must the place and date of production be included in the battery passport
Yes, production date and production location belong in the battery passport
Production date and production location are among the data that Annex XIII to the Battery Regulation requires for the battery passport. These are two separate pieces of information: the moment when the battery was produced, and the place — usually the factory or production address — where this occurred. Both are part of the basic identification of the battery, in the same category as, for example, the battery model and the name of the manufacturer.
Which batteries this applies to, and which do not
This obligation applies to the batteries for which the battery passport itself is mandatory: EV batteries, batteries for light means of transport (such as e-bikes and scooters) and industrial batteries above 2 kWh. For portable batteries without a passport requirement and for batteries that fall outside the scope of the Regulation, this requirement does not apply — simply because no passport is drawn up for those batteries. Also important is the precision required: this concerns the production date and location of the battery itself, not that of individual components such as cells that were manufactured elsewhere and later assembled into a battery pack. How these two relate to each other depends on how the production process is arranged at the manufacturer.
Mandatory from 18 February 2027, like the rest of the passport
This requirement is part of the broader passport obligation that enters into force on 18 February 2027. There is no separate or earlier date on which specifically production date and location become mandatory — that data simply runs along with the rest of the passport data. Until that date, there is no legal obligation to disclose this information via a passport, but that does not mean the information must not exist: manufacturers and importers typically already keep production date and location on record for their own administration, quality control or traceability, and that data is often already available when the passport is compiled.
What this means for those having a passport compiled
Those thinking about the passport now would do well to record production date and location early in the process, together with the other basic data. In practice, this usually comes in this order:
First, it is determined from which party this information comes — often the manufacturer, but when importing batteries produced elsewhere, that information lies with the factory of origin and must be requested or provided. Next, it is established how exactly the location will be indicated: a factory location with city and country is common, but the exact format that the data structure of the passport expects follows from the technical elaboration of Annex XIII. After that, it is checked whether the production date is known at battery level, or whether it is only recorded at batch level — in the latter case, it is advisable to check whether batch information sufficiently aligns with what the passport requires.
These two pieces of data rarely stand alone. They are usually supplied together with the other identification data that must appear in the passport, such as the battery model, the weight and the chemistry of the battery. A good overview of what all must be included can be found on the page about which data must be included in the battery passport. Those who also need to work out how the chemical composition is recorded will find an elaboration on the page about recording battery chemistry — information that is often provided in the same breath as production date and location, because it comes from the same production documentation.
For importers placing batteries from a foreign manufacturer on the market, it is practical to already inventory whether the manufacturer supplies this data as standard, or whether that needs to be requested separately. The earlier this process runs, the less pressure there will be when the passport obligation enters into force.
Where this is derived from: Annex XIII and Article 77
The obligation to include production date and production location follows from Annex XIII of Regulation (EU) 2023/1542 (Battery Regulation), which sets out what data the battery passport must contain. Article 77 of the same regulation governs the passport obligation as a whole: for which batteries a passport is mandatory, and from when that obligation applies. Together, these two provisions determine that production date and production location are not optional additions, but a fixed part of the dataset that belongs with the passport.
What to do now
Whoever has a battery passport drawn up via batpas.eu should ideally include production date and production location immediately in the data provided, together with the other basic information about the battery. For those uncertain whether this information is available at battery or batch level, it is advisable to check this now with their own manufacturer or production department — then this search will not be necessary when the obligation comes into force on 18 February 2027.
What this is based on
- Regulation (EU) 2023/1542, Annex XIII (data in the battery passport)
- 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
What is expected of you
Including production location in the passport
Annex XIII to Regulation (EU) 2023/1542 lists the place of production as data that must appear in the battery passport. For a company of 10 to 100 employees, this means in practice that a fixed, verifiable value is needed that matches what appears in the manufacturer's production documentation — not marketing text such as "made in Europe", but a concrete location that can be traced back to the factory or the production process. Importers of batteries or e-bikes who have the passport compiled should ideally obtain this data directly from the documentation provided by the manufacturer, rather than deriving or estimating it themselves.
Including production date in the passport
The same Annex XIII also lists the date of production as mandatory data. This seems straightforward, but for batteries produced in batches or series it is not always clear which date is meant: the date of the production batch, final assembly, or the last testing phase. For an importer processing hundreds or thousands of units per year, it is practically relevant to agree in advance with the manufacturer which date is to be provided and in what format, so that it is consistent across all passports for the same battery line.
Alignment with the rest of the passport
Production date and production location do not stand alone. They are part of the basic identification of the battery, together with other data that must appear in the passport, such as the model, chemistry and manufacturer. Anyone who wants to know exactly which other fields are mandatory and how they relate to each other will find a complete overview on the page about which data must be included in the battery passport. For a company having the passport compiled by a third party, it is practical to provide these basic data all at once, completely and consistently, rather than supplementing them in phases after a passport has already been published.
Where things go wrong in practice
An importer of light means of transport receives from the Asian factory only a shipment date and an invoice date, but no explicit production date — making it unclear which date should appear in the passport.
A battery trader sells the same battery under different model names to different customers, but the production location is not consistently taken over when compiling the passport, so two passports for physically identical batteries show a different location.
A machinery manufacturer assembles industrial battery packs from cells supplied by multiple suppliers, and there is no clear answer to the question of whether the "production date" is the date of cell production or the date of pack assembly.
An importer works with a factory that occasionally changes its production location (for example between two factory halls or two countries), without this change being communicated to the person compiling the passports, so that older and newer passports show an incorrect location.
A company obtains the production date from an internal ERP system that registers the date of receipt in its own warehouse, instead of the actual production date of the manufacturer.
What you can record
- A fixed agreement with the manufacturer on which date is to be communicated as "production date" (for example date of final assembly or last quality test), including the format in which it is to be supplied.
- Manufacturer documentation in which the production location is specified, for example a certificate of origin, a factory list or a supplier declaration.
- An internal overview per battery model or production line, in which production date and location are linked to the model, so that this information does not need to be looked up again per unit.
- A procedure for when a manufacturer changes production location, so that this change is communicated to whoever manages the passports — this connects to the question how often the data in the battery passport must be updated.
- A fixed delivery format towards batpas.eu or another party that compiles the passport, in which production date and location are included as a separate field alongside other basic data such as the battery chemistry.
- An internal check whether the production location that appears in the passport does not disclose information that is considered commercially sensitive — a question that touches on the subject protecting commercially sensitive information in the battery passport.
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 2026-09-05. Is something incorrect? Let us know — corrections take priority.