The EU battery passport is the electronic record that every electric vehicle (EV) battery, light means of transport (LMT) battery and industrial battery above 2 kWh placed on the EU market must have from February 18, 2027, under Article 77 of Regulation (EU) 2023/1542. It opens from a QR code on the battery, holds data on the model and on each individual unit, and splits access between the public, persons with a legitimate interest and the authorities. The company that places the battery on the market keeps it accurate and up to date; the regulation prescribes no technology and does not mention blockchain.
Which batteries need a passport, and from when
The regulation covers every category of battery, but the passport applies to three. From the same date, every battery must carry a QR code (Art. 13(6)): for those three it opens the passport, and for the rest a shorter set of information.
| Battery category | What it covers | Passport | What the QR code opens |
|---|---|---|---|
| Electric vehicle battery | Traction batteries for cars, buses, vans, trucks and trailers, and batteries over 25 kg for L-category vehicles (Art. 3(1)(14)) | Yes | The passport |
| LMT battery | Sealed traction batteries of 25 kg or less, such as those of e-bikes and e-scooters (Art. 3(1)(11)) | Yes | The passport |
| Industrial battery above 2 kWh | Batteries for industrial uses, including stationary energy storage, and other batteries over 5 kg that are not EV, LMT or SLI (Art. 3(1)(13)) | Yes | The passport |
| Portable, SLI (starter) and industrial up to 2 kWh | All other batteries | No | Label information, declaration of conformity, due diligence report, waste information and, for SLI, recycled content |
The passport is individual: each battery placed on the market from that date gets its own record, with the data of its model and of that unit, including data resulting from its use (Art. 77(1) and (2)). Other dates shape its content:
| Obligation | Date | Legal basis |
|---|---|---|
| Passport and QR code | February 18, 2027 | Arts. 77(1) and 13(6) |
| Upload of each unique identifier to the EU registry, live since July 20, 2026 | When the battery is placed on the market | Art. 77(10) |
| Due diligence on cobalt, natural graphite, lithium and nickel (operators with a net turnover of EUR 40 million or more, alone or as part of a group) | August 18, 2027, postponed by Regulation (EU) 2025/1561 | Arts. 47 and 48(1) |
| Carbon footprint declaration, EV batteries | 12 months after its methodology and format acts, not adopted as of October 16, 2026 | Art. 7(1) |
| Recycled content documentation | August 18, 2028, or 24 months after its methodology act, whichever is later; LMT batteries, August 18, 2033 | Art. 8(1) |
| Act defining who has a legitimate interest | Due by August 18, 2026; Commission planning: fourth quarter of 2026 | Art. 77(9) |
So three public fields, responsible sourcing (taken from the due diligence report), carbon footprint and recycled content, will be filled in after the passport starts: build them into the data model from day one. The due diligence threshold may also rise: the Commission proposed EUR 150 million (COM(2025) 501), negotiators reached a provisional agreement on that package in June 2026, and Parliament had not voted on it in plenary as of October 16, 2026.
What data the passport contains and who can see it
Annex XIII lists the content and Article 77(2) sorts it into four access blocks:
| Block | Who can see it | What it includes |
|---|---|---|
| Model, public | Anyone | Label information; composition, including chemistry, hazardous substances and critical raw materials; carbon footprint; responsible sourcing; recycled and renewable content; capacity, voltage, power, expected lifetime and other performance values; declaration of conformity; waste information |
| Model, restricted | Persons with a legitimate interest, the Commission, notified bodies and market surveillance authorities | Detailed cathode, anode and electrolyte composition; part numbers and spare-part sources; dismantling information; safety measures |
| Model, compliance | Notified bodies, market surveillance authorities and the Commission | Test reports proving compliance |
| Individual battery | Persons with a legitimate interest | Performance values at placing on the market and at each status change; state of health; status (original, repurposed, re-used, remanufactured or waste); charge cycles, accidents and other negative events, operating temperature and state of charge |
Persons with a legitimate interest are those who need the data to repair, remanufacture, repurpose, dismantle or recycle the battery, and the purchaser who wants to offer an individual battery to independent energy aggregators or energy market participants (Art. 77(2)). An implementing act will name them and set how far they can download and reuse the data (Art. 77(9)). Access is free of charge (Art. 78(b)).
Who is responsible. The operator that places the battery on the market keeps the data accurate, complete and up to date and may authorize another operator in writing to act for it (Art. 77(4)); recital 125 cites a vehicle manufacturer as an example. Whoever places a re-used, repurposed or remanufactured battery back on the market takes over, with a new passport linked to the original; when the battery becomes waste, the producer or the waste management operator does (Art. 77(7)). The passport ceases to exist once the battery is recycled (Art. 77(8)). Authorized storage providers may not sell or reuse the data, and the passport must stay available if the responsible operator disappears (Art. 78(c) to (e)).
How it fits with the digital product passport and the EU registry
The battery passport is the first EU product passport with a firm date, and the digital product passport under the ESPR follows the same model: a decentralized data system run by economic operators (recital 126), fully interoperable with the other product passports (Art. 78(a)).
What is centralized is the registry. Article 13(1) of the ESPR requires the Commission's registry to store battery identifiers, and Implementing Regulation (EU) 2026/1778 applies its rules to the battery passport. The Commission launched the registry, with a testing environment, on July 20, 2026; operators register through a user interface or an API. The six harmonized standards for product passports (EN 18216 and EN 18219 to EN 18223), whose references were published in the Official Journal in July 2026, support the ESPR, and the standardization request behind them also covers batteries, so they are a sound basis for identifiers, data carriers, storage and APIs.
How to build a battery passport
A battery passport is a data product with five parts. This is the order in which we approach it at Unknown Gravity.
1. Identifier and QR code
Each battery gets a unique identifier that also enables a web link to its passport (Art. 3(1)(66)), compliant with ISO/IEC 15459, parts 1 to 6, or an equivalent (Art. 77(3)). The QR code is printed or engraved on the battery or, where that is not possible, on the packaging and accompanying documents (Art. 13(7)). Serialize at the end of the line, register each identifier in the EU registry and keep the link stable for the battery's whole life. Our guide to product traceability compares identification methods.
2. Data model
Start from Annex XIII and DIN DKE SPEC 99100 (edition 2025-02, free from DIN), which turns the legal content into data attributes and adds recommended ones. The Battery Pass project, which published the Battery Passport Content Guidance (last updated in December 2023), ended in March 2025; its work continues in BatteryPass-Ready, which publishes a matching data attribute longlist and an open data model (version 2.0, August 27, 2026). Separate model data, unit data fixed at production and unit data that change with use, and give each field an owner, a source system, an access level and a version history. The data must be machine-readable, structured, searchable and based on open standards, without vendor lock-in (Art. 77(5)).
3. Storage, API and access control
You, or a provider you authorize, serve the passport; the Commission does not host it. That means an API with an open public view, restricted views per access level, authentication of each requester and a log of who read or changed what, as Article 78(f) to (h) requires restricted write rights, data integrity and security. Add a continuity arrangement in case you or your provider disappear (Art. 78(e)), and test before going live: BatteryPass-Ready opened a test environment in June 2026.
4. Integration with ERP, MES and the battery management system
- ERP and PLM: model data, bill of materials, composition and declaration of conformity.
- MES: cell-to-pack genealogy, serial numbers and end-of-line tests, which give the initial performance values.
- Battery management system: since August 18, 2024 it must hold state-of-health data for EV, LMT and stationary storage batteries (Art. 14); it feeds the dynamic part, usually through telematics.
- After-sales and second life: repairs, status changes and hand-over to recyclers.
5. Raw material and supplier data
Much of the data comes from outside the company. Due diligence requires "a chain of custody or traceability system" identifying upstream actors (Art. 49(1)(d)) for cobalt, natural graphite, lithium and nickel (Annex X), verified by a notified body (Art. 48(2)). Carbon footprint is declared per model and plant (Art. 7(1)), and recycled content per model, year and plant (Art. 8(1)). Collect those supplier figures as signed, versioned evidence linked to batches, not as spreadsheets.
These are the same building blocks as a blockchain traceability system, with the battery rules on top; the ledger itself is optional, as the next section explains. The operator that places the battery on the market remains responsible for what the passport says.
Where a shared ledger or blockchain helps, and where it does not
The battery passport does not require blockchain. It requires open standards, interoperability, controlled access and data integrity, and it can run on a database, an API and a QR code. A shared ledger adds value where several companies that do not share a system must trust the same data:
- Raw material due diligence. Mine, refiner, cathode maker and cell maker record custody events and certificates in an append-only log that no single company controls.
- Carbon footprint and recycled content inputs. Recording the hash of each supplier declaration shows later that nobody changed it, which helps when a notified body or an authority asks for evidence.
- Passport versions and second life. A hash per version proves what was published and when, one way to meet Article 78(g); a shared event log links the new passport of a repurposed battery to the original one.
It does not help, or it gets in the way, here:
- The truth of the input. A ledger proves a record was not altered, not that the cobalt came from the declared mine. Audits and third-party verification solve that: the oracle problem.
- Putting the passport on a chain. Much of the data is restricted or commercially sensitive, usage data linked to an owner can be personal data, and the passport must cease to exist after recycling. The European Data Protection Board recommends storing personal data off-chain (Guidelines 02/2025, Recommendation 2): keep the passport data off-chain and put only hashes and events on-chain.
- One company alone. If all the data come from your own systems, a database with an audit log is enough.
Real cases and their status
Third-party projects, cited from their own announcements. Our article on blockchain in the supply chain covers more cases, including closed ones.
| Case | What the source says | Blockchain | Status |
|---|---|---|---|
| Volvo Cars, with CATL and LG Chem | Traceability of battery cobalt, with Circulor and Oracle, and with RSBN, RCS Global and IBM | Yes, according to Volvo Cars | Announced on November 6, 2019; current status not stated |
| Volvo EX90, with Circulor | Passport through the Volvo Cars app and a QR code on the door frame: origin of cobalt, nickel, graphite and lithium, pack carbon footprint and recycled content | Not stated | Announced by Circulor in 2024, with deliveries in the EU and the US that year |
| Honda Motor Europe, with Circularise | Collaboration on structuring and disclosing battery passport data ahead of 2027 | Not mentioned | Announced on June 10, 2026 |
| Global Battery Alliance | Proof of concept with example data from Audi and Tesla | Not mentioned | January 2023; the data were partly estimated, according to its disclaimer |
Volvo's 2019 cobalt traceability used blockchain; the two most recent passport announcements do not mention it.
Frequently asked questions
When does the EU battery passport become mandatory?
On February 18, 2027, for every electric vehicle battery, LMT battery and industrial battery above 2 kWh placed on the EU market or put into service from that date (Art. 77(1)). The QR code becomes mandatory on all batteries the same day (Art. 13(6)).
Which batteries do not need a passport?
Portable batteries, starter (SLI) batteries and industrial batteries of 2 kWh or less. They still need a QR code from February 18, 2027, leading to their label information, declaration of conformity, due diligence report and waste information (Art. 13(6)).
Does the battery passport require blockchain?
No. Regulation (EU) 2023/1542 asks for interoperability, controlled access and data integrity without naming a technology. Blockchain is an option to prove the integrity of data from several companies, not a requirement.
Does it apply to batteries made outside the EU?
Yes. The obligation follows the battery onto the EU market. The operator that places it there, often the importer, is responsible and must upload the identifier to the EU registry, although it can authorize the manufacturer in writing to act for it (Art. 77(4) and (10)).
What happens when a battery gets a second life or is recycled?
A re-used, repurposed or remanufactured battery gets a new passport linked to the original one (Art. 77(7)). Once the battery is recycled, the passport ceases to exist (Art. 77(8)).
Sources
- Regulation (EU) 2023/1542, consolidated text of August 13, 2026 (EUR-Lex)
- Regulation (EU) 2025/1561 (EUR-Lex)
- Proposal COM(2025) 501 (EUR-Lex) and procedure 2025/0130(COD) (European Parliament)
- Regulation (EU) 2024/1781, ESPR (EUR-Lex)
- Implementing Regulation (EU) 2026/1778, passport registry (EUR-Lex)
- Implementing Decision (EU) 2026/1736, harmonized standards (EUR-Lex)
- The Digital Product Passport Registry is now live (European Commission)
- Access rights to the battery passport, planned act (European Commission)
- Carbon footprint methodology for EV batteries, planned act (European Commission)
- DIN DKE SPEC 99100 (DIN)
- Battery Pass and BatteryPass-Ready publications
- Battery passport proof of concept (Global Battery Alliance)
- Cobalt traceability (Volvo Cars)
- Volvo EX90 battery passport (Circulor)
- Honda Motor Europe and Circularise (Circularise)
- Guidelines 02/2025 on blockchain (EDPB)
Framework checked on October 16, 2026. This article is for information only and is not legal advice. Dates of acts not yet adopted come from the Commission's planning and may change; always check the current text of Regulation (EU) 2023/1542 on EUR-Lex. Do you need to prepare the passport for your batteries? Talk to us.