Does the battery passport apply to a home battery or stationary storage?

What you need to do concretely

What is expected of you

A home battery or a stationary energy storage system does not automatically fall into the same category as an EV battery or an LMT battery. The battery regulation works with different categories, and which category applies determines which obligations are associated with it — including the question of whether a digital battery passport is required. For precise classification it is useful to look at which batteries fall under the Battery Regulation, because a home battery can be classified differently depending on its design and application than might appear at first glance.

Determining which category the battery falls under

Article 3 of Regulation (EU) 2023/1542 (battery regulation) provides the definitions by which categories such as portable battery, LMT battery, electric vehicle battery, industrial battery and starter battery are distinguished from one another. A home battery that is constructed from cells and intended for stationary energy storage typically falls under the regime for industrial batteries. For a company with 10 to 100 employees that imports, assembles or trades in such systems, this means: first determine which category the product falls under according to Article 3, and only then consider which obligations apply to it. This is not a formality — the consequences for passport, documentation and safety requirements differ by category.

Checking whether the 2 kWh threshold applies

For industrial batteries, a power threshold applies. Batteries above 2 kWh fall under a heavier regime than smaller industrial batteries. For home batteries this threshold is often relevant, because many stationary storage systems for dwellings exceed this threshold. What this threshold precisely means for the obligations that follow is set out on the page about what the 2 kWh threshold means for industrial batteries. For a company that supplies multiple models or power classes, it is practical to test this threshold per product line, rather than making one assumption for the entire product range.

Comply with safety requirements for stationary storage

Article 12 of Regulation (EU) 2023/1542 (batteries regulation) sets out requirements for the safety of stationary battery systems for energy storage. That article does not only affect the question of whether a passport is required, but also how the product is technically and documentarily substantiated. For an importer or assembler of home batteries, this means that safety documentation becomes an integral part of assembling the product, in addition to the data that may end up in a passport. This requirement is independent of the question of whether the specific system is already subject to the passport requirement — the safety requirement in Article 12 applies to stationary storage systems as such.

Determine whether and when the passport becomes mandatory

For batteries that fall under the passport regime, a fixed entry date applies. Which date applies to which category is explained on the page on when the battery passport becomes mandatory. For a company that places household batteries on the market, it is important to link this date to its own product category, rather than assuming the date that has become known for another category — such as LMT batteries. Confusion about this often arises because different categories are mentioned together in reporting.

Where things go wrong in practice

A common first situation: a company assumes that a household battery automatically qualifies as a 'portable battery' because the device is relatively compact and is installed in a residential building. However, the definitions in Article 3 do not look at format or location, but at construction and application — and in the case of stationary storage this regularly leads to a different classification than expected.

A second scenario: an importer of stationary batteries assumes that the 2 kWh threshold is only relevant for commercial industrial applications, such as machinery manufacturing, and not for consumer products. That assumption does not hold without qualification — the threshold is linked to the capacity of the battery, not to the environment in which it is used.

A third scenario: a company focuses entirely on the digital product passport and the associated data, but pays no attention to the safety requirements in Article 12. For stationary storage systems, these requirements are separate from the digital product passport obligation and apply independently of it.

A fourth scenario: an assembler of stationary battery systems installs cells from different suppliers in one system, without having previously established who will supply which data. If it later becomes apparent that the system is subject to the digital product passport requirement, the basic information needed to compile the digital product passport is missing, and must subsequently be obtained from the cell supplier.

A fifth scenario: a company confuses the rules for stationary batteries with those for the battery of an e-bike or scooter, because both are "used in-house". These categories are not comparable with each other — different definitions apply to light electric vehicles, which are explained on the page on what a battery for light means of transport (LMT battery) is.

What you can record

• A written substantiation of the product category under which the stationary battery falls, with reference to the definitions in Article 3 of Regulation (EU) 2023/1542 (the Battery Regulation).
• The capacity (in kWh) of each model or product line, so that for each model it is clear whether the 2 kWh threshold applies.
• Documentation on the safety requirements in Article 12, kept separately from the digital product passport data, so that both files are independently verifiable.
• Agreements with cell suppliers and sub-suppliers on which technical data are supplied, and at what point in the assembly process.
• An overview of the relevant date of entry into force for the company's own product category, so that internal planning does not proceed from a date that applies to a different category.
• An internal framework establishing who within the company is responsible for monitoring changes in the classification, should a product line change in terms of capacity or structure.