The EU battery passport is a digital record that must accompany every electric vehicle battery placed on the EU market from 18 February 2027, and it applies to UK manufacturers and exporters whose batteries, or vehicles containing them, are sold into the EU. Each battery will carry a QR code linked to a unique identifier, giving regulators, recyclers and later users access to defined information about its make-up, origin, carbon footprint and condition.
This explainer sets out the legal basis in the EU Batteries Regulation, which batteries are in scope, what data the passport holds and who can see it, how the carbon footprint declaration fits in, and what UK exporters should be doing ahead of the 2027 date. It reflects sources checked in November 2026.
The legal basis for the battery passport
Regulation (EU) 2023/1542 on batteries and waste batteries was adopted on 12 July 2023, published on 28 July 2023 and entered into force on 17 August 2023. The European Commission’s batteries policy page gives 18 February 2024 as its general application date, with requirements phased in over the following years. The regulation replaced the earlier Batteries Directive 2006/66/EC.
Article 77 of the regulation requires an electronic record, the battery passport, and Annex XIII lists the information it must contain. The recitals explain the intent: the passport should support tracking and tracing of batteries and make information available along the value chain, and the QR code on each battery should give access to it. The industry-led Battery Pass consortium confirms the passport will be mandatory from 18 February 2027 for batteries placed on the market or put into service in the EU.
Which batteries need a passport
Three categories are in scope, according to the Battery Pass content guidance summary:
- electric vehicle batteries;
- light means of transport batteries, such as those in e-bikes and e-scooters;
- industrial batteries with a capacity above 2 kWh, including stationary energy storage.
Responsibility sits with the economic operator that places the battery on the EU market or puts it into service, normally the manufacturer or, for batteries made outside the EU, the importer established in the EU. That operator must assign the identifier and keep the data accurate and up to date. When a battery is prepared for reuse, repurposed or remanufactured and placed on the market again, the operator doing so takes over and a new passport is created; when the battery becomes waste, responsibility passes to the producer or waste management operator.
What the passport contains and who can see it
The Battery Pass guidance groups the Annex XIII information into data clusters and access levels. Some data is fixed at model level; some, such as state of health, is dynamic and specific to each battery.
| Access level | Examples of information |
|---|---|
| General public | Manufacturer and battery details, carbon footprint, due diligence report, recycled content |
| Persons with a legitimate interest and the Commission | Detailed composition, dismantling information, spare part sources, safety measures |
| Notified bodies, market surveillance authorities and the Commission | Test reports proving compliance |
| Persons with a legitimate interest | Individual battery data such as performance, state of health and use |
The guidance identifies clusters covering general information, carbon footprint, supply chain due diligence, materials and composition, circularity and resource efficiency, and performance and durability. The consortium’s current site refers to more than 80 data points and notes that its data attribute longlist and data model, version 2.0, were published on 27 August 2026, building on the DIN DKE SPEC 99100 specification. Our article on why a battery traceability record must survive handovers covers the practical problem of keeping such data intact across owners.
The QR code and the carbon footprint declaration
The passport is reached through a QR code. The Battery Pass content guidance cites Article 13(6) of the regulation as requiring the QR code, as the data carrier for the passport, to be marked on all batteries by 18 February 2027. Recital 44 of the regulation says the code should be printed or engraved on the battery, or affixed to its packaging and accompanying documents where that is not possible.
The carbon footprint declaration is a separate obligation under Article 7, made for each battery model per manufacturing plant, and its result becomes part of the public passport data. The regulation phases carbon footprint requirements in through delegated acts that set the calculation and verification method; the Battery Pass guidance of December 2023 described that methodology as still in draft. Because the application date for electric vehicle batteries depends on the delegated act, exporters should confirm the current position on EUR-Lex rather than rely on dates quoted before the act is adopted. Our analysis of why battery carbon comparisons need the same boundary explains why the calculation rules matter.
What the battery passport means for UK exporters
The EU regulation applies to batteries placed on the EU market, wherever they are made, so a UK cell, module or pack maker supplying an EU vehicle assembler, or a UK vehicle maker exporting cars to the EU, will feed data into a passport even though the obligation formally sits with the EU-side operator. In practice, EU customers are likely to pass data requests up the supply chain. For example, a UK pack assembler might be asked for cell origin, chemistry, recycled content evidence, test reports and a route to supply live state-of-health data.
The questions to settle early are practical:
- Which entity will act as the economic operator, and who generates the unique identifier?
- Where will passport data be hosted, and for how long?
- Can the battery management system provide the dynamic data required?
- Is supplier data on materials, due diligence and carbon footprint good enough to be published?
Separately from the EU rules, the Global Battery Alliance is developing its own voluntary GBA Battery Passport sustainability scheme, aiming to launch in 2027, which some customers may also ask about.
Key points for UK battery and vehicle exporters
- Plan for the battery passport to be mandatory for EV batteries placed on the EU market from 18 February 2027.
- Agree with EU customers who is the economic operator and who issues the identifier and QR code.
- Map Annex XIII data to existing sources, separating public, restricted and per-battery data.
- Check that battery management systems can supply state of health and other dynamic data.
- Track the carbon footprint delegated act on EUR-Lex before committing to a declaration date.
- Expect a new passport when batteries are repurposed or remanufactured for resale.
This article is general information, not tax, legal or financial advice.
Sources
- EUR-Lex: Regulation (EU) 2023/1542 concerning batteries and waste batteries
- EUR-Lex: Regulation (EU) 2023/1542, full text (HTML)
- European Commission: Batteries
- Battery Pass consortium: BatteryPass-Ready
- Battery Pass: Battery Passport Content Guidance, executive summary
- Battery Pass: Battery Passport Content Guidance, full document
- Global Battery Alliance: Battery Passport
Sources checked in November 2026. Rules, rates and schemes can change after publication, so check the linked official pages before acting.
