EU Battery Passport 2027 Deadline: What Manufacturers and Importers Must Do

From 18 February 2027, an EV battery, an LMT battery or an industrial battery with a capacity above 2 kWh without a compliant digital passport cannot legally be placed on the EU market or put into service. The obligation comes from Regulation (EU) 2023/1542 (Article 77(1)), and it falls on whichever economic operator places the battery on the market, manufacturer or importer (Article 77(4)). The EU battery passport 2027 deadline is written into the regulation itself, so it does not depend on a future Commission decision: only an amending regulation adopted by the European Parliament and the Council could move it, and none of the proposals to amend the regulation pending on 26 September 2026 would do so. This article sets out which batteries are covered, what data the passport must carry, who is legally responsible, and the practical steps to be ready in time.

The EU battery passport 2027 deadline, in plain terms

18 February 2027 is a hard statutory date written directly into Regulation (EU) 2023/1542. It is not subject to a separate Commission decision and it is not a target that phases in gradually. From that date, batteries in the covered categories that do not have a compliant passport cannot be placed on the EU market or put into service. For the legal text, the authoritative source is Regulation (EU) 2023/1542 on EUR-Lex.

Some related requirements under the same regulation follow different timelines. Specific recycled content targets and carbon footprint performance classes have their own phased implementation dates, several of which depend on delegated acts the Commission has yet to adopt. Do not confuse those phased targets with the passport itself. The passport deadline of 18 February 2027 is confirmed. For the full scope of obligations, including performance, labelling, and end-of-life rules, see our overview of the EU Battery Regulation 2023/1542.

Which batteries need a passport

Article 77 covers three battery categories:

• All EV (traction) batteries, regardless of capacity
• All light means of transport (LMT) batteries, defined in Article 3(1), point (11), as sealed batteries of 25 kg or less designed to provide traction power to wheeled vehicles such as e-bikes and e-scooters, other than electric vehicle batteries
• Industrial batteries with a capacity above 2 kWh

Portable batteries, SLI batteries, and industrial batteries of 2 kWh or below fall outside the Article 77 passport requirement. If you are unsure which category a product sits in, check it against the definitions in Article 3(1), points (9) to (14), of the regulation (the 2 kWh threshold applies to industrial batteries only, and point (11) defines LMT batteries). Document that assessment, because a market surveillance authority can require you to provide the documents and information that show your battery complies (Article 14(4), point (a), of Regulation (EU) 2019/1020).

What the passport must contain

Annex XIII of the regulation sets out the information the passport must contain, to the extent applicable to the category of battery concerned (Article 77(2)). Not all of it is due on 18 February 2027: the Commission’s guidance document, Digital Batteries Passport data points by category (Version 2.0, 15 August 2026), marks the carbon footprint, responsible sourcing and recycled content information as not to be filled or displayed as of February 2027. The passport covers, among others:

• Battery identification and manufacturer details: unique identifier, model, manufacturing location, and the economic operator responsible for placing the battery on the market
• Carbon footprint information: the carbon footprint declaration and performance class under Article 7(1) and (2) (Annex XIII, point 1(c)), calculated with a methodology that the Commission is to set by delegated act on the basis of the essential elements in Annex II. As of 26 September 2026 that delegated act has not been adopted, so the declaration does not yet apply
• Recycled content information: the shares of cobalt, lithium and nickel present in active materials that were recovered from battery manufacturing waste or post-consumer waste, and the share of lead present in the battery that was recovered from waste, as contained in the Article 8(1) documentation (Annex XIII, point 1(e)). For EV batteries and industrial batteries above 2 kWh (other than those with exclusively external storage) that contain cobalt, lead, lithium or nickel in active materials, that documentation is required from 18 August 2028 or 24 months after the Commission’s methodology delegated act enters into force, whichever is later, and for such LMT batteries from 18 August 2033; the delegated act has not been adopted as of 26 September 2026
• State of health parameters: data that allows assessment of remaining capacity and performance over the battery’s life
• Hazardous substances: the hazardous substances present in the battery, other than mercury, cadmium or lead (Annex XIII, point 1(b)), meaning substances classified as hazardous under Article 3 of Regulation (EC) No 1272/2008 (Article 3(1), point (52)). The regulation sets no concentration threshold for them and does not refer to REACH substances of very high concern; a Commission proposal of 10 December 2025 (COM(2025) 981) would change the label entry to substances of very high concern present at 0.1% weight by weight or more, but as of 26 September 2026 it has not been adopted
• Responsible sourcing information: information on responsible sourcing as indicated in the report on the battery due diligence policy that the economic operator must review and publish every year under Article 52(3) (Annex XIII, point 1(d)). The due diligence obligations apply from 18 August 2027 (Article 48(1)), and operators with a net turnover below EUR 40 million in the financial year preceding the last financial year, not part of a group exceeding that limit on a consolidated basis, are excluded (Article 47)

Each category demands active data collection from your supply chain. Recycled content figures come from your material suppliers. The carbon footprint calculation must use activity data for the anode, cathode, electrolyte, separator and cell casing that refers to the specific battery model and manufacturing plant, with no default activity data, combined with PEF-compliant secondary datasets (Annex II, point 5). Hazardous substance information depends on how the substances in the battery are classified, which suppliers of hazardous substances and mixtures must set out in safety data sheets (Article 31(1) of Regulation (EC) No 1907/2006). It must all be documented and verifiable, so allow ample time for the data-gathering phase.

How the passport is accessed

The regulation requires the passport to be accessible through a QR code (Articles 13(6) and 77(3) of Regulation (EU) 2023/1542), printed or engraved visibly, legibly and indelibly on the battery or, where that is not possible or not warranted on account of the nature and size of the battery, affixed to its packaging and to the documents accompanying it (Article 13(7)). The QR code links to a unique identifier that the economic operator placing the battery on the market attributes to the passport, and the QR code and the unique identifier must comply with ISO/IEC 15459, parts 1 to 6, or their equivalent (Article 77(3)). What rules out a static PDF or a generic product webpage is Article 77(5): the passport information must be based on open standards and be in an interoperable format that is machine-readable, structured and searchable. One passport also serves several audiences through the same code, at different access levels: some information is public, some is accessible only to notified bodies, market surveillance authorities and the Commission, and some only to persons with a legitimate interest, such as repairers, second-life operators and recyclers (Article 77(2)). The regulation does not prescribe GS1 Digital Link or any other particular identifier scheme; you can read more in our explainer on the GS1 Digital Link standard.

In short, you need a backend capable of hosting passport data in a structured format and linking it to a unique, persistent identifier for each battery unit, with a QR code that stays legible throughout the battery’s life.

Who is legally responsible

The obligation falls on the economic operator that places the battery on the EU market (Article 77(3) and (4)). For a manufacturer based inside the EU that places its batteries on the market, that is the manufacturer. For a battery imported from a manufacturer based outside the EU, it is the importer: the person established in the Union who places a battery from a third country on the market (Article 3(1), point (64)). No transfer is involved. The importer is itself the operator placing the battery on the market, so it must ensure that the passport information is accurate, complete and up to date (Article 77(4)) from the moment the battery is placed on the market (Article 77(1)).

This reshapes supply chain contracts. If you are a European importer sourcing batteries from a maker in Asia or North America, you cannot hand the responsibility to that maker. You may give it, or any other operator, written authorisation to act on your behalf (Article 77(4)), but the liability stays with you. You need contractual terms that require your supplier to deliver all the Annex XIII data in a format you can actually use to build and maintain the passport. An authorised representative appointed by a non-EU manufacturer does not change this: its mandate covers tasks relating to the manufacturer’s obligations under Chapters IV and VI of the regulation (Article 3(1), point (63)), while the battery passport sits in Chapter IX, so the importer placing the battery on the market remains responsible for it.

Where the battery passport sits in the wider DPP picture

The EU battery passport 2027 deadline is the first binding Digital Product Passport deadline, but it is not the last. The Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781 (ESPR), establishes a horizontal digital product passport framework and, under its Article 13, a central EU registry that the Commission was required to set up by 19 July 2026 and that is also to store battery identifiers (Article 13(1)). Implementing Regulation (EU) 2026/1778 of 16 July 2026 lays down the arrangements for that registry; as of 26 September 2026 it does not yet accept battery registrations. Product-specific DPP rules will then arrive through delegated acts, group by group, on their own timelines.

The practical takeaway: the data discipline you build for batteries is reusable. A platform designed around one regulation will leave you re-tooling for the next. Read more about the ESPR framework to see how the battery passport fits the broader trajectory.

Preparing for the EU battery passport 2027 deadline: a step-by-step plan

Working backwards from the deadline, here is a practical sequence:

1. Confirm which products are in scope. Check each battery’s category and, for industrial batteries, whether its capacity exceeds 2 kWh (Article 77(1)), and record your assessment.
2. Map your supply chain data requirements. Identify which suppliers must provide recycled content data, carbon footprint inputs, the material composition of the battery, and due diligence records. Every Annex XIII field needs a named source.
3. Update supplier contracts. Add data-provision obligations for each Annex XIII field. Specify format, update frequency, and what happens when data is late or incomplete.
4. Select a passport platform. You need a system that stores structured battery data, generates QR codes linking to a unique identifier that complies with ISO/IEC 15459 or an equivalent standard (Article 77(3); the regulation does not prescribe GS1 Digital Link or any other particular scheme), and maintains a persistent link between each physical unit and its digital record. Judge platforms on these technical requirements, not feature lists. If it helps to see those requirements demonstrated against a real battery, you can walk through them on a short demo (see below).
5. Prepare for the carbon footprint declaration. It is not due on 18 February 2027. Under Article 7(1) it applies 12 months (EV batteries) or 18 months (rechargeable industrial and LMT batteries) after the later of two Commission acts enters into force, a delegated act on the calculation methodology and an implementing act on the declaration format, and not before 18 August 2028 for LMT batteries or 18 August 2030 for rechargeable industrial batteries with external storage. As of 26 September 2026 neither act has been adopted, and Annex II sets out only the essential elements the methodology must build on. The data work is still long, so start collecting bill-of-materials and energy data for each battery model and plant now.
6. Run a compliance check before go-live. Confirm that every required field is populated, the QR code resolves correctly, and the data is accessible to the parties who need it, including market surveillance authorities.

Common mistakes to avoid

Several errors are predictable from the structure of the regulation.

• Treating the passport as a document rather than a data system. A PDF behind a QR code does not meet the requirement. The passport information must be in an interoperable format that is machine-readable, structured and searchable (Article 77(5)), reached through a QR code that, like the unique identifier it links to, complies with ISO/IEC 15459 or an equivalent standard (Article 77(3)), because authorities and other users need to query specific fields, not read a file.
• Assuming your supplier will handle it. If you are an EU importer, you are the economic operator placing the battery on the market, and Article 77(4) makes you responsible for the passport. A supplier’s willingness to cooperate is a commercial matter; your legal obligation is not conditional on it.
• Conflating the passport with CE marking. The battery passport is a separate obligation from conformity assessment. Both are required, but they involve different data and processes.
• Underestimating carbon footprint lead time. A battery lifecycle assessment needs primary data from multiple supply chain tiers. If your suppliers have not done this work, the declaration cannot be completed. Allow roughly 12 months if you are starting from scratch.
• Confusing the passport’s hazardous substance list with REACH duties. The passport lists the hazardous substances present in the battery, other than mercury, cadmium or lead, meaning substances classified as hazardous under Regulation (EC) No 1272/2008 (Annex XIII, point 1(b), and Article 3(1), point (52)), and sets no concentration threshold for them. REACH duties run alongside: a supplier of an article containing a candidate-list substance of very high concern above 0.1% weight by weight must give the recipient enough information to allow safe use (Article 33(1) of Regulation (EC) No 1907/2006), and the Court of Justice has held that for a product made of several articles, such as a battery pack, the threshold applies to each constituent article (Case C-106/14). A substance at 0.05% of the finished pack can therefore still trigger the REACH duty if it exceeds 0.1% of a sub-component.

What happens if you miss the EU battery passport 2027 deadline

Under Article 93, the regulation requires member states to lay down the rules on penalties applicable to infringements, and those penalties must be effective, proportionate and dissuasive. The specific amounts are set by each member state, so there is no single figure to quote. Because penalties are set per member state, a non-EU manufacturer selling across several member states faces a patchwork of national enforcement regimes through its importers, rather than one harmonised penalty.

What is consistent across every member state is the market consequence: from 18 February 2027, an EV battery, LMT battery or industrial battery above 2 kWh without a compliant passport cannot be placed on the EU market or put into service (Article 77(1)). Products entering the EU are subject to risk-based controls by the authorities each member state designates (Article 25 of Regulation (EU) 2019/1020). Their release for free circulation is suspended where, for example, a product is not marked or labelled as Union law requires, and refused where market surveillance authorities conclude that it does not comply (Articles 26 and 28 of that regulation), and batteries already on the market can be withdrawn or recalled (Article 16 of that regulation). That refusal is operational rather than financial. It stops the shipment, which is often the more immediate commercial risk than the penalty itself.

How Traceable helps you hit the deadline

Traceable is a digital product passport compliance platform built for EU importers and manufacturers placing EV batteries, LMT batteries and industrial batteries above 2 kWh on the market, the economic operators on whom Article 77(4) places the passport duty. Our AI-assisted extraction reads the supplier documents your team uploads, in PDF, PNG or JPG format, and proposes values for the Annex XIII fields it can find in them, which you review and approve, with a High, Medium or Low confidence rating on every extracted value so you can see what to double-check; how much it can fill depends on what the documents contain and on their quality. A compliance gap score flags every Annex XIII field that is still empty or unvalidated before you publish, so an incomplete passport cannot go live unnoticed.

Because the liability sits with you, Traceable gives you a supplier portal to request the recycled-content, carbon-footprint and material-composition data each Annex XIII field needs directly from the suppliers who hold it, in a structured, auditable way. The gathering you mapped in step 2 happens inside one system, and you control the record even when the data originates upstream. We generate GS1 Digital Link QR codes, run schema and structure validation on the passport, and give verifiers and authorities controlled access to the record. The same engine also supports textile products today, so the data discipline you build for batteries carries over as ESPR product rules arrive.

You can start with the free trial and map your first battery passport before committing to a paid plan, so you can validate the approach against your own data. AI document extraction is not included in any plan or the free trial: it is billed separately, based on the number of documents processed. Carbon footprint assessments alone can take around 12 months from a standing start, although the declaration will apply only once the Commission’s methodology and format acts are in force (Article 7(1)). Counting back from 18 February 2027, fewer than five months remain as of 26 September 2026, so the practical window to begin gathering supplier data is now, not next quarter. Start now, close your data gaps early, and the passport becomes a routine output rather than a last-minute scramble.

Two ways to start: book a 20-minute demo to see AI extraction propose values for the Annex XIII fields from your own supplier documents, or start the free trial and map your first battery passport today.