Does the battery passport also apply to second-hand or refurbished batteries?

Second-hand and refurbished batteries are also covered

Yes, a second-hand or refurbished battery may also require a digital product passport — not because it is old, but because it is placed on the market or put into service again at some point. The Regulation does not look at the age of a battery, but at the moment when that battery is (again) made available to a user within one of the categories for which the passport applies: EV batteries, batteries for light electric vehicles and industrial batteries above 2 kWh. A battery that, after refurbishment or repurposing, is sold again in that capacity, essentially goes through the same process as a new battery. Article 73 of Regulation (EU) 2023/1542 describes the conditions under which a battery prepared for reuse or repurposing is placed on the market again as a product. Article 45 identifies who acts as a market operator in that process — and thus which party bears the associated obligations.

Which situations this applies to, and which it does not

The distinction that matters here is not 'new versus second-hand', but 'placed on the market again versus remaining unchanged in the same application'. An EV battery that, after being rejected for vehicle use, is repurposed for stationary storage, changes application and thus effectively comes onto the market again — that is precisely the scenario described by Article 73. The same applies to a refurbished industrial battery above 2 kWh that is restored by a dealer and resold as a standalone product. In those cases, a new moment of 'placing on the market' arises, and with it the obligations that are attached to that moment, including the passport from the date it becomes mandatory.

It is different for a battery that simply remains with the product it was already in: a used e-bike that changes hands without any changes to the battery is generally not a new placing on the market of the battery as a standalone product. Private sales between consumers also fall outside the picture of market operator as described by Article 45 — the obligations are directed at businesses that trade in batteries, not at individuals who resell a second-hand product. Repair without change of application (replacing a cell, restoring a pack to function for the same purpose) is a different scenario from repurposing to a new application, and is also dealt with separately in the Regulation.

When this applies

For second-hand and refurbished batteries, the same date applies as for new ones: 18 February 2027. From that date, the passport requirement applies to batteries in the stated categories that are placed on the market or put into service — and this also applies to a refurbished or repurposed battery that is sold for the first time in that new capacity after that date. For batteries that were already placed on the market before that date and that do not appear on the market again as a product, nothing changes in the meantime regarding any passport obligation. Until 18 February 2027, the obligation does not yet exist; what does already exist are the conditions set out in Article 73 under which preparation for reuse or repurposing takes place, and the identification in Article 45 of who acts as a market operator in doing so.

What this concretely means for those involved

For a company that refurbishes, repurposes, or trades batteries as second-hand products, the first question is whether the battery falls within one of the three passport categories — EV, light electric vehicle, or industrial above 2 kWh. If so, the next question is whether the activity constitutes repurposing to a different application than the battery was originally intended for, or sale as a standalone product after refurbishment. In that case, there is a new moment of placing on the market, with the role of economic operator that comes with it according to Article 45. From 18 February 2027, this includes the passport obligation.

In practical terms, this means that a refurbishment or repurposing company would be wise to map out the process now: which data on the origin, composition and refurbishment history of the battery are available or must be collected, and which party in the chain will act as an economic operator in future. This is the same kind of information needed to compile a passport — origin, materials, performance data — and for a refurbished battery, it is often more difficult to obtain in full than for a new one, because the original manufacturer is not always involved in the refurbishment.

Where this is stated: Articles 73, 45 and 77

The basis for the passport itself is set out in Article 77 of Regulation (EU) 2023/1542. The conditions under which a battery, after preparation for re-use or repurposing, is considered a product again, are set out in Article 73. Who is designated as an economic operator in that process — and therefore which obligations are attached to that role — is set out in Article 45. For the precise wording and the exceptions that the regulation makes in this regard, the official text via the link at the bottom of this article is the appropriate source.

Anyone who is already refurbishing, repurposing or trading batteries as second-hand products can compare their own process against Articles 73 and 45 now to see at which step a new placing on the market occurs, and which data will be needed once the passport obligation comes into force.

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

A second-hand or refurbished battery does not disappear from the scope of the battery regulation once it is sold a second time. The question is each time: does this battery fall under one of the categories for which the digital product passport is mandatory — EV batteries, batteries for light means of transport, or industrial batteries above 2 kWh? If so, that obligation remains in place, even after refurbishment, repurposing or resale. Does the battery passport apply to my batteries? is therefore the first thing that must be clear before the rest of this section becomes relevant.

Determining who acts as a market operator

Article 45 of the battery regulation describes obligations for market operators who trade batteries that have been prepared for reuse, for repurposing, or that have been refurbished. Whoever purchases a battery, tests it, adapts it and places it back on the market thereby acts as a market operator for that battery — regardless of whether the same party has ever produced the battery. For a company of 10 to 100 employees that, for example, refurbishes and resells used e-bike batteries, this means that its own position in the supply chain must be redetermined: not as a distributor of an existing product, but as a party that effectively places the battery back on the market.

Reassessing whether the passport already exists or needs to be created anew

When a battery has been prepared for reuse in the same application, an existing passport may still be associated with that battery. In case of repurposing — the battery takes on a different function than it was originally made for, for example an EV battery that serves as stationary storage — the circumstances to which the passport relates change. Article 73 describes the conditions around that preparation for reuse or repurposing. In practical terms, this means that a company repurposing batteries must check whether the data in the existing passport still match the new application, or whether a new or amended dataset is required.

Recording origin and composition anew after refurbishment

Refurbishment often changes something in the battery itself: cells are replaced, a new enclosure is used, or the management system is adapted. These modifications affect exactly the data that should appear in a battery passport — composition, capacity, origin of components. For a refurbished battery, this means that the documentation from before refurbishment cannot be used as such; what is in the battery after refurbishment must match what the passport claims.

Determining who is responsible for maintaining the passport

With a second-hand battery that changes ownership without physical modification, the question is different from a refurbished battery. Who acts as the party that keeps the passport up to date once the battery takes on a new role? This is a question that must be answered concretely for each company working with second-life batteries — not in general terms, but for each flow of batteries that the company receives and releases.

Where things go wrong in practice

A few situations that often come up in practice when dealing in second-hand or refurbished batteries:

The assumption that "second-hand" is equivalent to "outside the rules". A used battery that is traded again falls within the same category as when it was new. The regulation does not make a general exception for this.

Repurposing without reviewing the data. An EV battery that continues as stationary storage takes on a different usage context, but the passport data are sometimes simply carried over without checking whether they still match the new application.

Refurbishment where composition changes, but documentation does not. Replacing cells or adapting components changes what is actually in the battery. If the passport data do not reflect this, a discrepancy arises between what is written down and what is in the battery.

Lack of clarity about who the market operator is. In collaborations between an importer, a revision enterprise and a sales outlet, it is not always established who bears which obligation from Article 45. This creates a gap in which nobody feels responsible for keeping the product passport up to date.

Stock with an unknown product passport status. Batteries that have been in stock for a long time — purchased before revision, or sourced from collection — sometimes no longer have a clear product passport status. What to do with them depends on the question what do I do with batteries already in stock, and that is a different question from the one for new batteries.

What you can record

An overview per battery stream: which batteries are prepared for re-use, which for repurposing, and which are revised — including which market actors appear in that chain according to Article 45.
A fixed procedure for checking whether an existing battery product passport still applies to the application, before a battery with a second life is resold.
Documentation of what actually changes to the battery during revision — cells, housing, management system — so that this can be traced back to the data that should be in the product passport.
Agreements between the parties in the chain (purchaser, revision enterprise, sales outlet) on who creates the product passport, who keeps it up to date, and who manages the QR data carrier.
A note on batteries that change application (repurposing), so that it is clear which data have been reviewed and which have been taken from the original registration.

For companies structuring this for the first time, what do I need to arrange if I give a battery a second life can help to work through these points in the right order, and what does a supervisory authority ask during an inspection of batteries provides a picture of what is asked in practice when a battery has had a second life.

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.