The date that matters: 18 February 2027
From 18 February 2027, a digital battery passport must be available for batteries falling under the Battery Regulation, with a QR code providing access to that data. This is laid down in Regulation (EU) 2023/1542, Article 77. For companies that import, sell or integrate e-bikes, scooters, or industrial batteries above 2 kWh, this means that from that date onwards an information obligation comes into effect that does not currently exist.
A question that often arises is whether this applies only to batteries that are new to the market after that date, or also to what is already on the shelves, in the warehouse or with the customer. This distinction is precisely where companies are running into difficulties now, and the answer depends on the moment when a battery is first made available in the EU, not on the moment when you sell it to the end user.
What the Regulation means by 'placing on the market'
The Regulation ties the obligation to the moment when a battery is first placed on the market in the European Union. For batteries that are first offered after 18 February 2027, the passport requirement applies. For batteries that have already been placed on the market earlier, the situation is different, and that is precisely the point where the text of the Regulation itself must be consulted to see which moment is decisive for your situation. We deliberately do not prescribe here when that applies to your inventory; that is a question that differs from situation to situation and is best put to a lawyer or the competent supervisory authority.
What can be said is: it is not about the date on which you sell a battery to a customer, but about the moment when that battery was first made available on the European market. An inventory that has been with you for longer is therefore a different matter from a new purchase order that you now place with a manufacturer outside the EU.
For whom this becomes relevant this year
In practice, the change affects three groups of companies in different ways. Importers who are now purchasing new models for delivery after the date must agree with their supplier who supplies the data for the passport. Battery traders who resell existing inventory face the question of whether that inventory falls under the old or the new situation. And machinery manufacturers who integrate batteries into their own equipment must check whether their end product is also subject to the obligation as a result, regardless of the battery inside it.
In the knowledge base where this has been worked out for each situation there is an overview of how this question is answered for each type of company, with references to the official text. This is a good starting point to see which part of the Regulation appears to apply to your situation, before you put the question to a lawyer.
What is practically involved
If a battery falls under the new obligation, there must be a passport that remains accessible throughout the life of the battery, with data on composition, performance and origin, among other things. Who must supply that passport and who must host it is one of the questions that companies are now discussing with their supplier or platform. Batpas.eu compiles the passport from the data supplied by the manufacturer or importer, hosts it for the period laid down by law, and supplies the QR data carrier that refers to that passport.
To see whether your type of battery and your role in the chain fit in here, you can see in a few questions roughly where you stand. This gives a first direction, not a definitive assessment of your situation.
What is not yet certain
Not all implementation details of the regulation are fully developed at this time. Where further technical standards or implementing provisions are expected, this is something to monitor through official EU sources or through the competent authority, and not something that can be stated with certainty now. Anyone in doubt about whether a specific situation falls before or after 18 February 2027 is well advised to enquire with a legal professional or the competent authority, and not to rely on a general assessment.
In the overview with frequently asked questions are the questions that come up most often around this date, each with a brief, factual explanation. And if you want to know where the information on batpas.eu comes from and how it is maintained, read that on the page explaining how we work.
Getting a first picture yourself
Whether 18 February 2027 represents a turning point for your company or not depends on what you sell, to whom, and since when. The free quick-scan provides a first, non-binding indication of this in a few minutes, including the reference in the official text, so that you can verify yourself what that indication is based on.