What Has Been Confirmed
The European Commission has reaffirmed that the battery passport obligation under Article 77 of the EU Battery Regulation (2023/1542) enters into force on February 18, 2027. There will be no postponement or transitional period. From that date, every EV battery, LMT battery, and industrial battery with a capacity above 2 kWh placed on the EU single market must carry a compliant, machine-readable battery passport.
This confirmation follows months of industry speculation about potential delays. The Commission has been clear: the timeline is fixed. Manufacturers, importers, and distributors who are not prepared by February 2027 will face market access restrictions.
What the Passport Must Contain
Annex XIII of the regulation specifies the mandatory data fields, organised into six categories:
- General information — Manufacturer identity, battery model, chemistry type, rated capacity, voltage, weight, and manufacturing date and location
- Carbon footprint — Declared carbon footprint per kWh over the battery lifecycle, calculated using the EU Product Environmental Footprint methodology
- Recycled content — Percentages of recycled cobalt, lithium, nickel, and lead, with pre-consumer and post-consumer breakdowns
- Performance and durability — Rated capacity, expected cycle life, energy round-trip efficiency, internal resistance, and state of health parameters
- Hazardous substances — REACH SVHC declarations with CAS numbers, concentration ranges, and safe use instructions
- Supply chain due diligence — Raw material sourcing policies, third-party audit status, and responsible sourcing documentation aligned with OECD Due Diligence Guidance
Who Is Affected
The obligation applies to all economic operators as defined under the regulation — manufacturers, importers, and distributors. If you place a battery on the EU market, you share responsibility for ensuring a compliant passport accompanies it. For batteries manufactured outside the EU, the importer becomes the responsible party if the manufacturer has not created a passport.
What Happens If You Are Not Ready
Batteries placed on the EU market after February 18, 2027 without a compliant passport will be considered non-compliant. Market surveillance authorities in each EU Member State have the power to order product withdrawal, block imports at customs, and impose financial penalties. The severity of penalties varies by Member State, but the market access restriction alone — the inability to legally sell the product in the EU — represents the most significant commercial risk.
Recommended Actions
- Conduct a gap analysis of your current product data against Annex XIII requirements
- Engage suppliers for upstream data (raw material origin, carbon footprint, recycled content certificates)
- Select a DPP platform that supports battery passport creation, GS1 Digital Link QR codes, and EU Central Registry integration
- Create and publish your first battery passport as a pilot, using your highest-volume product
- Establish a quarterly review cadence to ensure data remains current