What is a Battery Passport?
A Battery Passport is a specific type of Digital Product Passport mandated by the EU Battery Regulation (Regulation 2023/1542). It's a digital record containing comprehensive information about a battery's composition, origin, carbon footprint, and lifecycle—accessible via a QR code on the battery itself.
The Battery Passport is significant because it represents the first confirmed Digital Product Passport deadline under EU law. While other product categories await delegated acts, the Battery Regulation already contains specific requirements and dates, making it a template for future DPP implementations.
Key Features of the Battery Passport
- •Unique identifier: Each battery has a globally unique ID linked to its digital passport
- •QR code access: Scannable code on the battery links to passport information
- •Lifecycle tracking: State of health updates throughout the battery's life
- •Supply chain transparency: Due diligence on raw material sourcing
- •End-of-life support: Recycling and second-life application information
February 2027 Deadline
The EU Battery Regulation sets a clear deadline: February 18, 2027. From this date, all covered batteries placed on the EU market must have a valid Battery Passport.
Timeline Leading to the Deadline
Battery Regulation fully entered into force
Carbon footprint declaration required for EV and LMT batteries
Due diligence policies must be implemented
Battery Passport mandatory for industrial, EV, and LMT batteries >2 kWh
Recycled content disclosure mandatory
Minimum recycled content targets take effect
Why Start Preparing Now?
With the deadline less than 2 years away, battery manufacturers and importers should begin implementation now. Setting up Battery Passport systems, collecting supply chain data, and establishing carbon footprint calculations typically takes 12-18 months.
Which Batteries Are Covered?
The Battery Passport requirement applies to specific battery categories based on their application and capacity:
Electric Vehicle (EV) Batteries
Traction batteries in electric vehicles
- • Electric cars and vans
- • Electric buses and trucks
- • All capacity levels
Industrial Batteries >2 kWh
Batteries for industrial applications
- • Energy storage systems
- • Backup power systems
- • Industrial equipment batteries
LMT Batteries >2 kWh
Light Means of Transport batteries
- • E-bikes with removable batteries
- • Electric scooters
- • Electric motorcycles
Other Battery Types
Not requiring Battery Passports
- • Portable batteries (AA, AAA, etc.)
- • SLI batteries (starting, lighting)
- • Batteries under 2 kWh threshold
Note: While portable and SLI batteries don't require full Battery Passports, they still have labeling and end-of-life requirements under the Battery Regulation.
Battery Passport Data Requirements
The Battery Passport must contain comprehensive information across several categories. Here's the complete data requirement checklist:
Battery Passport Data Checklist
General Information
- Unique battery identifier
- Battery manufacturer name and address
- Manufacturing date and place
- Battery category and model
- Battery weight
Technical Specifications
- Battery chemistry (Li-ion, LFP, NMC, etc.)
- Rated capacity (kWh)
- Nominal voltage
- Expected lifetime (cycles/years)
- Temperature range of operation
Material Content
- Cobalt content and recycled percentage
- Lithium content and recycled percentage
- Nickel content and recycled percentage
- Lead content and recycled percentage
- Hazardous substances present
State of Health (Dynamic)
- State of Health (SoH) percentage
- Remaining capacity
- Charge cycles completed
- Remaining useful life estimate
Environmental & Compliance
- Carbon footprint (kg CO₂e per kWh)
- Due diligence report reference
- End-of-life handling instructions
- Recycling information and contacts
Carbon Footprint Requirements
Carbon footprint disclosure is one of the most significant Battery Passport requirements. The regulation introduces progressively stricter requirements:
Phase 1: Declaration (Feb 2025)
EV and LMT batteries must declare their carbon footprint in kg CO₂e per kWh of capacity.
- • Must follow EU calculation methodology
- • Covers raw material to manufacturing
- • Third-party verification recommended
Phase 2: Performance Classes (Feb 2026)
Batteries must display a carbon footprint performance class label (A to E or similar).
- • Enables consumer comparison
- • Classes based on life cycle CO₂e
- • Must be visible on battery and passport
Phase 3: Maximum Thresholds (2028)
Batteries exceeding maximum carbon footprint thresholds will be banned from the EU market.
- • Threshold values to be set by Commission
- • Based on battery category and chemistry
- • Drives industry decarbonization
Carbon Footprint Calculation Scope
The carbon footprint must cover:
- • Raw material extraction and processing
- • Cell and module manufacturing
- • Battery pack assembly
- • Transport of materials (significant stages)
Recycled Content Requirements
The Battery Regulation introduces mandatory recycled content requirements for critical battery materials. These requirements are phased in over time:
| Material | 2028 (Disclosure) | 2031 (Minimum) | 2036 (Minimum) |
|---|---|---|---|
| Cobalt | Declare % | 16% | 26% |
| Lithium | Declare % | 6% | 12% |
| Nickel | Declare % | 6% | 15% |
| Lead | Declare % | 85% | 85% |
Recycled content must be verified through documentation from the recycling process and supply chain. Battery Passports must include recycled content data and will be checked during market surveillance.
Supply Chain Due Diligence
The Battery Regulation requires companies to conduct due diligence on their battery supply chains, particularly for critical raw materials like cobalt, lithium, and nickel.
Due Diligence Requirements
- 1.Management systems: Establish policies on supply chain due diligence
- 2.Risk identification: Map supply chains and identify potential risks
- 3.Risk mitigation: Implement measures to address identified risks
- 4.Third-party verification: Have due diligence audited by independent body
- 5.Disclosure: Publish due diligence policies and reports
The Battery Passport must reference or link to the company's due diligence report, providing transparency on responsible sourcing practices.
How to Implement Battery Passports
Implementing Battery Passport compliance requires coordination across multiple departments and suppliers. Here's a practical roadmap:
Assess Your Portfolio
Identify which batteries in your portfolio require passports:
- • List all battery products by category
- • Check capacity thresholds (2 kWh)
- • Identify EU market exposure
Collect Supply Chain Data
Gather required information from suppliers:
- • Material composition and origins
- • Recycled content percentages
- • Carbon footprint data per component
- • Due diligence documentation
Calculate Carbon Footprint
Develop carbon footprint calculations:
- • Follow EU methodology requirements
- • Collect activity data from manufacturing
- • Apply appropriate emission factors
- • Consider third-party verification
Implement Passport System
Set up technical infrastructure:
- • Select or build Battery Passport platform
- • Generate unique identifiers
- • Create QR code integration
- • Establish data update processes
Test and Validate
Before the deadline:
- • Pilot with select battery models
- • Verify QR code functionality
- • Validate data accuracy
- • Train relevant staff
Frequently Asked Questions
Do e-bike batteries need a Battery Passport?
E-bike batteries are covered under the LMT (Light Means of Transport) category. If the battery capacity exceeds 2 kWh, a Battery Passport is required from February 2027. Many e-bike batteries are below this threshold, but check your specific products.
What about batteries already in the market before 2027?
Battery Passport requirements apply to batteries "placed on the market" after the deadline. Existing inventory sold before February 2027 doesn't need retroactive passports. However, batteries manufactured before the deadline but sold after it must comply.
How is State of Health (SoH) updated?
For EV batteries, the Battery Management System (BMS) calculates SoH based on capacity fade and internal resistance. This data must be accessible and can be updated in the passport when the battery is serviced, sold, or enters second-life applications.
What are the penalties for non-compliance?
Batteries without valid passports cannot be placed on the EU market after the deadline. Penalties are set by member states and can include fines, product recalls, and market bans. Given the high value of battery products, the commercial impact of non-compliance is significant.
Start your Battery Passport journey
February 2027 is approaching. Begin your compliance preparation now to ensure you meet the deadline without disruption.