TIANQIUThe battery passport is the newest document in the European battery file, and the one most often asked for where it cannot exist. Orders for alkaline cells arrive with a passport on the document list, and a supplier of a portable range cannot meet that — not because paperwork is missing, but because Article 77 of Regulation (EU) 2023/1542 applies it to three categories only.
The narrow reading is the useful one. It takes two minutes to check a product against, it decides whether your 2027 file is a data-collection project or a label change, and it stops the wrong document being promised in a quotation.
What is a battery passport?
A battery passport is an electronic record for one finished battery, required by Article 77 of Regulation (EU) 2023/1542 and reached through the QR code carried on the battery. It holds data on the model and on the individual unit — identification, materials, performance, and for some categories state of health.
Three design choices decide how it behaves in practice. It is per battery rather than per product family, which is why the regulation speaks of each battery placed on the market. It is decentralised: the responsible operator hosts the record, while the EU registry that became operational on 20 July 2026 holds the unique identifier and the registration data rather than the passport itself. And it is layered: Annex XIII divides the content into a public block, a restricted block for parties with a legitimate interest such as repairers and recyclers, a block for authorities and notified bodies, and the use-related data that changes over the battery’s life.
Which batteries need one from 18 February 2027?
Article 77(1) names three categories: each LMT battery, each industrial battery with a capacity greater than 2 kWh, and each electric vehicle battery placed on the market or put into service from that date. Every other battery category is outside the obligation, including the portable lines we build.
| Category | The legal test | Passport from 18 Feb 2027 |
|---|---|---|
| Electric vehicle battery | Traction battery for a vehicle, and for L-category vehicles above 25 kg | Yes |
| LMT battery | Sealed, 25 kg or less, powering a wheeled vehicle such as an e-bike or e-scooter | Yes, at any capacity |
| Industrial battery above 2 kWh | Designed for industrial use, including after repurposing, or any battery over 5 kg that is not EV, LMT or SLI | Yes |
| Industrial battery of 2 kWh or less | Same definition, at or below the threshold | No — QR code only |
| Portable battery | Sealed, 5 kg or less, not designed for industrial use, and not EV, LMT or SLI | No — QR code only |
| SLI battery | Starting, lighting or ignition duty, and auxiliary uses | No — QR code only |
Category definitions are those of Article 3 of Regulation (EU) 2023/1542; the passport scope is Article 77(1). The legal test is the one to apply to your product rather than the name on its datasheet.
Two clarifications from the Commission’s FAQ change how a project gets scoped. Where several units depend on a common control system and together form one working battery, the assembly is treated as one battery, so the capacity to compare against the 2 kWh threshold is the total. And the trigger is the individual battery’s first supply in the EU, not the model’s launch date.
Do portable batteries need a battery passport?
No. Article 3(9) defines a portable battery as sealed, 5 kg or less, not designed for industrial use, and not an EV, LMT or SLI battery; that category is not in Article 77(1), so there is no passport to obtain for it.
All 29 models in our published product data are declared as portable batteries — the 22 Zn-MnO₂ models, covering the alkaline button cells and the LR6, LR03, 6LR61, 6F22, 23A and 27A types, and the 7 Li-MnO₂ coin cells from CR1025 to CR2477. The rechargeable and USB-rechargeable lines we build, and the packs assembled from these cells, are portable too, as long as the finished pack is sealed, within 5 kg and not designed for industrial duty.
What does not follow is a free pass. A portable battery is exempt from the passport, not from the regulation, and two duties arriving in 2027 land on the cell and on the appliance that holds it.
What does a battery without a passport need instead?
Article 13(6) requires a QR code on every battery from 18 February 2027 — all of them, not only the three categories that carry a passport. The same paragraph decides what the code must open, and the destination differs by category.
| Battery group | What the QR code opens |
|---|---|
| EV batteries, LMT batteries, industrial batteries above 2 kWh | The battery passport, under Article 77 |
| Portable batteries, SLI batteries, industrial batteries of 2 kWh or less | The labelling information, the EU declaration of conformity, the due diligence report where that duty applies, and the waste-battery information |
| SLI batteries, additionally | The recovered cobalt, lead, lithium and nickel content calculated under Article 8 |
The three destinations are the three branches of Article 13(6); the second row applies to every portable cell order.
Placement is the practical question for a cell 5.8 mm across. Article 13(7) requires the label and the code to be printed or engraved visibly, legibly and indelibly on the battery, then allows both to move to the packaging and the documents accompanying the battery where marking the battery itself is not possible or not warranted on account of its nature and size. For a watch or coin cell in a blister, that means the artwork on the pack and the leaflet inside it — which is why a 2027 order can require a print change even though the cell is unchanged.
Who has to create the passport, and what can a factory do?
The obligation sits with the economic operator that places the finished battery on the EU market or puts it into service. For a battery made in China and imported, that is normally the importer or the brand owner supplying it under its own name.
Article 77(4) then allows that operator to authorise another company in writing to create or update the passport, and the FAQ names a non-EU manufacturer, a cell manufacturer or an OEM among the parties that can be authorised. Two boundaries matter before a project plan depends on the arrangement: registration in the EU registry must be carried out by the operator placing the battery on the market, and written authorisation does not transfer the ultimate legal responsibility for accuracy, completeness and updating.
The registry side is live. The DPP registry became operational on 20 July 2026, and the implementing regulation covering battery passports, (EU) 2026/1778, is published. An operator registers after verifying its identity with a qualified electronic seal or an equivalent attestation, and that verification lasts three years at most before it has to be renewed — a lead time worth planning rather than discovering in the month before a launch.
What must the passport contain, and what stays empty in 2027?
Annex XIII sets the content and the access tiers. The Commission’s working breakdown — Digital Batteries Passport – data points by category, version 2.0 of 15 August 2026 — separates Annex XIII into 71 data points and marks each one, per category, as mandatory, conditional, optional, or not to be filled in as of February 2027.
Three groups are deliberately left out at the start: the carbon footprint declaration and label, the recycled content shares, and the due diligence information. Each has its own date — the due diligence report is required from August 2027 under Article 48(2) — and a passport created in February 2027 carries those fields only for batteries placed on the market after the relevant obligation starts.
One moving part remains. Access to the restricted blocks depends on an implementing act defining who has a legitimate interest and how far they may download or republish what they see; it was due in August 2026 and was still in preparation at the time of writing, with a draft expected for public feedback in late 2026.
What else reaches portable batteries between now and 2028?
The passport is not the only deadline in the regulation, and for a portable order the others matter more: a QR code on every battery, label content still being re-cut, a replacement duty on the appliance that holds the cells, and performance values that are still to be set.
| Requirement | Applies from | What it means on a portable order |
|---|---|---|
| QR code on the battery, or on the packaging and documents where size does not allow (Article 13(6) and (7)) | 18 February 2027 | New artwork on the pack; the code has to resolve to the label information, the declaration and the waste information |
| General information label under Annex VI Part A (Article 13(1)) | 18 August 2026, or 18 months after the implementing act if later | The label content on the cell and pack, which our artwork carries and will be re-cut against |
| Separate collection symbol under Annex VI Part B | 18 August 2025 | The crossed-out bin on every battery, covering at least 3% of the largest side up to 5 x 5 cm, with the heavy-metal symbol beneath where it applies |
| Removability and replaceability of portable batteries in appliances (Article 11) | 18 February 2027 | An appliance design duty: end users must be able to remove and replace the cells with commonly available tools, and spare batteries must be available for five years after the last unit of the equipment model is placed on the market |
| Minimum performance and durability values for general-purpose portable batteries, button cells excluded (Article 9) | 18 August 2028, or 24 months after the delegated act setting the values if later | The values themselves are still to be set; what is already expected is that a model's declared performance data can be produced on request |
Dates are those written into Regulation (EU) 2023/1542 and, for Article 11, the Commission's guidelines C(2026) 5032 of 14 July 2026 on removability and replaceability.
Read together, the table explains why portable projects still land in a compliance meeting: the cell may be unchanged, but the pack artwork gains a code, the appliance side has to be designed for replacement, and the performance figures in the datasheet become a document a customer may have to defend.
What is the timeline?
The regulation has applied since February 2024, but most of what a battery order has to document arrives later and on a different date for each battery category. Read as a sequence, the portable lines sit on the QR code, the labelling, the removability rules and — from 2028 — the performance values.
| Date | What starts |
|---|---|
| 17 August 2023 | Regulation (EU) 2023/1542 enters into force |
| 18 February 2024 | General date of application |
| 18 August 2024 | CE marking and conformity assessment provisions; obligations on economic operators |
| 18 August 2025 | Separate collection symbol on all batteries |
| 20 July 2026 | EU digital product passport registry becomes operational |
| 18 August 2026, or later | General information label under Annex VI Part A |
| 18 February 2027 | Battery passport for EV, LMT and industrial batteries above 2 kWh; QR code on all batteries; removability and replaceability rules |
| 18 August 2027 | Due diligence report obligation under Article 48(2) |
| 18 August 2028, or later | Minimum performance and durability values for general-purpose portable batteries |
Dates as published in the regulation and in the Commission's battery passport materials; the delegated and implementing acts behind the later rows are still being adopted, which is why several read 'or later'.
What should a buyer put in the order?
Four points settle a 2027 file, and all four are cheaper to settle before artwork than after it: the category recorded in writing, the per-model declaration, the packaging change if a code is needed, and an early start on data collection for anything in scope.
- Classify the product in writing. Say which category the finished battery falls into, and for an industrial battery whether it exceeds 2 kWh. Record who places it on the market, because that is the entity the regulation addresses.
- Ask for the declaration number per model. That is the document a portable order actually needs. Ours are issued per model against the IEC 60086 series, with the standards and scope set out line by line on the certification matrix.
- Settle the 2027 artwork now. If the pack will need a QR code, the packaging proof is the moment to place it, together with the label content and the separate-collection symbol.
- For a pack in scope, start the data collection early. Where a customer’s finished battery is an LMT battery or an industrial battery above 2 kWh, the passport data comes from the same technical file as the declaration; the slower part is agreeing who supplies each data point and who registers.
The rest of the document set behind an order is set out on the EU compliance page and in the certificates and documents guide. First orders with us begin at 50 cartons per product line, and the compliance pack is prepared per model, so a mixed carton is covered by the papers for the models inside it.
Where every claim here comes from
Every rule quoted above is traceable to a named text, and every statement about our own range comes from our published product data rather than from inference.
- The passport obligation, its scope and its date — Article 77(1) of Regulation (EU) 2023/1542: each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market or put into service from 18 February 2027. Written authorisation, the linked passport after remanufacturing and the registry upload are Articles 77(4), 77(7) and 77(10).
- The category definitions — Article 3 of the same regulation: the portable battery in Article 3(9), the industrial battery in Article 3(13), the stationary battery energy storage system in Article 3(15).
- The QR code and where it goes — Article 13(6) for the code, its three destinations and the date, Article 13(7) for placement on the packaging and documents where the battery’s nature and size do not allow marking it, and Parts A, B and C of Annex VI for the label, the separate collection symbol and the code.
- What is not required in February 2027 — the Commission’s FAQ for batteries, questions 7.1 to 7.3 on the deferred carbon footprint, recycled content and due diligence fields, and Article 48(2) for the August 2027 due diligence report.
- The 71 data points and their status per category — the Commission’s Digital Batteries Passport – data points by category, version 2.0 of 15 August 2026, which states that it does not extend the regulation’s obligations.
- The registry and verification — the Commission’s digital product passport pages for batteries, for the registry launch on 20 July 2026 and the 18 February 2027 passport date, implementing regulation (EU) 2026/1778, and FAQ questions 2.2 to 2.4 and 6.2.
- Removability, replaceability and spare parts — Commission guidelines C(2026) 5032 of 14 July 2026 applying Article 11, including the five-year spare-part requirement in Article 11(7).
- Our own lines, model counts and the portable classification — our published product data, the same 29 models and categories rendered on the certification matrix.