Battery passport from 2027: when the obligation applies.
From 18 February 2027 the digital battery passport is mandatory - for EV batteries, LMT batteries and industrial batteries above 2 kWh. This guide answers the three core questions: when exactly the obligation kicks in, for whom it applies and which deadlines of the EU Battery Regulation already matter beforehand.
- When? From 18 February 2027. From that day, affected batteries may only be placed on the EU market with a digital battery passport and QR code (Art. 77, EU 2023/1542).
- For whom? EV batteries, LMT batteries (e-bike, e-scooter) and industrial batteries above 2 kWh - including home and large-scale storage. Portable batteries and starter batteries are exempt.
- Existing stock is untouched: the obligation applies to batteries placed on the market from the deadline - not retroactively.
- 2027 is only the finish line. The carbon declaration (2025) and due diligence (2025) already run - and the supply-chain data for the passport needs months of lead time.
All EU Battery Regulation deadlines at a glance
The regulation does not enter into force on a single day but in stages. The battery passport on 18 February 2027 is the best-known deadline - but not the first:
The EU Battery Regulation 2023/1542 enters into force and replaces the old Battery Directive 2006/66/EC - as a regulation it applies directly in every member state.
The bulk of the rules apply: CE conformity, labelling fundamentals and the systematics of the battery categories take effect from now on.
Traction batteries need a carbon-footprint declaration - the first deadline that requires real supply-chain data. Further categories follow in a staggered manner.
Larger companies must demonstrate due diligence for raw materials such as cobalt, lithium, nickel and natural graphite - audited processes instead of declarations of intent.
The deadline: every EV, LMT and industrial battery above 2 kWh needs a digital battery passport when placed on the market, reachable via a QR code on the battery.
For cobalt, lithium, nickel and lead the share from recycled material must be documented - binding minimum quotas follow from 2031.
The full background to the regulation is explained in the guide EU Battery Regulation 2023/1542.
Which batteries need a passport from 2027?
The passport obligation depends on the battery category - not on the size of the company. Even a mid-sized manufacturer with a single storage model is affected:
| Category | Typical products | Passport duty from 2027 |
|---|---|---|
| EV / traction batteries | electric car, e-van, hybrid | Passport + QR from 18 Feb 2027 |
| LMT batteries | e-bike, e-scooter, cargo bike | Passport + QR from 18 Feb 2027 |
| Industrial batteries > 2 kWh | home storage, BESS, forklift, UPS | Passport + QR from 18 Feb 2027 |
| Portable batteries | power tools, laptop, household | No passport - but labelling & take-back |
| SLI / starter batteries | 12 V starter battery in a car | No passport - but carbon & recycled-content duties |
Unsure which category your battery falls into? The eligibility check clarifies that in 90 seconds - the categories in detail are shown in the guide Battery models & application classes.
“Placing on the market”: what the deadline actually means
The obligation is tied not to the production date but to placing on the market - the first making available of the battery on the EU market. Three practical consequences follow:
Batteries placed on the market before 18 Feb 2027 need no passport retroactively - even if they are resold afterwards.
Anything not yet made available on the EU market by the deadline needs the passport - regardless of when it was produced. Full warehouses offer no protection from the duty.
Anyone importing batteries from third countries into the EU places them on the market - the importer must ensure a compliant passport exists.
Responsibility by role
Manufacturers create the passport, importers verify it, distributors may only offer compliant goods (Chapter VI of the regulation). Suppliers are not obliged to hold a passport but provide the data - how that works in practice is shown on the page for suppliers.
Battery-passport-ready by 2027: the realistic roadmap
The passport itself is quickly generated - the data is the bottleneck. Anyone who only requests the supply-chain values shortly before the deadline has lost. This is the roadmap manufacturers use to be ready in time:
Which of your models fall under the passport obligation? Category, capacity and time of market entry decide - the eligibility check answers this in 90 seconds.
Annex XIII requires around 90 data points per model - from chemistry to carbon footprint. Check early which values are missing in-house and which suppliers hold them.
Supply-chain data is the bottleneck with the longest response times. Anyone who only asks in late 2026 waits while the deadline draws closer.
One passport per unit, not per model - with a unique GS1 Digital Link QR. Start with a pilot model and then scale to the entire catalogue.
The step-by-step guide with software criteria is in the article Create a battery passport; what looms without a passport is calculated in Risks of non-compliance.
Common questions about the 2027 battery passport duty
When does the battery passport become mandatory?
Which batteries does the passport obligation apply to?
Does the battery passport also apply to batteries sold before 2027?
Is the battery passport already mandatory today?
Who has to create the battery passport?
What happens if I have no battery passport from 2027?
How long must the battery passport stay available?
Sources & further reading
From the first model to an EU-compliant battery passport before the deadline bites.
Batteriepasswerk generates EU-compliant battery passports per unit - with a GS1 Digital Link QR, to DIN DKE SPEC 99100, hosted in the EU. Create the model, invite suppliers, serialise: done before 2027.