EU Battery Regulation & Battery Passport

From 18 February 2027, EV, LMT and industrial batteries above 2 kWh must each carry a battery passport

The EU's first mandatory digital product passport — earlier than ESPR, and the nearest hard deadline for battery exporters

What Is the EU Battery Regulation?

The EU Battery Regulation (EU) 2023/1542 entered into force on 17 August 2023 and has applied fully since 18 February 2024, replacing the 2006 Batteries Directive. It covers every battery placed on the EU market, imported batteries included, across the whole life cycle — from raw material sourcing and production to use and end-of-life recycling.

Full Life-Cycle Control

Carbon footprint, recycled content, hazardous substance limits, recycling efficiency, performance and durability — all mandatory together, not one stage at a time.

The EU's First Mandatory DPP

The battery passport is set out in Article 77 — the first digital product passport the EU actually enforces, earlier and more concrete than ESPR's product-group passports.

Direct Duties for Third-Country Exporters

Manufacturers, importers and distributors all carry duties. Chinese exporters must prepare passport data and carbon footprint records — without them, importers cannot place the batteries on the market.

Which Batteries Need a Passport?

The battery passport is mandatory from 18 February 2027 for these three battery types

EV Batteries

Electric vehicle batteries, including traction packs for light electric vehicles. One unique identifier per battery, reachable via the QR code on the casing.

LMT Batteries

Batteries for light means of transport (LMT) — e-bikes, e-scooters and similar. Export volumes are growing fast, making this the first deadline many companies hit.

Industrial Batteries Above 2 kWh

Industrial batteries above 2 kWh, including energy storage systems. Beyond the passport, these also need a carbon footprint declaration.

Portable batteries and SLI batteries (used for starting, lighting and ignition) are outside the passport mandate, but still subject to the Regulation's carbon footprint, recycled content and labelling requirements. Duties fall on manufacturers, importers and distributors alike.

Compliance Timeline

Obligations phase in — the passport is the last and hardest deadline

18 Feb 2024 · Fully Applicable

Replaces the 2006 Batteries Directive; carbon footprint, recycled content and due diligence duties roll out on a fixed schedule.

18 Feb 2025 · EV Carbon Footprint

Electric vehicle batteries must file a full life-cycle carbon footprint declaration, third-party verified.

18 Feb 2026 · Industrial Batteries

Industrial batteries above 2 kWh, including energy storage, come under the carbon footprint declaration.

18 Feb 2027 · Passport Mandatory

EV, LMT (e-bikes, e-scooters and similar) and industrial batteries above 2 kWh must each carry a passport, reachable via the QR code on the casing.

On recycled content, reporting starts in August 2028 and minimum content requirements from August 2031. The exact dates for the carbon footprint requirements depend on the EU delegated acts.

The Three Core Obligations

Battery passport, carbon footprint declaration and supply chain due diligence form the backbone of compliance

Battery Passport (Art. 77)

A unique identifier per battery, reachable through the QR code on the casing. Seven data groups: general information and labelling, carbon footprint, supply chain due diligence, material composition, circularity and resource efficiency, performance and durability, and recycled content — opened in tiers to the public, manufacturers, supply chain partners and authorities.

Carbon Footprint Declaration

Full life-cycle carbon footprint calculated under the EU methodology and third-party verified. Performance classes apply from August 2026; maximum carbon footprint thresholds from February 2028.

Supply Chain Due Diligence

Companies must adopt and disclose a due diligence policy covering cobalt, natural graphite, lithium, nickel and their chemical compounds. Originally applying from 18 August 2025, postponed to 18 August 2027 by (EU) 2025/1561.

What Carbbit Delivers

From scoping to a live passport, across the whole compliance chain

Scoping & Roadmap

  • Determine whether your batteries fall under the passport, carbon footprint and due diligence duties
  • Rank the mandatory deadlines and priorities by battery type

Carbon Footprint & Verification

  • Calculate the full life-cycle carbon footprint per the EU methodology
  • Build traceable material and energy data collection, and interface with third-party verifiers

Passport Data & Carrier Rollout

  • Structure the Article 77 data groups into passport fields with tiered access rights
  • Generate unique identifiers and casing QR codes, integrate with products and maintain them

Due Diligence & Supply Chain Data

  • Adopt and disclose a due diligence policy covering cobalt, natural graphite, lithium and nickel
  • Collect and verify upstream and downstream data for importer due diligence and market surveillance

Service Process

Four steps from scoping to a live battery passport

1

Scoping

Identify battery type, applicable duties and their mandatory deadlines

2

Data Modelling

Design passport fields, carbon footprint collection forms and ownership

3

Calculation & Verification

Complete carbon footprint calculation, third-party verification and the due diligence policy

4

Passport Rollout

Generate unique identifiers and QR carriers, integrate with products and maintain them

Start Your Battery Regulation Compliance Preparation

Leave your details to get a battery applicability check and a passport data field checklist