Industrial Battery Passports: What Stationary Storage and UPS Battery Manufacturers Must Prepare

From 18 February 2027, every industrial battery above 2 kWh placed on the market or put into service in the EU must carry an industrial battery passport. That requirement comes from Article 77(1) of Regulation (EU) 2023/1542. If you manufacture stationary storage systems, grid-connected battery energy storage systems, or UPS batteries that exceed 2 kWh, this article explains what the passport must contain, who is responsible for it, and what data you need to collect before that date.

Which industrial batteries need a passport

Article 3(1), point (13), of Regulation (EU) 2023/1542 defines an industrial battery as a battery specifically designed for industrial uses, one intended for industrial uses after preparation for repurposing or repurposing, or any other battery weighing more than 5 kg that is not an electric vehicle, LMT or SLI battery. Article 3(1), point (15), states that every stationary battery energy storage system is an industrial battery, including systems that store energy from and deliver it to the grid.

UPS batteries and batteries for automated guided vehicles are assessed under the Article 3(1), point (13), definition. If a UPS battery is specifically designed for industrial use, or weighs more than 5 kg and is not an EV, LMT or SLI battery, it is an industrial battery. The passport obligation then applies only if that battery exceeds 2 kWh, as Article 77(1) sets that threshold.

Recital 15 of the Regulation adds that traction batteries for off-road machinery and batteries for energy storage in private or domestic environments are also industrial batteries. Recitals are not binding, but they reflect the legislature’s intent when the definition is ambiguous.

The old framework under Directive 2006/66/EC was repealed with effect from 18 August 2025 under Article 95 of Regulation (EU) 2023/1542. There is no equivalent passport obligation in the old directive to carry forward.

What one passport covers

Article 3(1), point (1), defines a battery as consisting of one or more cells, modules or packs of them. A battery energy storage system placed on the market as one industrial battery above 2 kWh therefore needs one passport under Article 77(1).

Under Article 1(4), cells or modules made available on the market for end use, without further incorporation or assembly into larger battery packs or batteries, are treated as batteries placed on the market and must meet the requirements of the most similar battery category. The Regulation does not say how a replacement module is treated under Article 1(4), so confirm with your market surveillance authority whether a spare module you supply counts as a separate battery.

If your product is a complete system sold as a single battery, one passport covers it. If you supply cells or modules to another manufacturer, Article 39 requires you to provide, free of charge, the information and documentation that manufacturer needs to comply with the Regulation.

What the industrial battery passport must contain

Annex XIII of Regulation (EU) 2023/1542 sets out the data categories. Article 77(2) states that Annex XIII applies to each passport category only to the extent applicable, so not every field applies equally to every battery type. The four points in Annex XIII cover: point 1, information on the battery model accessible to the public; point 2, information on the battery model accessible only to persons with a legitimate interest and the Commission; point 3, test report results accessible only to notified bodies, market surveillance authorities and the Commission; and point 4, information and data on the individual battery accessible only to persons with a legitimate interest.

For industrial batteries above 2 kWh, the following Annex XIII fields are directly relevant.

• General information (point 1(a)): This brings in Annex VI, Part A, which covers manufacturer identification, battery category, place and date of manufacture, weight, capacity, chemistry, hazardous substances, usable extinguishing agent and critical raw materials.
• Hazardous substances (point 1(b)): The passport must include the hazardous substances present in the battery, other than mercury, cadmium or lead, classified under Regulation (EC) No 1272/2008, as defined in Article 3(1), point (52), of Regulation (EU) 2023/1542. This is not a REACH SVHC declaration.
• Carbon footprint (point 1(c)): This follows Article 7(1). For rechargeable industrial batteries other than those with exclusively external storage, the obligation applies from 18 February 2026 or 18 months after the relevant delegated and implementing acts enter into force, whichever is later.
• Responsible sourcing (point 1(d)): This follows the due diligence obligations in Article 48(1), which apply from 18 August 2027. Operators excluded by Article 47 are not subject to those obligations.
• Recycled content (point 1(e)): This follows Article 8(1). For industrial batteries above 2 kWh other than those with exclusively external storage, the obligation applies from 18 August 2028 or 24 months after the relevant delegated act enters into force, whichever is later.
• State of health (point 4(b)): Article 14 covers stationary battery energy storage systems. Among industrial batteries, state of health information in the passport applies only to stationary battery energy storage systems, because Article 14 does not extend to other industrial batteries.
• Battery status (point 4(c)): This includes a waste status value. Once a battery reaches end of life, the status field reflects that.

The Commission has published a non-binding guidance document on Digital Battery Passport data points by category, Version 2.0 of 15 August 2026. That document identifies 32 mandatory data points for industrial batteries above 2 kWh for February 2027. Those figures come from the guidance document, not from Regulation (EU) 2023/1542 itself, and the document states that it does not extend the rights and obligations in the legislation.

Who is responsible for the passport and for how long

Article 77(4) requires the economic operator placing the battery on the market to keep the passport accurate, complete and up to date. Article 78(e) keeps the passport available even after that operator ceases to exist or ceases its activity in the Union.

Responsibility shifts in two specific situations under Article 77(7). First, if a battery undergoes preparation for re-use, preparation for repurposing, repurposing or remanufacturing and is then placed on the market or put into service again, the operator carrying out that activity takes responsibility. That battery receives a new passport linked to the original. Second, once the battery becomes waste, responsibility moves to the producer, its producer responsibility organisation, or the selected waste management operator.

The passport ends when the battery has been recycled. Article 77(8) sets that rule. Article 78(e) separately requires the passport to remain available if the responsible operator ceases to exist or ceases its activity in the Union.

The data you need to collect now

18 February 2027 is the date that matters for placing batteries on the market or putting them into service. Several data fields have their own later dates, but the passport itself must exist from that date. Here is what you need to prepare.

1. Battery model data: Collect the Annex VI, Part A, information for each product line: manufacturer identification, battery category, place and date of manufacture, weight, capacity, chemistry, hazardous substances, usable extinguishing agent and critical raw materials. Voltage is a separate Annex XIII, point 1(h), field.
2. Hazardous substance classifications: Identify the hazardous substances present in the battery, other than mercury, cadmium or lead, as classified under Regulation (EC) No 1272/2008. This is a classification exercise, not a REACH SVHC screening.
3. Carbon footprint declaration: For rechargeable industrial batteries, the Article 7(1) obligation applies from 18 February 2026 or 18 months after the relevant acts enter into force. If those acts are already in force, your carbon footprint declaration should already be in preparation.
4. Responsible sourcing documentation: Article 48(1) applies from 18 August 2027. You have time, but the due diligence process takes months to build. Start mapping your supply chain now.
5. State of health parameters (stationary systems only): If you manufacture stationary battery energy storage systems, Article 14 requires state of health data. Define how your battery management system will report the point 4(b) parameters.
6. Cell and module supplier data: Use Article 39 to formally request the information and documentation you need from upstream suppliers. Put that request in writing and keep records.

Industrial battery passport: the lifecycle dimension

The passport is not a one-time filing. Article 77(4) requires it to stay accurate and up to date throughout the battery’s life. For stationary storage systems, that means updating state of health data (point 4(b)) as the battery ages. For any battery that is repurposed or remanufactured, Article 77(7) requires a new passport linked to the original.

The status field at Annex XIII, point 4(c), must reflect the battery’s current status, defined as original, repurposed, re-used, remanufactured or waste. Once the battery enters the waste stream, the responsible party changes. Once it is recycled, the passport closes under Article 77(8).

This lifecycle structure means your data management system must be able to receive updates, link new passports to originals, and transfer access rights when responsibility shifts. A static document approach will not meet Article 77(4).

How the industrial battery passport connects to broader compliance

The passport sits inside a wider set of obligations under EU Battery Regulation 2023/1542: Complete Guide for Manufacturers. Carbon footprint, recycled content, due diligence, and state of health are each governed by separate articles with separate timelines. The passport is the delivery mechanism that makes all of that information accessible to the right parties at the right access level.

Market surveillance authorities and notified bodies access the test report results at Annex XIII, point 3. Persons with a legitimate interest, such as repairers, remanufacturers, second-life operators and recyclers, access the individual battery data at Annex XIII, point 4. The public accesses the model-level information at Annex XIII, point 1. Your system must enforce those access tiers from day one.

If you want to see how a compliant industrial battery passport works in practice before February 2027, register for a free trial and test your data against the Annex XIII requirements with real product data from your own catalogue.