Does the starter battery of a car fall under the battery passport?

What you need to do concretely

What is expected of you

Determine which category the starter battery falls under

The Battery Regulation uses a classification system into categories, and a starter battery from a car does not automatically fit neatly into one category. A starter battery — usually a lead-acid battery that starts the engine and powers the on-board electronics — is not a traction battery (which propels the vehicle) and therefore not an EV battery in the sense of the Regulation. For a company importing or trading starter batteries, this means that the first step is always to establish what type of battery it is exactly, regardless of the assumption that "in a car" automatically means "EV battery". Article 3 of Regulation (EU) 2023/1542 provides the definitions used to make that classification, and that classification then determines which obligations apply. Anyone in doubt as to whether a particular type of battery falls under the Regulation will find a general explanation on which batteries fall under the Battery Regulation.

Assess whether the starter battery qualifies as an industrial battery

Starter batteries not considered portable batteries may, within the system of the Regulation, fall into the residual category of "industrial battery". For industrial batteries, a threshold applies: batteries below 2 kWh fall outside some of the obligations that apply to the heavier industrial batteries. A typical car starter battery has a capacity that often falls (well) below that 2 kWh threshold, which is relevant to the question of whether the digital passport applies. For a company with 10 to 100 employees that stocks starter batteries, it is practical to document the capacity in kWh for each product line, so that this comparison with the threshold does not need to be checked each time. An explanation of that threshold can be found on what does the 2 kWh threshold mean for industrial batteries.

Distinguish between the starter battery and the EV battery in the same vehicle

In hybrid and electric vehicles there are often two batteries: the traction battery that propels the vehicle, and a smaller lead-acid or lithium starter battery for the 12-volt system. This distinction is relevant for the application of the passport, because the mandatory digital product passport in the Regulation is linked to specific categories — with the EV battery as one of the categories for which the obligation is most clearly established. For a trading company that supplies vehicle components, this means that an invoice or technical specification ideally indicates which battery in the vehicle it is, so that there is no confusion between the two functions. Background information on what such a passport contains in terms of content can be found on what exactly is a battery passport.

Establish whether your own role in the value chain leads to obligations

Even if a starter battery does not fall under the passport obligation, other parts of the Battery Regulation — such as requirements for labelling, substances or collection — remain relevant, depending on the category in which the battery is placed. For an importer or manufacturer, it is practically relevant to establish what role you fulfil in the value chain (manufacturer, importer, distributor), because obligations are linked to that. A general checklist to determine whether the passport applies can be found on does the battery passport apply to my batteries.

Where things go wrong in practice

"It's in a car, so it's an EV battery." This is the most common assumption. The term "EV battery" in the Regulation refers to the battery that propels the vehicle, not to every battery that is in a vehicle. A starter battery in an ordinary internal combustion engine car is not an EV battery, even though it sits under the bonnet of a car.

Capacity not documented, threshold cannot be checked. Companies that trade starter batteries do not always have the kWh value of their range documented. Without this figure, it is not possible to establish whether a specific battery is above or below the 2 kWh threshold for industrial batteries, and the question remains unanswered until someone explicitly asks — for example a trading partner or supervisor.

Confusion between 12-volt battery and traction battery in hybrids. In hybrid vehicles, there is both a small starter battery and a larger traction battery. In correspondence and technical documentation, these two are sometimes not clearly distinguished from each other, which leads to confusion about which battery passport (if required at all) belongs to which battery.

Assumption that 'no passport requirement' means 'no obligation whatsoever'. Even if a starter battery falls outside the passport requirement, other provisions of the regulation — on substances, labelling or end of life — may still be relevant. Omitting the passport is sometimes incorrectly equated with 'the regulation does not apply'.

Old assumptions from the previous directive persist. Companies that have been working with battery regulations for a long time sometimes still reason from the classification of the old battery directive, whereas the current regulation has its own system of categories and definitions. The difference between the two regulations is explained at what is the difference between the battery regulation and the old battery directive.

What you can record

• An overview per product line of the battery type (lead-acid, lithium, other) and the function (starting, propulsion, powering on-board systems).
• The capacity in kWh of each starter battery that is placed on the market, so that comparison with the 2 kWh threshold for industrial batteries can be made directly.
• For vehicles with multiple batteries (hybrid, electric): a clear link in the technical documentation between the battery type and the associated function, so that starter battery and traction battery are not confused.
• The established role in the supply chain (manufacturer, importer, distributor) per product line, as a basis for determining obligations.
• Correspondence with suppliers or manufacturers confirming under which category of the regulation a specific type of starter battery falls according to them.
• A fixed procedure to re-assess new product lines (for example, when expanding to hybrid or EV components) against the definitions in Article 3 of the regulation, rather than relying on previous classifications.