BATTERY PASSPORT · EU REGULATION 2023/1542

From February 2027, every EV and industrial battery on the EU market carries a digital passport.

One QR. One data record. Cradle-to-grave, updated across the life.

Runs on your public disclosures. Nothing from you.

Deadline: 18 February 2027 for LMT, EV and industrial batteries >2 kWh In scope: All battery makers and importers placing batteries on the EU market Penalty: National sanctions, market exclusion, product recall
This is for

You are the Product Compliance Lead at a battery, EV or consumer electronics maker with EU sales. The EU battery regulation is live. Your product engineering team asks what a "battery passport" actually needs to contain.

The answer

The EU Battery Regulation (Regulation (EU) 2023/1542) requires a digital Battery Passport for every LMT (light-means-of-transport) battery, every electric vehicle battery, and every industrial battery above 2 kWh placed on the EU market from 18 February 2027. The passport is a QR-linked data record covering identity, composition, performance, carbon footprint, recycled content, supply-chain due diligence, and end-of-life. It updates through the battery life.

What Battery Passport actually is

The passport is issued by the "economic operator placing the battery on the market" (typically the OEM). Data is stored under the EU Digital Product Passport (DPP) infrastructure and accessed through a QR code, RFID tag or similar carrier on the product.

Content is layered. Public data (basic ID, performance, carbon footprint) is open to any user. Business-only data (composition, due diligence) is restricted to authorised parties. Regulator-only data (full traceability) is restricted to authorities.

The carbon footprint declaration follows a methodology published by the Commission (based on the PEF Category Rules for batteries). The recycled content declaration follows a methodology also published by the Commission. Both come into force staged, with performance thresholds tightening over time.

Why now

February 2027 is 18 months away. Data pipelines from suppliers, in-plant systems, and lifecycle databases take longer than 18 months to establish for a first-time passport. Starting the data model now is the difference between a first battery placed on the market with passport and a first battery held at customs.

WHAT BREAKS

What breaks when your carbon number is not defensible.

Three failure modes we see on every Battery Passport scan.

FAILURE 01

Supplier data gaps on composition

Cathode active material supplier will not disclose composition below the summary level. The passport composition section stays incomplete.

FAILURE 02

PEF-non-conformant carbon footprint

The company calculated a footprint under ISO 14067 but the passport requires a PEF-based calculation. The declaration cannot be filed.

FAILURE 03

Data infrastructure not machine-readable

Data lives in a PDF spec sheet. The passport requires structured, machine-readable data behind a QR. The submission fails on format.

HOW CARBON-OS ANSWERS

Three moves that make Battery Passport defensible.

ANSWER 01

A data model tuned to Annex XIII

Carbon-OS carries the battery passport data model as defined in Annex XIII of Regulation 2023/1542. Every field, every tier, is a first-class object.

ANSWER 02

PEF-compliant carbon footprint

The battery footprint is calculated under the PEF Category Rules referenced by the Commission, not just ISO 14067.

ANSWER 03

Supplier data flows built in

Cathode, anode, electrolyte, casing suppliers all get a data-collection template that maps to the passport. Their responses flow to the passport record.

See where your Battery Passport number stands. Free scan.

Get your Carbon X-Ray scan
FAQS

What people ask, straight.

Which batteries need a passport?

LMT batteries (e-bikes, e-scooters), EV batteries (all), and industrial batteries above 2 kWh capacity. Portable batteries (consumer devices) are exempt from the passport requirement, though other Regulation obligations still apply.

When does the passport requirement start?

18 February 2027. Announced under Article 77 of Regulation (EU) 2023/1542. Commission implementing acts on data content and access have been staged through 2025 and 2026.

Who issues the passport?

The economic operator that places the battery on the EU market. For imported batteries, that is typically the importer. For EU-made batteries, that is the OEM.

What is the carbon footprint methodology?

The Commission-published Product Environmental Footprint (PEF) Category Rules for batteries. Broadly aligned with ISO 14067 but with battery-specific rules on allocation and use-phase.

Does the passport update over the battery life?

Yes. State of health, remaining capacity, and second-life or recycling status are updated post-market. That is what makes it a "digital" passport, not a static declaration.