General information
Manufacturer, brand, model, place and date of manufacture, unique serial number/identifier.
● Compliance · EU 2023/1542
EU Battery Regulation 2023/1542 - plainly explained
From 18 February 2027, every electric-vehicle, LMT and industrial battery (above 2 kWh) placed on the EU market needs a digital battery passport, accessible via a QR code on the battery. This page explains who is affected, what must be in the passport, and which other obligations the regulation introduces - in plain English, without regulatory jargon.
18.02.27
Passport deadline
EV, LMT, industrial > 2 kWh
5
Battery categories
3 subject to passport requirement
4
Access views
Public · Pro · Recycler · Authority
71
EU data points
Version 2.0, 15.08.2026
Deadline18.02.
2027
2027
Deadline for the digital battery passport
From this date, EV, LMT and industrial batteries (> 2 kWh) may only be placed on the EU market if they carry a digital battery passport. The passport is accessible via a unique QR code on the battery (engraved or printed) and contains the mandatory information specified in the regulation - per individual battery, not per model. Data must be stored for the entire service life of the battery.
03 · Who is affected?
Five categories - three with a passport obligation
The EU Battery Regulation distinguishes five battery categories. The passport obligation from February 2027 applies to three of them. Other obligations of the regulation (conformity, labelling, collection, recycling) apply to all categories regardless of the passport.
| Category | Examples | Passport from 18.02.2027? |
|---|---|---|
| Electric vehicle batteries (EV) | Traction batteries for passenger cars, commercial vehicles, buses | Yes, mandatory |
| Industrial batteries (> 2 kWh) | Stationary storage (BESS), UPS, intralogistics (AGVs/forklifts), commercial storage | Yes, mandatory |
| Light means of transport (LMT) | E-bike, e-scooter, pedelec, e-moped | Yes, mandatory |
| Industrial batteries (≤ 2 kWh) | Small buffer batteries | No passport in first phase |
| Portable batteries (devices) | Consumer electronics, power-tool batteries | No passport in first phase |
| SLI batteries | 12 V car starter batteries | No passport in first phase |
Who is responsible?
The obligation falls on the economic operator who places the battery on the EU market or puts it into service - typically the manufacturer, importer or brand owner. End customers, resellers without their own brand, and pure service providers are not directly subject to the passport obligation.
Not sure?
- Our eligibility check clarifies in two minutes which category applies to you and which specific obligations you face.
04 · Mandatory content
What must be in the passport?
The mandatory content is defined in Annex XIII of the regulation. Which data points must be filled from 18 February 2027 is set by the European Commission's official list (71 data points, Version 2.0, 15 August 2026): 47 are mandatory for EV, 50 for LMT and 32 for industrial batteries. DIN DKE SPEC 99100 is not the source of mandatory fields but a non-binding pre-standard that data structure and access levels are aligned with. The passport covers the following areas:
Material composition
Cathode and anode chemistry, electrolyte, critical raw materials (cobalt, lithium, nickel, natural graphite).
Carbon footprint
Not yet applicable: per the Commission not to be filled as of February 2027; the format is still to be specified in an upcoming implementing act. There is no date yet.
Due diligence
Public due-diligence report (Art. 52(3)), required from August 2027; operators below EUR 40 million net turnover are exempt.
Performance & durability
Rated capacity, rated voltage, expected lifetime in cycles, internal resistance.
Recycled content
Cobalt, lithium, nickel, lead: not to be filled as of February 2027, only with Art. 8 (documentation from 18.08.2028). The renewable content share, by contrast, is mandatory.
Safety & hazard information
Hazard classification and safety features.
Repair & dismantling
Information for workshops and recyclers.
Status information
Per unit: in market / repaired / second life / end-of-life.
Conformity & test data
CE conformity, declaration of conformity, test reports.
What we do not calculate for you: the carbon footprint
The carbon footprint declaration is not yet applicable; you will later determine the value via a Life-Cycle Assessment (LCA). Until then, Batteriepasswerk keeps the field visible as not yet applicable, and you can store existing LCA data voluntarily. We can connect you with LCA partners on request.
05 · Unit vs. model
Per unit or per model? - the most important distinction
The most common misunderstanding we encounter: the battery passport is required per physical battery, not per product family. In practice:
50k
Passports for 50,000 batteries
If you produce 50,000 batteries per year, you need 50,000 individual passports - each with a unique identifier and its own QR code.
2
Data layers per passport
Model data (chemistry, materials, performance - identical for all units) and unit data (serial number, production date, site, batch - unique per piece).
1
One QR code, multiple views
The QR code on the battery uniquely resolves to that specific unit and returns the appropriate view depending on the access role of the caller.
How Batteriepasswerk handles this
- You maintain the model template once. Then you import your serial numbers via CSV, Excel or API - Batteriepasswerk automatically generates thousands of unit passports and QR codes from it.
06 · Role-based access
Who gets to see what?
Not everyone should see all data. The regulation distinguishes three access levels (public, legitimate interest, authorities); Batteriepasswerk maps them to four views, which the QR code resolver delivers depending on the caller:
Public
End consumers, NGOs, buyers
Basic information, renewable content share, performance and durability, safety and recycling information - the "nutrition label" layer. Carbon footprint and recycled content are added once the delegated acts apply.
Legitimate interest
Research, accredited bodies
In-depth materials and supply chain data.
Value chain
Recyclers, repurposers, workshops
Dismantling instructions, detailed material composition, repair information.
Authority
Market surveillance & notified bodies
Full access to all data including conformity evidence.
Technical implementation: Realised via a resolver following GS1 Digital Link - one QR code, multiple views. The server determines which data layer to return based on the request.
07 · Timeline
Regulation timeline
Aug 2023Milestone
Entry into force of Regulation (EU) 2023/1542
Replaces Directive 2006/66/EC.
Feb 2024Milestone
General provisions apply
Start of the application of general provisions.
18.02.2025Milestone
Base date CO₂ declaration EV (Art. 7)
The later date applies: 12 months after the delegated act enters into force, and that act is still missing. Not applicable today.
18.02.2026Milestone
Base date CO₂ declaration industrial (Art. 7)
For rechargeable industrial batteries above 2 kWh; again the later date counts, 12 months after the delegated act. Not applicable today.
18.02.2027Main deadline
Digital battery passport mandatory ⭐
For EV, LMT and industrial batteries (> 2 kWh). Unique QR code on each battery.
18.08.2027Milestone
Due diligence obligations (Annex X)
For cobalt, lithium, nickel and natural graphite (postponed from August 2025 via the Omnibus package).
18.08.2028Milestone
Recycled content documentation (Art. 8)
Recycled content for cobalt, lithium, nickel and lead must be documented (methodology via delegated act). Also the base date of the CO₂ declaration for LMT, again only 12 months after the delegated act.
18.08.2031Milestone
First recycled content minimums
At least 16 % cobalt, 6 % lithium, 6 % nickel and 85 % lead from recycling.
18.08.2036Milestone
Raised recycled content thresholds
Tightened minimum shares for recycled content.
The EU continuously publishes delegated acts that specify or adjust individual obligations. Only the regulation text and the official legal acts are binding.
08 · Standards
The technical building blocks
The regulation defines the what; technical standards define the how. Three building blocks are central to implementation:
DIN DKE SPEC 99100
The German pre-standard for the data attributes of the battery passport, published in early 2025 by DIN and DKE (edition 2025-02, Battery Pass Consortium, BMWK-funded). Non-binding: it describes format, unit and value range of the data attributes and three access levels. Which fields are mandatory is set by the European Commission's data-point list. Freely available.
Data attributesGS1 Digital Link
Standard for resolving a QR code to structured data. Cleanly separates physical identifier from digital view and is currently the most likely candidate for the broader Digital Product Passport as well - that standardisation is still under way within the ESPR.
QR resolverAsset Administration Shell (Catena-X)
IDTA, the Battery Pass Consortium and Catena-X have developed AAS submodels that make the passport interoperable within the automotive data space - with ECLASS/IEC-CDD semantics and a standardised AAS API. Relevant if you supply OEMs such as BMW or VW.
AutomotiveHow Batteriepasswerk uses these standards
- Mandatory fields per the European Commission's official list of 71 data points (Version 2.0, 15 August 2026); data structure and access levels aligned with DIN DKE SPEC 99100.
- QR codes per GS1 Digital Link.
- AAS export for Catena-X in preparation.
09 · Annex X
Supply-chain due diligence
From 18 August 2027, economic operators placing EV and industrial batteries (> 2 kWh) on the market must demonstrate due diligence in their supply chain - for four critical raw materials: cobalt, lithium, nickel and natural graphite. The evidence must be third-party verified by a notified body and retained for ten years. Operators with a net turnover below EUR 40 million are exempt (Art. 47).
| Obligation | What must be demonstrated |
|---|---|
| Risk identification | Assessment of supply-chain risks (human rights, environment, corruption). |
| Risk management | System for risk mitigation and documented measures. |
| Third-party audit | Independent audit of the supply-chain policy. |
| Reporting | Public report under Art. 52(3), which the passport shows as data point 19; the first report is expected in 2028. |
Note on the postponement
These obligations were originally planned for August 2025 and were moved to August 2027 via the Omnibus simplification package. A further postponement cannot be ruled out - the regulation text and delegated acts remain binding.
What Batteriepasswerk provides: The Annex X due-diligence workflow is part of our Enterprise plan and will be rolled out ahead of the 2027 deadline. You can already store supply-chain data and third-party verification evidence in a structured, versioned way.
10 · CO₂
Carbon footprint in the battery passport
Art. 7 provides for a carbon footprint declaration for EV, rechargeable industrial (> 2 kWh) and LMT batteries. The base dates it names (EV 18.02.2025, industrial 18.02.2026, LMT 18.08.2028) each apply only "or 12 months after the entry into force of the delegated act, whichever is later". That act has not been adopted - so today the declaration applies to no category. The Commission lists the carbon footprint declaration and label (data points 17 and 18) as not to be filled as of February 2027 and gives no timing yet; once the act is adopted, there is more than a year to comply. Performance classes and maximum thresholds come even later.
How exactly the value is calculated and presented in the passport will only be set by the pending legal acts. It will be based on a Life-Cycle Assessment (LCA).
Clear distinction
- Batteriepasswerk does not calculate your carbon footprint. Until the act applies, the dashboard and the passport keep the field visible as not yet applicable - it does not disappear. You can already store existing LCA data (in-house or from an LCA partner) voluntarily. Once the act is adopted, the field becomes mandatory via a rule update. We can recommend LCA partners on request.
11 · Recycled content
Recycled content
The regulation sets minimum recycled content shares - first from 18 August 2031 (16 % cobalt, 6 % lithium, 6 % nickel, 85 % lead), raised from 2036. Before that, from 18 August 2028, recycled content must be documented under Art. 8; the calculation method is set by a delegated act.
In the passport, recycled content (data points 20 to 23) is not to be filled as of February 2027, per the Commission. It is added in line with Art. 8 and the delegated act and then becomes part of the public "nutrition label" view. The renewable content share (data point 24), by contrast, is mandatory from the deadline.
12 · Conformity mapping
How Batteriepasswerk makes you compliant
We have mapped every regulatory requirement to a concrete feature. Status and availability are transparent:
| Requirement | Batteriepasswerk feature | Status |
|---|---|---|
| Unique passport per unit + QR code | Mass serialisation via CSV/API; GS1 Digital Link QR per unit | Available |
| Mandatory content per Annex XIII (71 EU data points, Version 2.0) | Model template with all mandatory fields, validation | Available |
| Role-based access (public, recycler, authority) | Resolver with access roles | Available |
| Lifetime data storage (15–25 years) | EU hosting (Germany), versioning | Available |
| Supplier data collection | Self-service links for suppliers, no account required | Available |
| Certificate ingestion (automated data capture) | OCR/AI extraction of uploaded certificates | Upcoming · 2027 |
| Annex X due-diligence workflow | Documentation, third-party verification, audit trail | Upcoming · 2027 |
| Catena-X / AAS integration | AAS submodel export, Catena-X API | Upcoming · 2027 |
| ERP/MES integration for automated serialisation | REST API v1 (OpenAPI 3.1), scoped keys, test mode | Available |
| Carbon footprint (not yet applicable) | Field visible as not yet applicable, LCA data voluntary; mandatory via rule update once the act applies | Available |
| Audit mode for authorities | Full access for notified bodies / market surveillance | Available |
Features marked "upcoming" will be rolled out ahead of the respective deadlines. Early customers are actively involved in development and receive preferential terms.
13 · FAQ
Frequently asked questions
Does each individual battery need its own passport?
Yes. One passport per physical battery, with a unique identifier and QR code - not per model. Batteriepasswerk generates these automatically from a single model template.
What happens if I miss the deadline?
You will no longer be permitted to place your batteries on the EU market. Member States set the precise sanctions; in Germany, market surveillance is carried out by the competent federal and state authorities. The national implementing rules are binding.
Does this only apply to German manufacturers?
No. The obligation applies to everyone who places batteries on the EU market or puts them into service - regardless of where they are produced. Importers from Asia are subject to the same passport requirements as EU manufacturers.
What if my battery is only 1.9 kWh?
The passport obligation for industrial batteries applies only above 2 kWh. Other requirements of the regulation (conformity, labelling, collection) still apply.
Does Batteriepasswerk calculate our carbon footprint?
No. The carbon footprint declaration is not yet applicable: the delegated act is missing, and the Commission lists it as not to be filled as of February 2027. Batteriepasswerk therefore keeps the field visible as not yet applicable and makes it mandatory via a rule update once the act applies. We do not produce the life-cycle assessment (LCA); if you already have LCA data, you can store it voluntarily.
What are the mandatory fields based on - DIN DKE SPEC 99100?
Mandatory fields follow the European Commission's official list of 71 data points (Version 2.0, 15 August 2026). DIN DKE SPEC 99100 is a non-binding pre-standard; we align our data structure and access levels with it. On top of that come QR codes per GS1 Digital Link and hosting in Germany.
What if the EU shifts the deadline?
We actively monitor the regulation and delegated acts and adapt our roadmap accordingly. Your subscription and data remain unchanged.
Legal notice
This page summarises EU Battery Regulation (EU) 2023/1542 for information purposes and does not constitute legal advice. Only the regulation text, the associated delegated acts and the national implementing rules are binding. For a binding assessment of your specific situation, please consult a qualified law firm or the competent market surveillance authority.
15 · Sources
Further reading
Regulation text (EU) 2023/1542
EUR-Lex - official full text.
European Commission data-point list
“Digital Batteries Passport - data points by category”, Version 2.0, 15.08.2026.
DIN DKE SPEC 99100
Non-binding pre-standard, freely available via DIN and VDE.
Battery Pass Consortium
Systemiq, BMWK-funded - content guidance and technical demonstrators.
Catena-X
Battery passport in the automotive data space.
GS1 Germany
Digital Link and the PINE programme.
BatteryPass-Ready
Test environment for passport solutions.
Ready to make your batteries compliant?
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