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
10
Mandatory areas
Annex XIII / DIN DKE SPEC 99100
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 and formalised as data attributes in the standard DIN DKE SPEC 99100. The passport covers the following areas:
Material composition
Cathode and anode chemistry, electrolyte, critical raw materials (cobalt, lithium, nickel, natural graphite).
Carbon footprint
Calculated figure (not an estimate) from raw material extraction through to manufacturing, per site and batch, without offsets.
Due diligence
Third-party-verified supply chain evidence for EV and industrial batteries, from 18.08.2027.
Performance & durability
Rated capacity, rated voltage, expected lifetime in cycles, performance class.
Recycled content
Share of recycled materials (cobalt, lead, lithium, nickel).
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
You determine this value via a Life-Cycle Assessment (LCA) — we store it in a structured way and display it in the passport in accordance with the regulation. 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, CO₂, 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 provides for four access levels, which the QR code resolver delivers depending on the caller:
Public
End consumers, NGOs, buyers
Basic information, carbon footprint, recycled content, performance class, safety and recycling information — the "nutrition label" layer.
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.
Feb 2025Milestone
CO₂ declaration EV (Class 1)
Mandatory carbon footprint declaration for EV batteries — manufacturer declaration.
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).
From 2028Milestone
CO₂ obligations for industrial batteries
Gradual extension of CO₂ obligations to industrial batteries (declaration, performance classes, thresholds).
2030/31Milestone
First recycled content minimums
Minimum recycled content (cobalt, lead, lithium, nickel) first become enforceable.
From 2033Milestone
Raised recycled content thresholds
Tightened stages 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 standard for the data attributes of the battery passport, published in January 2025 by DIN and DKE (Battery Pass Consortium, BMWK-funded). Defines format, unit and value range for each mandatory field. Freely available.
Data attributesGS1 Digital Link
Standard for resolving a QR code to structured data — the same standard used by the broader Digital Product Passport. Cleanly separates physical identifier from digital view.
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
- We structure data according to DIN DKE SPEC 99100.
- QR codes per GS1 Digital Link.
- AAS export for Catena-X / Path.Era in preparation (available 2027).
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.
| 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 | Regular reports to market surveillance authorities. |
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
For EV batteries, a carbon footprint declaration (Class 1: manufacturer declaration) has applied since February 2025. Performance classes and thresholds follow in stages; CO₂ obligations for industrial and LMT batteries kick in later.
The value must be calculated, not estimated — via a Life-Cycle Assessment (LCA), per production site, per batch, cradle-to-gate (raw material extraction to factory gate). Carbon offsets are not permitted.
Clear distinction
- Batteriepasswerk does not calculate your carbon footprint. You supply the figure from your LCA calculation (in-house or via an LCA partner) — we take the number in a structured way, attach methodology and source evidence, validate plausibility and display it in the passport in accordance with the regulation. We can recommend LCA partners on request.
11 · Recycled content
Recycled content
The regulation sets minimum recycled content shares — first applicable from the early 2030s, with tightened stages later. The materials primarily affected are cobalt, lead, lithium and nickel.
Actual recycled content per battery is documented in the passport and forms part of the public "nutrition label" view — enabling consumers and buyers to compare.
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 / DIN DKE SPEC 99100 | 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 | Upcoming · 2027 |
| Display carbon footprint compliantly | Structured intake + display of LCA value | 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. You supply the value calculated via a Life-Cycle Assessment — we store it in a structured way and display it in the passport in accordance with the regulation.
Is the data structure DIN DKE SPEC 99100 compliant?
Yes. Data structure per DIN DKE SPEC 99100, QR code per GS1 Digital Link, data hosted 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.
DIN DKE SPEC 99100
Freely available via DIN and VDE.
Battery Pass Consortium
Systemiq, BMWK-funded — content guidance and technical demonstrators.
Catena-X / Path.Era
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?
Create your first passport to DIN DKE SPEC 99100 in minutes — free, no IT project required.