What exactly is a battery passport?

What you need to do concretely

What is expected of you

A battery passport is a digital file attached to one specific battery, containing data on composition, origin, performance and recycling information. Article 77 of Regulation (EU) 2023/1542 (Battery Regulation) describes that this passport is accessible via a QR code or comparable data carrier on the battery itself. Annex XIII to that regulation lists which data must be included: from chemical composition to information about the manufacturer and the product's lifespan. For a company with between 10 and 100 employees, this translates into a number of practical obligations.

Ensuring that the correct data are available

The data in Annex XIII do not come from nowhere. They must be collected from product information, test reports and documentation from suppliers. For an importer of e-bike batteries, this means that the data recorded by the manufacturer in the country of origin must actually be passed on and be in order before a passport can be drawn up. Anyone who assembles or modifies batteries themselves must be able to substantiate that data themselves.

Linking the passport to the battery before it is placed on the market

Article 77 describes that the passport exists before the battery is traded. This means that the process of collecting data, drawing up the passport and applying the QR code becomes part of the normal import chain, not something that is corrected afterwards. For companies that import batteries or vehicles with batteries on a large scale, this is an additional step between purchasing and sales that requires time and coordination with the supplier.

Keeping the passport accessible

The passport is not a one-time document; it must remain accessible to the user and to supervisory authorities for as long as the battery is in use. This requires hosting that does not depend on the continued existence of one webshop or importer, and a QR code that continues to point to working information even after years.

Knowing which battery falls under the obligation

Not every battery receives a passport. The question which batteries fall under the Battery Regulation is therefore the first question a company must answer for itself, before time is spent collecting data for a battery that may fall outside scope.

Where things go wrong in practice

Data are available, but not in the right form. A manufacturer supplies an extensive technical datasheet, but that document is not structured according to the layout that Annex XIII requires. Someone must make that translation, and that work is often underestimated until the passport actually has to be drawn up.

The battery is hidden in a larger product. In scooters, power tools or machines, the battery is sometimes not easily recognisable. If someone has not previously investigated does an e-bike or scooter battery need a battery passport, they run the risk that the question is only raised when the batch is already on its way.

Confusion about who is responsible for built-in batteries. When a battery is built into an end product, it is not always obvious who draws up the passport: the battery manufacturer, the assembler, or the party bringing the end product to the European market. This question is addressed on the page the battery is built into my product — who then makes the passport, and it is a question that companies often ask too late, namely only when the import flow is already running.

Assumption that smaller or cheaper batteries automatically fall outside the rules. For industrial batteries, the question what does the 2 kWh threshold mean for industrial batteries plays a role, and it is a threshold that does not always correspond to what is intuitively seen as "small" or "large".

Not taking into account the expiry date of the transitional period. Companies that are currently still supplying without a passport sometimes assume that this will continue for the time being. The question when does the battery passport become mandatory shows that this date is fixed and that preparation cannot wait until the last month.

What you can record

• An overview of which battery types the company places on the market, and for each type the conclusion whether it falls within the battery regulation.
• A list of the data from Annex XIII per battery type, together with who supplies this data (own production, manufacturer, importer) and which document it is already in.
• Agreements with suppliers on the timely and complete provision of technical and composition data, preferably laid down in the purchase contract or a separate data agreement.
• An internal process that describes at what point in the import chain the battery passport is requested or compiled, so that this is not carried out as a separate action afterwards.
• A fixed location for the QR code or data carrier per product line, so that it is consistently applied to all specimens of the same battery.
• Documentation on the hosting lifespan of the passport, so that it is demonstrable that the data remains accessible for the required period.

For companies that still need to determine whether their product category already falls within this, it is advisable first to check their own situation against the question does the battery passport apply to my batteries, before data and processes are set up for an obligation that may not apply.