EU Battery Passport, 18 February 2027: Scope, Data and What Stays Empty

18 February 2027 is the only binding product passport deadline that is close, and it is the only one in force for any of the categories we cover. It comes from Art. 77(1) of Regulation (EU) 2023/1542, not from the ESPR. Six months out, the two things worth getting right are the scope (it is narrower than most summaries say) and the data (several required-looking fields must be left empty).

What the Battery Regulation is

Regulation (EU) 2023/1542 replaced the old Battery Directive and covers the full battery lifecycle. Art. 77 creates the battery passport. It applies regardless of where the battery is manufactured, as long as it is placed on the EU market.

Who needs a passport, and who only needs a QR code

This is the single most misreported part of the regulation. The passport obligation under Art. 77(1) covers exactly three groups:

• EV batteries, at any capacity
• LMT batteries (light means of transport: e-bikes, e-scooters and similar), at any capacity
• Industrial batteries above 2 kWh (energy storage, backup power, data centre batteries)

The 2 kWh threshold applies only to industrial batteries. It is not a general cut-off, and it has nothing to do with portable batteries.

Portable and SLI batteries are out of passport scope entirely. The cells in a power tool, a torch or a laptop, and the starter battery in a car, do not get a passport. From the same date, 18 February 2027, they do need a QR code under Art. 13(6) and Annex VI Part C, pointing to label information, the declaration of conformity, the due diligence report and the Art. 74(1)(a) to (f) waste information. That is a much smaller job, and building a full passport for those products is wasted effort.

What Annex XIII actually contains

Annex XIII is organised in four points with different audiences, not the three tiers you often see described:

• Point 1: public. Anyone scanning the QR code sees it.
• Point 2: dual audience. Detailed composition, part numbers, dismantling information and safety measures. Art. 77(2)(b) gives notified bodies, market surveillance authorities and the Commission access; Art. 77(2)(c) gives persons with a legitimate interest access to the same point.
• Point 3: authorities only. Test reports.
• Point 4: legitimate interest. Dynamic data for the individual battery, such as state of health and cycle count.

The fields you must leave empty in February 2027

A surprisingly large block of Annex XIII cannot be filled on the application date, because the enabling acts do not exist. If a tool blocks you from publishing until you complete these, the tool is wrong:

• Carbon footprint declaration and performance class. Depend on Art. 7(1) and 7(2) acts that are unadopted. The EV methodology act was due 18 February 2024 and is more than two years late.
• Recycled cobalt, lithium, nickel and lead shares. Depend on the Art. 8(1) calculation methodology act, which was legally due 18 August 2026 and has not been adopted.
• Responsible sourcing and due diligence. Regulation (EU) 2025/1561 moved Art. 48(1) from 18 August 2025 to 18 August 2027, and Chapter VII does not apply at all below EUR 40 million net turnover (Art. 47).

The Commission's own Digital Batteries Passport, data points by category guidance (v2.0, 15 August 2026) marks these as "not to be filled or displayed as of February 2027". That document is expressly not the Commission's official position, but the legal point stands without it: you cannot declare a figure against a methodology that has not been adopted.

What you do need ready

• Battery identity: manufacturer, model, unique identifier, chemistry, nominal capacity, weight and dimensions
• Hazardous substances and safety information
• Performance and durability documentation. Binding since 18 August 2024 under Arts. 10(1) and 14(1) for rechargeable industrial batteries above 2 kWh, LMT and EV batteries, with the battery management system holding Annex VII state of health data at read-only access.
• Collection and recycling information, end-of-life handling
• A persistent unique identifier and a data carrier physically on the battery

Who is affected

Key dates, with sources

How to prepare

1. Classify every battery first. EV, LMT, industrial, portable or SLI. Everything else follows from that, and getting it wrong means either missing an obligation or doing months of work you never owed.
2. Map your supply chain. Identify each battery model and who manufactures each cell.
3. Request supplier data early. Chemistry breakdowns, weight, capacity and hazardous substance declarations often take suppliers months to compile.
4. Plan for item-level identifiers. One passport per physical battery is a production and printing problem as much as a data problem. Test scanning on real units.
5. Sort out your eIDAS credential. Uploading the identifier to the EU DPP registry requires a qualified electronic seal under Implementing Reg. (EU) 2026/1778, valid for at most three years. Procurement takes time.
6. Leave the deferred fields blank. Do not invent a carbon footprint class or a recycled cobalt percentage to fill a form.

Enforcement: what can and cannot happen

Member States set penalties under Art. 93, and market surveillance authorities can require corrective action or withdrawal from the market. Those are real.

What is not real, despite how often it is claimed: an automated customs block for a missing passport. ESPR Art. 15 customs controls apply only to products covered by an Art. 4 delegated act, the registry to EU CSW-CERTEX interconnection has an outer deadline around 6 August 2030 under Art. 15(3), and DG GROW stated on 27 May 2026 that battery passports need not be provided in electronic customs declarations. Plan for market surveillance, not for a border scanner.

Industry work such as the Battery Pass consortium is useful for aligning data formats, but it is a voluntary initiative and conformity with it is not conformity with the regulation.