Sector Guide

Battery Passport — EU Regulation 2023/1542

The Battery Passport is the first mandatory Digital Product Passport under EU law. Deadline: February 2027. Here is exactly what you need to provide, who must comply, and how to prepare.

Regulation (EU) 2023/1542 (the Battery Regulation) mandates a full digital product passport for industrial batteries ≥ 2 kWh, electric vehicle batteries, and light means of transport batteries — effective 18 February 2027.

Who must comply with the Battery Regulation?

Manufacturers of EV traction batteries, industrial batteries of 2 kWh or more, and light means of transport batteries such as e-bikes and e-scooters. Where the manufacturer is outside the EU, the importer carries the full Battery Passport obligation.

EV Battery Manufacturers
All manufacturers of lithium-ion or other EV traction batteries entering the EU market.
Industrial Battery Manufacturers
Batteries ≥ 2 kWh for stationary storage, industrial equipment, or grid applications.
LMT Battery Manufacturers
Light means of transport: e-bikes, e-scooters, e-cargo bikes with removable batteries.
EU Importers
If the manufacturer is outside the EU, the importer bears full Battery Passport obligations.

What data must a battery passport contain?

Six categories of data: product identification, chemical composition, performance and capacity, carbon footprint, circularity and end-of-life, and supply chain due diligence.

Product Identification
  • Battery model & SKU
  • GTIN / EAN code
  • Batch & serial number
  • Manufacturing date & location
  • Country of origin
Chemical Composition
  • Battery type (Li-ion, LFP, NiMH, etc.)
  • Cathode, anode & electrolyte materials
  • Critical raw materials: Li, Co, Ni, Mn, graphite (%wt)
  • Recycled content (% and origin)
  • Hazardous substances (REACH)
Performance & Capacity
  • Nominal capacity (Ah) & energy (Wh)
  • Nominal voltage & charge voltage
  • Cycle life (80% DoD)
  • Round-trip energy efficiency
  • Expected lifetime (years/cycles)
Carbon Footprint
  • Carbon footprint per kWh (kg CO₂e)
  • Carbon footprint performance class
  • Carbon footprint study verification
  • Lifecycle stage breakdown (cradle-to-gate)
  • GHG emission intensity declaration
Circularity & EOL
  • Removability & replaceability index
  • Recycled content declaration
  • End-of-life collection scheme
  • Extended producer responsibility info
  • Pre-consumer recycled content (%)
Supply Chain
  • Supplier name & address (Tier 1)
  • Due diligence policy (Art. 52)
  • Third-party verification report
  • Country of extraction of CRMs
  • Conflict minerals declaration

When does the battery passport become mandatory?

18 February 2027 for industrial batteries of 2 kWh or more, EV batteries and LMT batteries — together with the QR code carrier and the carbon footprint declaration. Recycled content targets follow from August 2028.

Aug 2023Regulation (EU) 2023/1542 entered into force
Feb 2027Battery Passport mandatory: industrial batteries ≥ 2 kWh, EV batteries, LMT batteries
Feb 2027QR code carrier mandatory on every battery unit
Feb 2027Carbon footprint declaration & performance class mandatory
Aug 2028Recycled content targets apply: Co 16%, Pb 85%, Li 6%, Ni 6%
2030Higher recycled content targets: Co 26%, Li 12%, Ni 15%
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