The Battery Passport: What Exactly is in the EU Battery Regulation?
There’s a lot of talk about the battery passport, about opportunities, obligations, CO₂ transparency, and digital product passports. But let’s be honest: very few people have actually read the EU Battery Regulation in detail. Yet it clearly spells out what will be required of manufacturers, importers, and users.
In this article, we take a direct look at the regulation itself, specifically Chapter IX and Articles 77 and 78.
Article 77 – The Battery Passport
Article 77 of the EU Battery Regulation lays the foundation for the digital battery passport and answers the most important question first: Which batteries does it apply to, and when?
Starting 18 February 2027, no large battery may be placed on the EU market or put into service without a digital battery passport. This applies to all new batteries brought to market from that date onward.
The regulation initially limits this obligation to three categories:
Light vehicle (LV) batteries - for example, batteries in e-bikes, e-scooters, or small delivery vehicles.
Industrial batteries with a capacity above 2 kWh - such as stationary energy storage systems, forklifts, telecom backup systems, or UPS units.
Electric vehicle batteries - traction batteries used in electric cars, buses, and commercial vehicles.
Information Included in the Battery Passport
An initial overview of the required content is provided in Annex XIII of the regulation. It defines three levels of data access, depending on who is allowed to see what:
Publicly accessible information - such as manufacturer, battery type, model designation, chemical composition, capacity, and CO₂ footprint. These data points are meant to create transparency and help users compare products.
Authority and compliance information - data only accessible to market surveillance authorities and notified bodies. This includes test reports and technical documentation relevant to safety and compliance checks.
Restricted-access information - available only to specific actors with a legitimate interest, such as recyclers, remanufacturers, or repair operators. These datasets cover details like dismantling instructions, safety precautions, material composition, and information on the condition of used batteries.
The European Commission will define by August 2026 which entities belong to this third group and to what extent they may download or reuse the data.
QR Code Label
Access to the battery passport is provided via a QR code printed directly on the battery. This QR code contains a link to the digital battery passport, which is hosted on a dedicated online platform. These platforms are not centrally managed by the EU, but operated by different providers, for example, open-dpp. In other words, the QR code does not point to a single European database, but to the specific platform where the passport for that battery is stored.
Through that link, users can access the relevant information, publicly or with restricted access, depending on their authorization level. Importantly, each individual battery receives its own digital passport, not just one per model or series. That means two batteries of the same type will each have a unique digital ID with their specific data, usage history, and potentially Second-Life information.
Responsible Economic Operator
Responsibility for the battery passport lies with the entity that places the battery on the EU market, the so-called “economic operator.” This could be the cell manufacturer, a pack assembler, an importer, or, in the case of repurposed or remanufactured batteries, the company who reintroduces them into the market. This economic operator must ensure that all information in the battery passport is accurate, complete, and kept up to date. They may delegate data collection and management to specialized service providers, for example, partners who structure and maintain the data (see also Article 40).
We’ll explore this topic in more depth in a separate blog post: who qualifies as an “economic operator,” what their specific duties are, and how companies can efficiently meet these requirements.
Article 78 – Technical Design and Operation of the Battery Passport
Article 78 sets out the technical framework for the battery passport. It must be interoperable, secure, openly accessible, and available long-term. Data must not be manipulated or used for unrelated purposes, and access must follow clearly defined authorization levels.
The detailed technical implementation, data formats, interfaces, and standards, is currently being developed within various standardization committees and will later be implemented by software providers and platforms in a legally compliant way, such as open-dpp. For battery manufacturers, this is actually a relief: they do not have to design or code the technical details themselves, but can rely on existing, compliant platforms that already meet the legal and interoperability requirements.
What’s Still Open?
Many details of the battery passport are not yet finalized. They will be defined in delegated and implementing acts that the European Commission will adopt over the coming years. Article 77 already specifies:
"The Commission is empowered to adopt delegated acts in accordance with Article 89 to amend Annex XIII as regards the information to be included in the battery passport in view of technical and scientific progress."
The upcoming implementing act related to Annex XIII will be one of the most critical components of the entire framework.
It will define in detail:
Which specific data must be included in the battery passport
How this information should be structured and formatted
Who can access which parts of the data – for example, manufacturers, market surveillance authorities, recyclers, or Second-Life operators.
This act will therefore determine the practical framework for how the battery passport functions and how data is exchanged securely between all relevant stakeholders.
A first idea of what this structure could look like can already be found in the DIN SPEC 99100. This specification outlines a common data model and technical architecture for digital battery and product passports. While it is not legally binding, it serves as a valuable early guideline for organizations that are already preparing to collect or share battery passport data.