Battery Passport 2027 guide for small EU sellers and importers
What the 18 February 2027 deadline covers, what a battery passport contains at a high level, and what to organise before registration.
Check your current preparation across scope, identifiers, ownership, data inventory, access rights and registry workflow.
Which batteries are in the 2027 passport scope?
Article 77 of Regulation (EU) 2023/1542 says that from 18 February 2027 each LMT battery, each electric vehicle battery and each industrial battery with a capacity greater than 2 kWh placed on the market or put into service must have an electronic battery passport.
Do not use this threshold as a universal rule for every battery type. If your product does not clearly fit one of these categories, verify the applicable classification and legal requirements.
What information belongs in the battery passport?
The Regulation distinguishes model-level information and information specific to the individual battery. Annex XIII and implementing rules determine the detailed fields and who can access them.
Some information is public, while other data is restricted to authorities, notified bodies or parties with a legitimate interest. That means a useful preparation project should map both the data field and its access class instead of building one public page with everything.
A practical preparation workflow
- Confirm scope and battery category.
- Assign the responsible economic operator. Decide who owns the passport and accuracy of its records.
- Prepare stable model and individual identifiers.
- Create a structured Annex XIII data inventory. Mark each field as verified, missing or waiting on a supplier.
- Map public and restricted access.
- Plan the data carrier and digital link.
- Assign evidence and lifecycle owners. Battery data can change over its life; define who maintains it.
- Test the EU Registry workflow.
How the DPP Registry fits in
The European Commission launched the DPP Registry and testing environment on 20 July 2026. The Registry is part of the registration and identifier infrastructure; detailed passport information follows the decentralised DPP model.
For small businesses, the useful work before the deadline is therefore not just creating a QR code. It is building a clean, auditable product-data source that can feed the required passport and remain maintainable after launch.
Official sources
Frequently asked questions
When does the battery passport requirement start?
For the battery categories listed in Article 77(1), the date is 18 February 2027.
Is a QR code enough?
No. The data carrier links to a larger digital information system. You still need the required identifiers, fields, access rules and maintained source data.
Does the free checker prove compliance?
No. It measures preparation completeness and highlights gaps. It does not certify product compliance.