Per-Unit vs Per-Model Battery Passport: What EU Regulation 2023/1542 Actually Requires

One of the most common questions compliance managers ask about the EU battery passport is whether they need one passport per battery model or one passport per individual battery unit. Regulation (EU) 2023/1542 gives a clear answer: one passport per unit, but that passport carries both model-level and unit-level data. Understanding how those two layers work together is what this article explains.

Which Batteries Need a Passport From 18 February 2027

Article 77(1) of Regulation (EU) 2023/1542 requires each light means of transport (LMT) battery, each industrial battery with a capacity above 2 kWh, and each electric vehicle (EV) battery placed on the market or put into service to have its own battery passport. The duty starts on 18 February 2027.

Article 3(1), point (19), defines a battery model as “a version of a battery all units of which share the same technical characteristics relevant for the requirements of this Regulation on sustainability, safety, labelling, marking and information, and the same model identifier.” That definition matters because it draws the line between what is model data and what is unit data inside each passport.

A batch number does not replace a passport. Article 77(1) requires each battery to have a passport, and Article 77(3) links that passport to a unique identifier attributed to that specific battery. Separately, Article 38(6) has required manufacturers to mark batteries with a model identification and a batch or serial number, product number, or another identifying element since 18 August 2024. Those markings support traceability but do not substitute for the per-unit passport obligation.

Per-Unit vs Per-Model Battery Passport: How the Two Layers Sit Inside One Record

Every battery in scope gets its own passport. That passport holds two categories of information, set out in Annex XIII of the Regulation.

Points 1 to 3 of Annex XIII cover the battery model. Point 4 covers the individual battery. Article 77(2) states that the passport must contain “information relating to the battery model and information specific to the individual battery, including resulting from the use of that battery, as set out in Annex XIII.”

In practice, this means the same model-level fields appear in every unit passport for batteries of that model, while the unit-level fields differ from battery to battery. You do not create one shared model record and link units to it instead of giving them passports. You create one passport per unit, and that passport contains both layers.

What Goes in the Model Layer

Annex XIII, point 1, lists information on the battery model that is accessible to the public. Point 1(a) incorporates Annex VI, Part A, which lists general information including the date of manufacture at point 4 of that Annex. The date of manufacture therefore counts as model information, not unit information, under the Regulation’s structure.

Point 1(b) covers the material composition of the battery, including its chemistry, hazardous substances present other than mercury, cadmium or lead, and critical raw materials present. Point 1(c) covers carbon footprint information, but only once Article 7 of the Regulation applies to the battery in question. Point 1(e) covers recycled content information, but only once Article 8 applies. If those articles have not yet started to apply to your battery category, you do not include those fields.

Points 2 and 3 of Annex XIII hold model-level information with restricted access. Under Article 77(2), point 2 is accessible to notified bodies, market surveillance authorities and the Commission, and separately to persons with a legitimate interest. Point 3 holds test report results accessible only to notified bodies, market surveillance authorities, and the Commission. Article 77(2) sets these access groups.

What Goes in the Unit Layer

Annex XIII, point 4, covers information and data on the individual battery. It is accessible only to persons with a legitimate interest, as set out in Article 77(2).

Point 4(b) places state of health data in the individual battery layer. State of health changes over the battery’s life, so it cannot be a fixed model attribute. Article 14(1) has required state of health data in the battery management system of stationary battery energy storage systems, LMT batteries, and EV batteries since 18 August 2024. That requirement predates the passport obligation by more than two years, meaning manufacturers in those categories should already be capturing this data at unit level.

Point 4(a) covers rated capacity for the individual battery. The Commission guidance document on Digital Battery Passport data points by category, Version 2.0 of 15 August 2026 (a non-binding document that states it does not extend the rights and obligations in the legislation), notes that this data point is “same as data point 11 (capacity), but now dynamic” for EV and LMT batteries, reflecting that capacity can change with use.

Point 4(d) covers usage data for the individual battery. This is the kind of information that accumulates during operation and that second-life assessors and recyclers need to evaluate a battery at end of life.

How the QR Code Connects Each Unit to Its Passport

Article 77(3) makes each battery’s passport accessible through the QR code required by Article 13(6). That QR code links to a unique identifier that the economic operator placing the battery on the market attributes to that battery.

The QR code and the unique identifier must comply with ISO/IEC 15459-1:2014, 15459-2:2015, 15459-3:2014, 15459-4:2014, 15459-5:2014, and 15459-6:2014, or their equivalent. These are the GS1 and AIDC standards for unique identification of transport units and individual items.

Article 13(7) sets out where the QR code must appear. The default is that it is printed or engraved on the battery itself. Where that is not possible or not warranted, it must be affixed to the packaging and to the accompanying documents. The QR code duty applies from 18 February 2027, the same date as the passport obligation under Article 13(6).

The consequence of this structure is that every battery leaving your facility from that date needs a scannable QR code that resolves to a live passport record containing both the model layer and the unit layer for that specific battery.

What This Means for Your Data Architecture

Many manufacturers assume they can create one master record per model and attach a list of serial numbers to it. The Regulation does not permit that approach as a substitute for individual passports. Article 77(1) is explicit: each battery has a passport. Article 77(3) is explicit: each passport is linked to a unique identifier attributed to that battery.

A practical architecture has three components. First, a model data store that holds the Annex XIII, points 1 to 3, fields for each battery model. Second, a unit data store that holds the Annex XIII, point 4, fields for each individual battery, updated as the battery moves through its life. Third, a passport record per unit that combines both, accessible via the QR code unique identifier, with access controls that match the groups set out in Article 77(2).

The EU Battery Regulation 2023/1542 compliance page on the Traceable platform sets out how these three components map to the platform’s data model, including how the access tiers for Annex XIII points 1, 2, 3, and 4 are enforced separately for each passport.

Common Misunderstandings to Avoid

First, the date of manufacture is model information, not unit information, because point 1(a) of Annex XIII incorporates Annex VI, Part A, point 4. If your system stores manufacture date only at unit level, you may need to restructure.

Second, carbon footprint and recycled content fields are conditional. Point 1(c) and point 1(e) of Annex XIII apply only once Article 7 and Article 8 respectively apply to your battery category. Do not include placeholder values before those articles apply.

Third, the batch marking requirement under Article 38(6) and the passport requirement under Article 77(1) are separate obligations. Complying with one does not satisfy the other. Article 38(6) has applied since 18 August 2024. Article 77(1) applies from 18 February 2027.

Fourth, state of health is a living data point. It belongs in Annex XIII, point 4(b), and must be updated as the battery is used. A passport that records state of health only at the moment of manufacture does not meet the requirement that the passport contain “information and data resulting from its use,” as Annex XIII, point 4(d), describes it.

Access Rights Across the Two Layers

Article 77(2) sets four access groups across the four points of Annex XIII. Point 1 is public. Points 2 and 3 are accessible to notified bodies, market surveillance authorities, and the Commission. Points 2 and 4 are accessible to persons with a legitimate interest. Annex XIII has four numbered points, and your system must enforce access at that level of granularity.

Persons with a legitimate interest include, for example, repairers, second-life operators, and recyclers who need point 4 data to assess a battery’s remaining value. Your passport system must be able to authenticate those users and grant them access to points 2 and 4 without exposing point 3 data, which is reserved for conformity assessment bodies and authorities.

Summary of Key Dates

• 18 August 2024: Article 38(6) batch and model marking requirement applies. Article 14(1) state of health data in battery management systems applies.
• 18 February 2027: Article 77(1) per-unit passport obligation applies to LMT batteries, industrial batteries above 2 kWh, and EV batteries. Article 13(6) QR code obligation applies on the same date.
• Article 7 and Article 8 dates: Carbon footprint (point 1(c)) and recycled content (point 1(e)) fields in the passport become mandatory only when those articles apply to the relevant battery category. Those dates depend on delegated acts that have not all been adopted; check the status of each delegated act before including those fields.

If you are building or procuring a battery passport system now, the 18 February 2027 deadline leaves less time than it appears. You need to collect unit-level data from manufacturing lines, connect it to model-level data, generate unique identifiers that comply with the ISO/IEC 15459 series, print or engrave QR codes on batteries or packaging, and enforce four separate access tiers.

To see how Traceable could handle this for your products, register for a free trial.