When does the battery passport become mandatory?

What you need to do concretely

What is expected of you

The date of 18 February 2027 comes from Article 96 of Regulation (EU) 2023/1542 (Battery Regulation), which sets out when the obligation under Article 77 concerning the battery passport becomes applicable. Until that date, there is time to prepare your organisation; from that date onwards, the obligation applies to batteries that fall within the scope of the Regulation. What this means in practice breaks down into a few recognisable points.

Know whether your own batteries fall under the obligation

Not every battery receives a passport. The Regulation works with categories — EV batteries, LMT batteries (for light means of transport), industrial batteries above 2 kWh, and a number of others. For a company of 10 to 100 employees that imports, trades or incorporates batteries, the first step is therefore not "how do we make a passport", but "does this product fall under it at all". That is precisely where many companies get stuck, and it is worth finding out early via Does the battery passport apply to my batteries?. The question of which product categories are precisely designated is also described at Which batteries fall under the Battery Regulation?.

Know who is responsible in the chain

The obligation does not automatically rest with the party selling the end product. In an e-bike or scooter, the battery is often built in, and it is not self-evident who compiles the passport: the cell manufacturer, the battery pack builder, the importer of the bicycle, or another link in the chain. For companies that incorporate batteries into their own product, this is one of the first questions that must be answered, and it is covered in more detail at The battery is built into my product — who creates the passport then?.

Collect the data in time

A passport consists of data coming from various points in the chain: technical specifications, origin of materials, performance, and data on repair and recycling. For a company of this size, this often means that agreements must be made with suppliers well before the deadline comes into view — not because the date itself is approaching fast, but because gathering data from external parties usually takes longer than is estimated internally.

Be ready with the QR data carrier

The passport must be accessible via a QR code or comparable data carrier on or with the product. That is a physical and logistical matter in addition to the substantive one: where does the code go on the product, how does it relate to existing labels, and how is the link with the digital passport maintained during the time the product is in use.

Where things go wrong in practice

The date is confused with "still far away". Because 18 February 2027 lies in the future, preparation is sometimes postponed until that year itself. However, gathering data from suppliers and setting up a process takes time that does not align linearly with the remaining calendar.

It is assumed that the obligation applies only to large manufacturers. For smaller importers and traders of e-bikes, scooters or batteries, the Regulation appears at first reading to be a matter for industry. The question of whether an own product falls under one of the categories is therefore posed too late.

The built-in battery is overlooked. In products in which a battery is incorporated — an e-bike, a machine, a device — the battery is sometimes treated as a minor matter, whereas it may carry its own passport obligation, separate from the passport or conformity of the main product.

There is waiting for "more clarity" that does not align with one's own planning. Implementing acts and further technical standards are still to be published. Waiting until everything is definitive means for some companies that preparation only starts at a point when the time to gather data has already become tight.

The boundary between battery categories is not drawn sharply. Especially in industrial applications, the 2 kWh threshold is sometimes checked too late, causing a product that falls just above or below that limit to be incorrectly assessed in terms of obligation.

What you can record

• An overview of your own product categories and, for each category, the outcome of the assessment whether the battery passport applies.
• A list of suppliers per product, indicating which party supplies which data (cell specifications, origin of raw materials, test results, repair and disassembly information).
• Agreements with suppliers on the form and timing of data submission, preferably documented in writing so that this does not remain merely a verbal arrangement between individuals.
• An internal responsible person or department that oversees the passport process, including a timeline that does not begin only at the deadline itself.
• Documentation on the placement of the QR data carrier on the product and its linking to the digital passport.
• A file in which changes to the regulations are recorded, so that in the event of later amendments it is clear which version of the regulation was used as the starting point.

For companies that are uncertain whether their product category is relevant or not, it is advisable to first assess your own situation against the definitions — for example via the pages on What is a light means of transport battery (LMT battery)? or on the question Does the battery in an e-bike or scooter need a battery passport? — before investing time in setting up an entire data collection process.