What is a Battery Passport, and do you need one?
From 18 February 2027, EU Regulation (EU) 2023/1542 Article 77 requires every battery in three categories sold or placed in service in the EU to carry a Digital Battery Passport. This page explains what that means in plain language, with a real example you can scan.
Once the deadline passes, batteries in scope cannot legally be placed on the EU market without a passport. Customs holds, recalls and fines all become real risks. Now is the moment to figure out whether your products are in scope.
What is it, exactly?
A Digital Battery Passport is not a PDF. It is a public web URL that resolves to a structured data document (JSON-LD format) describing one specific physical battery. The URL is encoded in a QR code, and that QR code is printed on the battery itself or on its packaging.
When a customs officer, repair technician, recycler or curious consumer scans the code, they land on a viewer page (like the example below) showing chemistry, capacity, manufacturing data, recycled content, expected lifecycle, supply-chain due-diligence pointers and more.
See a real example
This is what a Battery Passport looks like in production — exact same layout your customers' end users will see when they scan a QR code. Scroll the page, click "View raw JSON-LD" at the bottom to see the structured data.
View live demo passport →Who needs one?
Three battery categories are in scope from 18 February 2027:
Light Means of Transport — e-bikes, e-scooters, e-mopeds, electric kick-bikes. The biggest category by unit volume. Importers of e-mobility products feel this first.
Forklift batteries, AGV batteries, telecom backup, behind-the-meter and grid storage batteries above 2 kWh capacity. Excludes small UPS units below 2 kWh.
Electric vehicle traction batteries — passenger cars, vans, trucks, buses. OEMs are well advanced here; importers of converted vehicles or replacement packs less so.
Phone, laptop and power-tool batteries. These will likely come into scope in later regulatory phases, but as of April 2026 they are excluded.
Who is legally responsible?
EU manufacturers issue the passport directly — it is part of placing the battery on the EU market.
Importers of non-EU batteries become the legally responsible party once they import. If your Chinese supplier doesn't issue passports, you must — there's no opting out.
Authorised representatives may be appointed by non-EU manufacturers to act on their behalf within the EU. Common pattern for Asian brands selling through European distributors.
What do I do with it once I have it?
- Print the QR code on the battery itself, on its label, or on durable packaging. Minimum size and contrast requirements apply (we generate a print-ready PNG).
- Keep the passport URL accessible for the lifetime of the battery — typically 5 to 15 years. We host the resolver URL forever as part of the passport price.
- Update the passport if material facts change (recall, refurbishment, second-life redeployment, end-of-life recycling). Updates are free — log into BatteryComply, edit, save.
- Provide a paper or digital copy to authorities or buyers on request, in addition to the QR code.
Common questions
Is a Battery Passport the same as a Declaration of Conformity?
No. The DoC is a manufacturer's signed statement that a product meets EU requirements — required for the audit we run. The Battery Passport is a structured public data record about a specific physical battery, separate document, separate purpose. You typically need both.
Can I generate the passport myself by reading Annex XIII?
Yes, the regulation is publicly available. Realistically, doing it yourself means: reading the 27-page Annex XIII spec, building a JSON-LD generator that anchors schema.org and the right namespace, registering UUIDs in ISO/IEC 15459 format, generating ISO/IEC 18004-conformant QR codes, and hosting the resolver URLs forever. We do all of this for €289 per passport, and the URL is hosted for the battery's lifetime.
What if my product is borderline — e.g., a 1.8 kWh industrial battery?
Then it's currently out of scope (the threshold is 2 kWh). But borderline products tend to drift into scope as regulators clarify edge cases. Email us with your spec sheet and we'll tell you straight.
Will customs actually enforce this on Day 1?
Honestly, the first 6 months will be inconsistent. Some EU countries (Netherlands, Germany, France) will enforce strictly. Others will warn before holding. Plan as if Day-1 enforcement happens — you cannot afford a customs hold on a container of e-bikes.
What does it cost from BatteryComply?
€289 / 2 890 kr per passport, one-time payment. Includes data extraction from your spec sheet, JSON-LD assembly, QR code generation in print-ready PNG, and lifetime hosting of the resolver URL. Bulk pricing kicks in at 5+ passports — email info@batterycomply.com for a quote.