How do I give each battery a unique identification?
Each battery receives a unique identification code
A unique identification per battery is one of the data items that will be included in the battery passport, and that code links the physical battery to the digital data recorded about it. Without that link, a QR code on a battery has little value: the code must refer to exactly one set of data, not to an entire product line or a collection of batteries that may differ from each other. The unique identification is therefore not merely a serial number for internal administration; it is the technical anchor that allows anyone scanning the QR code — a recycler, an inspector, a subsequent owner — to access the correct, up-to-date data for that specific battery.
Who this applies to, and who it does not
This matter applies to batteries for which a digital passport becomes mandatory: EV batteries, batteries for light means of transport (such as e-bikes and scooters) and industrial batteries above 2 kWh. For these categories, a unique identification is part of the data set that must be included in the passport. This explicitly does not involve replacing existing markings such as CE marking or type designation — these remain separate. The unique identification in the passport is supplementary data, specifically intended to enable the battery to be traced in the digital system. Batteries outside the scope of the passport obligation, such as small portable batteries or industrial batteries below 2 kWh, are not subject to this requirement, although a manufacturer may of course choose to assign an internal serial number to them as well.
From when this becomes mandatory
The obligation to provide a digital battery passport — and thus also a unique identification as part of the data set — will take effect from 18 February 2027. Until that date, there is no legal obligation to identify batteries in this way, but there is every reason to start earlier: a unique identification must be assigned consistently from the point of production or import, and it is difficult to retrofit this for batteries already in circulation. Those who now set up a numbering system that aligns with what will later be required will not need to rebuild that system.
How this works in practice
The first step is to choose a system that produces no duplicate numbers within your own organisation — not within a single model, and not between different models or batches. This can be a sequential serial number, a combination of batch code and sequential number, or another system, as long as each individual battery retains its own traceable number. The second step is to record that identification at the moment the battery is manufactured or imported, so that no batteries leave the factory without a number or with a number that has to be 'looked up' later. The third step is to include that identification as part of the data supplied for drawing up the passport, together with the other data from Annex XIII. The fourth step is to ensure that the identification remains physically traceable: the QR data carrier on the battery must point to the correct identification and thus to the correct passport, and this must remain accurate as long as the battery is in use — in practice, for the years that the passport is hosted. Those providing this as an importer or trader should ensure in advance that a fixed place is reserved in their own inventory system for this number, so that it is not filled in differently by chance or by different staff members.
Where this is laid down: Article 78 and Annex XIII
The obligation for unique identification follows from the combination of Article 78 of Regulation (EU) 2023/1542, which regulates the technical design and operation of the battery passport — including the way the QR data carrier must refer to the correct data — and Annex XIII of the same regulation, which sets out what data the passport must contain. The unique identification is one of the data elements included therein, alongside, among other things, technical and composition data of the battery.
Anyone who already imports or trades batteries that will later fall under the passport requirement can best start by setting up their own, consistent numbering per battery, and record it as a permanent part of the production or import administration. When the data for the passport is submitted, that identification is then immediately available and there is no need to subsequently determine which number belongs to which battery.
What this is based on
- Regulation (EU) 2023/1542, Article 78 (technical design and operation of the battery passport)
- Regulation (EU) 2023/1542, Annex XIII (data in the 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
An identification number that uniquely identifies the battery itself
Annex XIII of the Battery Regulation lists the unique identification code of the battery as part of the data that must appear in the battery passport. This is not the same as a model number or type designation: it is a code that distinguishes one individual battery from every other battery, even from the same model and the same production batch. For a company with 10 to 100 employees, this means in practice that a system must be in place that assigns a new, never-before-used number to each battery that comes off the production line (or is imported). A continuous serial number per production line is acceptable in principle, provided that no duplicate numbers are created between different lines, factories or suppliers.
Link the number to the rest of the passport
Article 78 describes that the battery passport must be accessible via a data carrier on the battery and that this refers to the correct, up-to-date data. The unique identification number is the link in this process: the number on the battery (or embedded in it) must correspond one-to-one with the passport displayed online. For a company, this means that there must be no separate administrative record in which numbers are assigned "approximately" or "per batch" — each number must be traceable to exactly one passport. Anyone linking this to an ERP or inventory systemensures that the identification number automatically runs with other product data, rather than being manually typed in.
Make the number readable and traceable via the data carrier
The unique number must not only exist in a database, but also be physically traceable to the battery. This is done via the QR code or similar data carrier that refers to the passport. Exactly how that code gets onto the battery and what technical requirements it must meet is described under how the QR code for the battery passport gets onto the battery. For companies working with barcodes or GS1 structures, it is useful to check whether the existing numbering system can be aligned with the way it is set up within GS1 Digital Link so that two parallel numbering systems do not develop side by side.
Distinguish between the battery number and other markings
A battery often carries multiple designations: a CE marking, a chemistry designation, a capacity designation and therefore also the unique identification number for the passport. These appear alongside each other but have a different function. Which labels and markings are precisely mandatory and how they differ from the passport number is explained under labelling and marking of batteries. For a company that assembles or imports batteries itself, it is practically relevant to make a clear distinction between these markings when setting up the production process, so that they do not overwrite or confuse each other.
Where things go wrong in practice
A first situation that often occurs: an importer purchases batteries from multiple manufacturers, each using their own internal serial numbering. Without correction, duplicate numbers then arise as soon as two manufacturers happen to have assigned the same number to a battery. The passport then refers to the wrong battery or to multiple batteries at the same time.
A second situation: the unique number is assigned during production, but is only entered into the system that manages the passports afterwards, by hand. If there is a mistake in typing — a digit transposed, a zero forgotten — the passport no longer corresponds to the correct battery.
A third situation arises with batteries that are repackaged or rebuilt, for example when individual cells are assembled into a new battery pack for a light electric vehicle. It is then not always clear whether the original cell number is retained, or whether the assembled pack receives an entirely new number. Without an agreement on this, digital product passports are created that refer to the wrong layer of the product.
A fourth situation: a battery is replaced under warranty after sale, and the replacement battery is accidentally assigned the same identification number as the original. Or a replacement battery does not receive its own digital product passport at all. The exact rules for this are described under a replacement battery and its own digital product passport.
A fifth situation occurs when a company bases its own numbering on a series that was once set up for internal inventory management, without taking into account the requirement that the number must be permanent and unique. When that internal series is later purged or reused — something that happens regularly in inventory systems — there is a risk that a number once assigned to a battery will be assigned to a different product years later.
What you can record
- A description of the numbering structure: how the unique identification number is constructed, which series is reserved for it, and how double assignment of numbers is prevented between production lines, facilities or suppliers.
- An overview of the point in time at which the number is assigned in the production or import process, and who is responsible for it.
- An agreement on how the identification number is entered into the system that manages the digital product passport, including a check for incorrect entries.
- A documented rule on what happens to the number during rebuilding, repackaging or assembly of cells into a new pack.
- A note on the handling of replacement batteries: does the replacement receive a new number, and how is the relationship with the original digital product passport documented.
- An overview of where and how these numbers are archived, also with regard to the question how long a battery digital product passport must remain available and where the data of the battery digital product passport is located online and who manages it.
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.