In short
- It covers electric vehicle, light vehicle (e-bikes, e-scooters…) and industrial batteries above 2 kWh first sold in the EU from 18 February 2027.
- Whoever first sells the finished battery in the EU is responsible: often the importer or the assembler.
- Each battery needs a unique code, a QR code, its data and registration in the EU registry before it is sold.
- Much of the data is held by your supplier: request it now and put it in writing in the contract.
Updated:
Does it affect you?
It affects you if you sell for the first time in the EU (or start using yourself) a battery in one of three categories: electric vehicle; light vehicle, such as e-bikes, e-scooters or some light e-motorbikes; or industrial above 2 kWh, for example home and business energy storage. Portable and car starter batteries do not need a passport.
The date applies to each battery: those first sold in the EU from 18 February 2027 must have one, even if the model was sold before.
Who is responsible: the importer, the manufacturer or the assembler?
The company that first sells the finished battery in the EU is responsible. In practice:
If you import finished batteries from outside the EU, you are usually responsible, even though you did not make them.
If you import a product with the battery already installed (for example an e-bike or equipment with an industrial battery), you may also be the one responsible.
If you import the loose parts and assemble the battery yourself, the parts do not carry a passport, but you become the manufacturer of the finished battery.
If you sell under your own brand or modify the battery, the rules treat you as the manufacturer. The European Commission's FAQ, which is guidance, explains it the same way.
An example
Imagine a company that imports e-bike batteries from China and sells them under its own brand to shops in several EU countries. Under the rules it is the manufacturer: it must give a passport to every battery it sells from 18 February 2027, even though its supplier holds the technical data. Its job is to obtain that data, check it, decide who hosts the passports and register them in the EU registry before selling.
What you need
A unique code for each battery, following an international identification standard (ISO/IEC 15459) or equivalent.
A QR code on the battery linking to its passport. If it does not fit, on the packaging and documents.
The passport data, in three groups: general model data (who makes it, what it is made of, weight, capacity, hazardous substances…), performance and durability data, and per-unit data that changes with use, such as its state of health when the battery has an electronic control system. The Commission publishes a list of 71 possible data points, and not all apply to every battery.
Three access levels: a public part, a part for those with a legitimate interest (repairers, recyclers…) and a part for the authorities.
The step almost nobody knows: the EU registry
Besides creating the passport, it must be registered in the European Commission's passport registry before the battery is sold. To register, your company must first verify its identity with a qualified electronic identification, such as a company electronic seal.
The registry does not store the passport: it stores the code and the link. The passport is hosted by your company or the provider you choose, and must remain available even if the company ceases to exist.
What depends on your suppliers
Much of the data is only held by whoever makes the battery or its components: composition, performance or how it is dismantled. If you import from outside the EU, request it now and state in the contract who provides it, in what format and how it is updated. You can authorise another company in writing to manage the passport on your behalf, but you remain responsible.
What already applies today
The passport arrives in 2027, but other obligations under the same rules already apply: the EU declaration of conformity and CE marking, performance and durability documentation for light vehicle, electric vehicle and rechargeable industrial batteries above 2 kWh, and information on collection and waste. In addition, in each country where you sell, whoever first makes the battery available usually has to register as a producer. Checking this now avoids surprises when the passport arrives.
What is still pending
As of this guide (November 2026), some pieces are not settled: the Commission had not yet opened battery registration in the registry, the rule detailing who can see restricted information is still missing, and data such as the carbon footprint will come later. That is why it makes sense to prepare the data that will not change now and review the rest every few weeks.
Where to start
1. List the battery models you sell and classify each one in its category.
2. Clarify your role in each case: importer, manufacturer or assembler.
3. Check which data you already have and which you need to request from your supplier.
4. Decide who will host the passports and who will keep them up to date.
5. Prepare your company's verification in the EU registry.
If you would rather not do it alone, tell us what you sell and we will tell you whether it affects you, what is missing and where to start.
Your questions, answered
Do I need one passport per model or per battery?
Per battery. Each unit has its own unique identifier and passport, although much of the data is shared by batteries of the same model.
My supplier says they will handle the passport. Is that enough?
It can help, but if you are the one placing the battery on the EU market, the responsibility is yours. Authorise them in writing and make sure you can check that the data is correct and up to date.
Are there penalties if it is not ready?
Penalties are set by each Member State. In practice, without a passport the battery does not comply with the rules and its sale may be blocked.