What Is the EU Battery Passport?
What Does the New Regulation Introduce and Who Does It Affect?
The European Union’s Battery Regulation (EU) 2023/1542 treats batteries not merely as technical products, but as environmental, economic, and digital assets. At the core of this approach lies the Battery Passport.
The battery passport is a digital identity designed to ensure transparency, traceability, and verifiability of batteries throughout their entire lifecycle — from production to recycling.
This article provides a structured overview of:
- what the battery passport is,
- which information it must contain,
- and what it means for economic operators,
based on the Regulation’s recitals, key articles, and Annex XIII.
Purpose of the Battery Passport (Recitals 123–125)
According to the Regulation, the battery passport aims to:
- Increase transparency across the battery supply and value chain
- Maximise standardised and reliable information sharing
- Ensure traceability of batteries
- Enable data-driven decisions on sustainability, reuse, and recycling
The battery passport goes beyond basic technical specifications and includes information such as:
- carbon intensity of manufacturing processes,
- origin of materials,
- share of renewable materials,
- raw materials and hazardous substances,
- battery composition.
Processes Covered by the Battery Passport
The Regulation requires the battery passport to provide information on the following processes:
- Repair
- Reuse
- Remanufacturing
- Disassembly
- Treatment
- Recycling and recovery
In addition, the passport must indicate under which conditions these processes are required, allowing both economic operators and authorities to make informed decisions about the battery’s next lifecycle stage.
Access Levels to Battery Passport Information (Article 77)
The battery passport is not a single, fully public data set. The Regulation clearly defines tiered access levels.
1. Publicly Accessible Information
- Battery model and basic technical data
- Carbon footprint information
- Recycled content share
- Renewable content share
- Labelling and marking information
2. Information Accessible to Authorities Only
(Approved bodies, market surveillance authorities, and the European Commission)
- Evidence of regulatory compliance
- Test and conformity assessment results
3. Information Accessible to Parties with Legitimate Interest
(Repairers, remanufacturers, second-life operators, recyclers, etc.)
- Detailed material composition (cathode, anode, electrolyte)
- Disassembly instructions and exploded diagrams
- Safety instructions
- State of Health (SoH)
- Usage data and cycle history
This structure aims to balance commercial confidentiality with circular economy objectives.
QR Code and Digital Access Requirement
As of 18 February 2027, the following batteries must carry a QR code:
- LMT batteries
- Industrial batteries with a capacity above 2 kWh
- Electric vehicle batteries
The QR code:
- links to a unique identifier assigned by the economic operator placing the battery on the market,
- must comply with ISO/IEC 15459 series or equivalent standards,
- provides direct digital access to the battery passport.
Responsibility and Authorisation
The Regulation establishes clear responsibility rules:
- The economic operator placing the battery on the market is responsible for ensuring that passport data is:
- accurate,
- complete,
- and up to date.
- This operator may grant written authorisation to another operator to act on its behalf regarding passport updates.
- When a battery undergoes reuse, remanufacturing, or changes status to waste:
- responsibility is transferred,
- a new battery passport is created,
- and links to the original passport(s) are maintained.
Annex XIII — The Data Backbone of the Battery Passport
One of the most critical components of the Regulation is Annex XIII, which defines:
- which data fields are mandatory,
- which data is accessible to which stakeholders,
- how individual battery data must be managed.
This clearly demonstrates that the battery passport is not merely a technical label, but a legal, operational, and digital data governance system.
Conclusion: The Battery Passport Is Not a Label — It Is a System
The battery passport is:
- not just a QR code,
- not just a dataset,
- not just a regulatory checkbox.
It is an end-to-end system that requires:
- digital infrastructure,
- access control and authorisation mechanisms,
- lifecycle data management,
- interoperable and machine-readable data architectures.
In the coming years, compliance will no longer be optional.
For all actors involved in producing, importing, selling, using, or recycling batteries, battery passport compliance will be a regulatory necessity.
This article is based on EU Battery Regulation (EU) 2023/1542 and related secondary legislation.
For more information: https://batrix.io