement, but not that a replaced battery should be permitted without a passport. The two obligations are separate: one governs whether a battery must be replaceable, the other governs whether a passport must accompany it.

What is expected of you

Treating a replacement battery as a newly placed on the market product

For an importer or dealer supplying replacement batteries — separately, as spare parts, or built into a revision — this means that each supplied battery is eligible for its own passport, in the same way as the battery originally supplied with the device. In practice: a company of 10 to 100 employees that sells both complete e-bikes and loose replacement batteries must set up a passport process for those batteries in the same way as for any other battery type that it places on the market. There is no exemption for "components" that are not also regarded as independently supplied batteries.

Giving a unique identification to each replacement battery

Because a replacement battery is considered a standalone product, it must also be independently identifiable. With a substantial replacement inventory — think of a dealer supplying hundreds of batteries per year as a replacement part — it is practically inconvenient if batteries are tracked only on the basis of the model or the device in which they are used. How this is set up in practice is described on How do I give each battery a unique identification?.

Distinguishing between a replacement battery and a repaired battery

Not every intervention is a replacement. A battery that is repaired — for example, cell replacement within an existing pack, or recalibration — remains essentially the same battery with the same passport. A battery that is exchanged in its entirety for a new unit is not. For a company offering both repair and replacement, it is practically relevant to make that distinction internally clear, as it determines whether a new passport is required or not.

Ensuring that the replacement battery carries its own QR code

A battery passport is only useful to the user if the corresponding QR code is on the battery itself. With a replacement battery that is supplied separately, this is a point of attention: the code must come with the component, not with the device in which it was originally located. How that code is applied to the battery is explained on How does the QR code for the battery passport get on the battery?.

Where things go wrong in practice

A few situations that frequently occur with replacement batteries:

  • The replacement battery is regarded as "just a component", with the result that no one in the company wonders whether a passport must accompany it. This perception arises especially with smaller, quickly deliverable batteries for light electric vehicles, because the battery looks no different from an ordinary spare part.
  • The passport of the old battery is "transferred" to the new one, assuming the device should have one passport. This backfires: the passport belongs to the battery, not the device, and a replacement battery with a different composition or origin requires its own data.
  • A replacement battery from a supplier other than the original manufacturer is supplied without clarity on who is responsible for compiling the passport — the original manufacturer of the device, or the party that actually brings the replacement battery to market.

What you can record

  • An internal overview of which delivered batteries are considered "replacement parts" and which are repair parts within an existing pack, so it is clear when a new passport is needed.
  • A fixed procedure for assigning a unique identification to each replacement battery at the time of delivery, rather than retrospectively.
  • Agreements with the manufacturer or supplier of the replacement battery on who provides the data for the passport, and in what form.
  • A record of which QR code has been applied to which physical battery, linked to the inventory or order number with which the replacement was delivered.
  • A fixed location where these agreements and the associated passport data remain accessible for ten years, even when the replacement battery was supplied via a different department or branch than the original sale.

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.