How do I approach the battery passport step by step?

The approach in a nutshell

The battery passport is created in a fixed sequence: first it becomes clear which data are mandatory, then that data is collected at the source, next the passport is compiled and hosted, and finally the battery itself is provided with the QR code that refers to that passport. This sequence is not by chance — a passport without underlying data is empty, and a passport without a QR code on the battery is unfindable for those who need it. Whoever tackles this step by step therefore does not start with the QR code but with the question of what information should actually be included in it.

Which batteries and which parties this applies to

It concerns three categories: batteries for electric vehicles, batteries for light means of transport such as e-bikes and scooters, and industrial batteries above 2 kWh. Smaller batteries — a loose power bank cell, a battery in a toy car — do not fall under this. The obligation rests with the party placing the battery on the EU market: usually the manufacturer, or in the case of imports from outside the EU the importer acting as the first responsible party. A retailer reselling batteries that are already provided with a passport does not have to draw up that passport themselves — that link in the chain delivers what has already been made. Whoever themselves sources batteries or products with batteries from a third country and is the first to place them on the EU market is indeed the party that must have the passport compiled.

From when this must apply, and what applies until then

The obligation comes into force on 18 February 2027. Until that date, there is no legal obligation to maintain a digital battery passport, but the data that must be in the passport from then on — composition, origin, performance, repair and recycling information — are not collected overnight. Manufacturers and importers who already begin organising this data now will have a head start when the obligation comes into force; those who wait until just before the date must do the same amount of work in much less time.

The steps in the order in which they apply

The first step is to check whether a product falls within the scope: an EV battery, a battery for a light means of transport, or an industrial battery above 2 kWh. Everything below or outside that currently has no passport obligation.

The second step is to determine who in the chain is responsible. In the case of imports from outside the EU, this is usually the importer; for production within the EU the manufacturer. This question is not always straightforward when there are multiple links between factory and end user, and therefore deserves attention before data is collected — otherwise work is done by the wrong party.

The third step is to inventory which data are needed. Annex XIII of Regulation (EU) 2023/1542 lists what a battery passport must contain: among other things, data on the composition and origin of materials, performance and durability, and information relevant to repair, reuse and recycling. This overview effectively forms the checklist with which the rest of the process is structured.

The fourth step is to actually collect the data. For an importer, this usually means: requesting it from the manufacturer in the country of origin. Not every manufacturer outside the EU is familiar with what Annex XIII exactly asks for, so this step often requires more coordination than the other steps combined.

The fifth step is to have the passport compiled from the collected data and to arrange hosting that bridges the lifetime of the battery. A passport that goes offline after a few years does not meet the purpose of Article 77: the data must remain accessible as long as the battery is in use.

The sixth and final step is the link between the digital product passport and the physical battery: the QR code or equivalent data carrier that is affixed to or placed with the battery, and that directly refers to the passport. Without this link, the passport exists, but it cannot be found by a user, installer or recycling company.

Where this sequence follows from

That a battery product passport must be created is stated in Article 77 of Regulation (EU) 2023/1542 (Battery Regulation). Which data the passport must precisely contain is set out in Annex XIII of the same regulation. Together, these two sources determine both the obligation and the content, and thereby also the sequence in which a process is logically structured: first find out what must be included, only then collect and build.

Anyone wishing to start now would be well advised to first determine which category their own batteries fall under and which data from Annex XIII are already available and which must still be requested from the manufacturer. That overview is the basis on which the rest of the process — compilation, hosting and the QR code on the battery — is built.

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

What is expected of you

The battery passport does not come into existence all at once. It is a sum of steps that largely run one after the other, and each step has its own pitfall. Below is the sequence that works in practice.

Determining whether the battery falls under the obligation

Not every battery that a company trades will need a passport. The regulation targets specific categories, and the first step is to check whether your own product group falls under them. For an importer who brings both e-bike batteries and loose industrial batteries to the market, the answer can differ per product line. If you do not yet have a clear picture of this, you will find a detailed explanation at whether the battery passport applies to your own product group.

Collecting data according to Annex XIII

Article 77 of Regulation (EU) 2023/1542 (batteries regulation) stipulates that the passport must provide access to the data set out in Annex XIII. That is a substantial list: from chemical composition to the origin of raw materials, from performance to recycling information. For a company with 10 to 100 employees, this usually means that data from multiple sources come together: technical specifications from the manufacturer, test reports, procurement documentation and sometimes information that only arises at the importer itself, such as the moment of placing on the EU market. Companies that do not have this data centralized often only discover when filling it out how many separate files are actually needed.

Choosing and linking a carrier

The passport must be digitally accessible via a data carrier, in practice a QR code on the battery or the packaging. That is more than sticking a sticker on: the code must continue to work as long as the battery is in use, and must point to the correct, up-to-date data. For companies working with small series, this often raises the question of whether this is worthwhile; an answer to that question can be found at making a battery passport for a small run.

Arranging hosting and availability over time

The data must not only exist, but also remain accessible for years to come. That requires a choice: host it yourself, or outsource this to a platform that guarantees continuity. For a company without its own IT department, this is often the part that takes the most time, partly because availability does not stop at delivery but continues as long as the battery is on the market.

Testing before the passport goes live

A passport that exists but does not open correctly does not count as in order. For going live, it is common practice to check whether the QR code actually leads to the correct data, whether the information is complete according to Annex XIII, and whether it is also readable on a mobile device. An overview of what to check in this regard can be found at testing the battery passport before going live.

Where things go wrong in practice

Data are spread across multiple departments. Procurement has the supplier data, engineering has the test results, and no one has the overview. Compiling the passport then runs into delays because every time something has to be requested from a different colleague or supplier.

The QR code is devised separately from the process. A code is created and stuck on the battery, while the underlying data is not yet complete or not yet verified. The result is a working code that points to an incomplete passport.

Inventory that has already arrived is forgotten. An importer sets up the process for new shipments, but batteries that are already on the shelf or in the warehouse remain out of sight. What to do with these is covered at batteries already in stock.

Second-hand and refurbished batteries are overlooked. When trading in used e-bike batteries or refurbished industrial batteries, it is sometimes assumed that the passport only applies to new products. Whether and how this also applies to second-hand and refurbished batteries is worked out at the page on second-life and refurbished batteries.

Planning is started too late. Because assembling the battery passport requires multiple steps and multiple parties, the lead time often turns out to be longer than expected. An assessment of what is realistic in this regard is provided at how much time it takes to get things in order.

What you can record

An overview per product line of which batteries fall under the obligation and which do not, with the substantiation for this.
A list of the data from Annex XIII, with per data item the source: manufacturer, own administration, test report or otherwise.
A fixed point of contact or process for keeping the data current, especially when a battery enters a second life and the information in the passport must be adjusted accordingly — see what needs to be arranged if a battery enters a second life.
A test protocol that is followed before a passport goes live, including who performs the check and what is signed off on.
An overview of the costs per passport, so that this is reflected in the pricing; an indication of the composition is provided at what a battery passport costs.
Agreements on collection and take-back, because that chain affects the data that must be included in the passport; see arranging collection and take-back.
A protocol for the case where a battery must be recalled, with in it who adjusts the passport and how the amendment is documented; worked out at what to do if a battery is recalled.
A file per battery type that is ready in case a supervisory authority asks for it; what to expect in this regard is provided at what a supervisory authority asks for during an inspection.

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.