From 18 February 2027, Article 77 of Regulation (EU) 2023/1542 requires a battery passport for each EV battery, each LMT battery and each industrial battery above 2 kWh placed on the EU market or put into service, subject to the regulation’s scope and exclusions. The passport combines category-specific information, identifiers, differentiated access and updating duties. These are enacted battery rules; general ESPR product measures follow a separate process.
What information goes into a battery passport?
Answer checked:
A battery passport combines information about the model with information about the individual battery, including information from its use. Annex XIII separates public model information, restricted technical information, compliance test reports and individual-battery information.
The fields depend on battery category or subcategory and on the operative date of the underlying requirement. Not every Annex XIII item is required for every battery on 18 February 2027, and not all information is public. Read Article 77(2) with the Annex and the provisions it references.
Map each applicable item to its access group, source, owner and update trigger. Commission data-point guidance supports preparation but is non-binding; its numbered entries are not a universal mandatory-field count. Keep the checklist’s separate review warnings visible.
Source: Battery Regulation — current consolidated text — Consolidation 13 August 2026; Articles 1, 3, 13, 39, 77–78 and Annex XIII. As checked 22 September 2026.
Source: European Commission — battery-passport preparation guidance — 21 August 2026 announcement and linked non-binding category/data-point guidance. As checked 22 September 2026.
Source: Battery Regulation corrigendum — 10 April 2026 — Annex XIII(1)(q) refers to Article 13(4) and (5). As checked 22 September 2026.
| Information group | Examples | Legal locator |
|---|---|---|
| Public model information | Identification, chemistry/materials, capacity, voltage, performance, durability, conformity and waste-management information | Annex XIII(1); category and timing conditions apply |
| Restricted model information | Detailed composition, replacement parts, dismantling instructions and safety measures | Annex XIII(2) with Article 77(2) |
| Restricted compliance evidence | Results of compliance test reports | Annex XIII(3) with Article 77(2) |
| Individual battery information | Performance changes, state of health, lifecycle status and use history | Annex XIII(4) with Article 77(2) |
Do EV batteries need a DPP?
Answer checked:
Yes. From 18 February 2027, each electric vehicle battery placed on the EU market or put into service must have a battery passport, subject to the Regulation’s scope and exclusions. The industrial-battery threshold of greater than 2 kWh does not apply to the EV category.
Use Article 3(1)(14): the EV category covers traction batteries for hybrid or electric category-L vehicles where the battery weighs more than 25 kg, and traction batteries for hybrid or electric vehicles in categories M, N or O. A vehicle’s separate starting, lighting or ignition battery is not automatically an EV battery.
Confirm the category, first relevant EU-market or service date and any Article 1 exclusion. Then plan the individual identifier, QR-linked passport, category-specific information and controlled updates. A postponement of battery due-diligence rules does not postpone Article 77.
Source: Battery Regulation — current consolidated text — Consolidation 13 August 2026; Articles 1, 3, 13, 39, 77–78 and Annex XIII. As checked 22 September 2026.
Do industrial batteries need a battery passport?
Answer checked:
Yes, if their capacity is greater than 2 kWh and they are placed on the EU market or put into service from 18 February 2027, subject to scope and exclusions. Exactly 2 kWh does not meet this passport threshold, although other battery requirements can still apply.
Classify the battery under Article 3(1)(13), not a marketing label. A stationary battery energy storage system, as defined in Article 3(1)(15), is an industrial battery with internal storage designed to store and deliver energy to the grid or end users, regardless of where or by whom it is used. Article 77(1) does not restrict this passport requirement to rechargeable industrial batteries or exclude external-storage batteries; do not import narrower conditions from a different provision.
Record the category, rated capacity and relevant market/service date. If the battery is legally an EV or LMT battery, use that category’s rule instead: neither has the industrial passport capacity threshold. Check Article 1 exclusions and map the applicable Annex XIII information.
Source: Battery Regulation — current consolidated text — Consolidation 13 August 2026; Articles 1, 3, 13, 39, 77–78 and Annex XIII. As checked 22 September 2026.
Scope: classify the battery before using a field list
Article 77(1) covers each electric-vehicle battery, each LMT battery and each industrial battery with capacity greater than 2 kWh. The requirement is triggered by placing the covered battery on the market or putting it into service from the application date.
Use the Article 3 definitions rather than a marketing label. In particular, an LMT battery is a sealed traction battery weighing 25 kg or less for the specified wheeled vehicles and is not an EV battery; the EV definition distinguishes category L traction batteries weighing more than 25 kg and categories M, N and O. Industrial classification includes its specified industrial purpose and other routes in Article 3(1)(13).
- Use the existing product applicability checker if facts are uncertain
- Return to the Battery Passport overview
| Battery class | Article 77 capacity condition | Preparation boundary |
|---|---|---|
| EV — Article 3(1)(14) | No >2 kWh threshold | Confirm the legal vehicle/battery definition and Article 1 scope. |
| LMT — Article 3(1)(11) | No >2 kWh threshold | Do not substitute the industrial capacity test. |
| Industrial — Article 3(1)(13) | Greater than 2 kWh | Exactly 2 kWh is outside this passport capacity condition; other battery obligations can still apply. |
Choose your next step
If scope is uncertain, start with the shared applicability checker. If you already have a reviewed battery scope, use the Annex XIII preparation checklist and its source conditions. The reference is fully visible in the page; no email or account is required.
Timing: the passport date and field schedules differ
18 February 2027 is an enacted application date in Article 77(1), not an indicative Commission work-plan milestone. It concerns the relevant batteries placed on the market or put into service.
Article 77(2) qualifies the information by battery category or subcategory. Annex XIII also references provisions with their own scope, conditions and application dates. The non-binding guidance published by the Commission in August 2026 identifies staged treatment for, among other things, carbon-footprint information, due-diligence reporting and recycled-content information. These conditions are recorded beside the relevant reference items.
The Commission programme currently lists Q4 2026 for battery access-rights work. That planning entry does not change the enacted passport date and is not evidence that the access-rights act has been adopted.
Identification, QR code and data carrier
Article 13(6)(a) links the QR code for passport batteries to the battery passport. Article 77(3) requires a unique identifier attributed by the economic operator placing the battery on the market. It names ISO/IEC 15459 parts 1:2014, 2:2015, 3:2014, 4:2014, 5:2014 and 6:2014, or equivalent standards. This is not a rule that only one commercial identifier supplier may be used.
Annex VI Part C requires high contrast and readability by a commonly available QR-code reader. Article 13(7) requires visible, legible and indelible marking on the battery; where its nature or size prevents or does not warrant that, the marking is on the packaging and accompanying documents.
Article 77(10), read with its amendment and corrigendum, refers to unique-identifier upload to the registry under ESPR Article 13(1). Passport content storage and rights-controlled access remain separate requirements. Do not replace the battery-specific provisions with a generic registry or standards milestone.
Passport information: model, individual battery and use
Answer checked:
Article 77(2) requires model information and information specific to the individual battery, including information resulting from its use, as set out in Annex XIII and insofar as it applies to the category or subcategory.
Read the reference as legal information items and explicitly labelled preparation records. It is not a universal mandatory-field count. Cross-references, duplicated information, category conditions and developing implementation details must be resolved before an operational dataset is configured.
The current consolidated battery text is dated 13 August 2026. The 10 April 2026 corrigendum corrects Annex XIII(1)(q) to refer to Article 13(4) and (5). The preparation checklist below was checked against the 13 August 2026 consolidation on 9 October 2026. Its conditional fields and access distinctions remain explicit.
Source: Battery Regulation — current consolidated text — Consolidation 13 August 2026; Articles 1, 3, 13, 39, 77–78 and Annex XIII. As checked 22 September 2026.
Source: Battery Regulation corrigendum — 10 April 2026 — Annex XIII(1)(q) refers to Article 13(4) and (5). As checked 22 September 2026.
Access: public does not mean unrestricted
Answer checked:
Annex XIII separates public model information from restricted model information, conformity test reports and individual-battery information. Article 77(2) and Article 78 control access according to the specified roles and rights.
Article 77(9) set 18 August 2026 for the Commission implementing act on legitimate-interest access. The Commission battery FAQ checked on 9 October 2026 still describes that act as being developed, with a draft expected in October or November 2026. The programme’s Q4 2026 entry remains indicative. A statutory adoption deadline or draft timetable is not evidence of adoption. Do not disclose restricted information or treat unresolved permissions as settled.
Source: Battery Regulation — current consolidated text — Consolidation 13 August 2026; Articles 1, 3, 13, 39, 77–78 and Annex XIII. As checked 22 September 2026.
Source: European Commission — DPP programme timeline — Indicative Q4 2026 battery access-rights work; a timetable is not proof of adoption. As checked 22 September 2026.
| Information group | Legal access reference | What remains to check |
|---|---|---|
| Annex XIII point 1 | Publicly accessible model information | The individual item’s category and timing conditions still apply. |
| Annex XIII point 2 | Legitimate-interest persons and the Commission; Article 77(2)(b) also refers to notified bodies and market-surveillance authorities | Read the Annex heading with Article 77(2). Legitimate-interest entitlements still require the current Article 77(9) review. |
| Annex XIII point 3 | Notified bodies, market-surveillance authorities and the Commission | Test reports are not a general public-download class. |
| Annex XIII point 4 | Persons with a legitimate interest | Article 77(2)(c) and Annex XIII point 4 apply; detailed entitlements remain qualified. Separate Article 14 BMS access is not general passport access. |
Responsibility, maintenance and lifecycle changes
Under Article 77(4), the economic operator placing the battery on the market ensures the information is accurate, complete and up to date. Written authorisation may allow another operator to act on its behalf. Responsibility and supplier support are different concepts.
Article 77(7) transfers responsibility after preparation for reuse, preparation for repurposing, repurposing or remanufacturing to the operator placing the resulting battery on the market or putting it into service. It requires a new passport linked to the original passport or passports. When the battery becomes waste, the specified producer, producer responsibility organisation or selected waste-management operator assumes the stated responsibilities.
Article 77(8) provides that the passport ceases to exist after recycling. Do not promise an indefinitely active passport after that point. Preserve the distinction between a passport and any separate record-retention obligations.
Technical access, integrity and continuity
Article 77(5) requires open standards and interoperable formats and networks, without vendor lock-in, with machine-readable, structured and searchable information. Article 78 adds technical, semantic and organisational interoperability; free access according to rights; controlled storage and updates; authentication, reliability, integrity, security and privacy.
Article 78(e) requires continued availability after the responsible operator ceases to exist or ceases activity in the Union. Continuity planning, provider-exit tests and recovery evidence are recommended ways to prepare for that duty; the provision does not prescribe a particular backup architecture.
An authorised processor’s permitted use of the data is bounded by Article 78(d). A passport provider contract should be reviewed against that restriction and the operator’s ongoing responsibilities. No blockchain requirement is asserted here.
Exclusions and transition questions
Article 1(5) excludes batteries incorporated into, or specifically designed for, the stated equipment connected with essential security interests and specified military equipment, and equipment designed to be sent into space. Its military wording does not extend the exclusion to products that are not intended for specifically military purposes.
Article 1(6), as corrected on 17 April 2024, excludes Chapters III and IX for batteries incorporated into, or specifically designed for, equipment designed specifically for the safety of nuclear installations. Chapter IX contains the battery passport provisions. A general connection with a nuclear facility is not enough to apply that wording.
Second-life operations, waste status, category changes and market-placement dates require their own fact-based review. Selecting Not applicable in the preparation checklist does not determine or override any legal exclusion.
Preparation: distinguish a value from its evidence
The following five-part record is a recommended preparation model, not five additional statutory passport fields. Possessing a data value is different from being able to substantiate it.
What will be reported?
Record the unit, battery/model scope, relevant date and applicable condition.
Where did it come from?
Identify the controlled system, supplier document, test or calculation.
What substantiates it?
Keep the versioned document, method, result or provenance needed to review the value.
Who maintains it?
Name an internal responsible function. Likely ERP, PLM, supplier, quality or sustainability sources below are suggestions, not law.
When was it checked?
Record verification and the change or review trigger. These choices are not collected by this public checklist.
Annex XIII data and evidence reference
A battery passport contains the model information and individual-battery information specified in Annex XIII, subject to the relevant conditions. Different information is available to the public, authorities and persons with a legitimate interest. This reference separates the legal information items from suggested sources, owners and supporting evidence; it does not turn every item into an unconditional public field.
Read each information item with its legal source, condition and access class. The source-system, owner and evidence suggestions are recommended preparation; they are not additional passport fields required by law. A data value and the evidence that substantiates it are different records.
Dated source reference. Confirm the conditions and current source before applying an information item to a battery. The checklist does not establish applicability, conformity or legal compliance.
Open source and implementation questions
- The Commission batteries FAQ checked on 17 October 2026 describes the Article 77(9) access-rights act as being developed, with a draft expected in October or November 2026; the portal indicates Q4 2026. The statutory adoption deadline was 18 August 2026. This is a dated source observation, not proof that no unindexed document exists. Preserve Annex XIII access classes; do not settle eligible persons or granular rights from planning material.
- Guidance version 2.0 points 17-18 says carbon-footprint declaration/label information is not to be displayed in February 2027 pending implementing format. Article 7 has category-specific later-of triggers. Recheck adopted acts and actual triggers before asserting a due date for any battery category.
- Guidance point 44 refers to proposed Annex XIII 1(t) instructions and says application is on hold pending Omnibus adoption. Current enacted Annex XIII point 1 ends at (s). COM(2025)504 Annex V(3) proposes (t) for stationary battery energy storage systems only. No adopted amendment adding (t) was identified; it is excluded from the enacted field list. Existing instructions/safety duties elsewhere in the Regulation still need to be met.
- The August 2026 guidance says it does not extend legal rights or obligations, does not add requirements and is not an authoritative interpretation or the Commission official position. Its numbering includes overlapping, conditional, later-applying and proposed items. Do not describe its 71 rows as 71 mandatory fields.
- Some Annex XIII labels do not specify complete units, definitions, formats, sampling or measurement methods. Record a value, source, evidence, owner and verification date; preserve uncertainty rather than inventing a legal format. Organisational owner/source/evidence mappings in this profile are recommended preparation, not statutory assignments.
- The current EUR-Lex consolidation checked on 17 October 2026 is dated 13 August 2026 and includes Regulation (EU) 2026/1738, which replaced Annex I. The reviewed Article 77, Article 78 and Annex XIII provisions retain their passport requirements. This profile is not a substance-restriction compliance engine.
Preparation status and evidence gaps
- Available
- 0
- Missing
- 0
- Supplier needed
- 0
- Needs review
- 0
- Condition marked not applicable
- 0
- Not reviewed
- 0
These counts describe your preparation choices. They do not validate the data or evidence, settle legal scope, or establish compliance. Conditional items still require a substantiated applicability decision.
The readiness assessment covers wider organisational preparation, including ownership, suppliers, traceability and systems, beyond this battery information checklist.
Assess your wider DPP readinessRecord your battery data and evidence review
In a DPPLogic workspace, record product facts with their sources, link evidence references and keep human review decisions together. The Free plan covers up to 5 products. Your choices and results on this page are not transferred; start the product record in the workspace.
Primary and authoritative sources
Source links are provided for verification. Scope, consolidated versions and later measures should be checked again before implementation or reliance.
Regulatory disclaimer. This content provides general diagnostic and preparation information. It is not legal advice, certification or regulatory approval. Requirements may differ by product category, jurisdiction, market and supply-chain role and may change over time.