Batteries Regulation Article 77 explained: the battery passport

Battery passport Article 77: What you need to know

From 18 February 2027, a major new requirement takes effect across the EU: every large battery, industrial battery over 2 kWh, and electric vehicle battery sold in the Union must be accompanied by a battery passport. This is not a paper document or a simple label. It is a digital record—an electronic file containing detailed information about the battery’s composition, performance, safety, and lifecycle. Article 77 of the Batteries Regulation (Regulation (EU) 2023/1542) sets out how this passport must work and who is responsible for managing it.

The battery passport represents the first mandatory application of Digital Product Passport technology in the EU. It marks a significant shift in how batteries are tracked, managed, and recycled across their entire life cycle. For any business placing batteries on the EU market—whether you manufacture them, import them, or distribute them—Article 77 creates binding obligations to implement, maintain, and give access to this digital record.

How the battery passport works

The passport is accessed via a QR code attached to or printed on the battery or its packaging. When a user (consumer, regulator, recycler, or authorized party) scans the QR code, they are directed to an electronic record linked to a unique identifier for that specific battery or battery model. This digital system holds all the information required by the Batteries Regulation—from raw material composition and manufacturing data to performance metrics, safety warnings, and end-of-life recycling instructions.

The system is designed to work seamlessly across the EU market, using open standards and machine-readable data formats. This means the passport can be read and understood by different software systems without technical barriers or vendor lock-in. The data must be interoperable and transferable, so that information can move between systems and stakeholders without loss or distortion.

Three levels of access: who sees what

Article 77 establishes a tiered access model. Not everyone who scans the QR code sees the same information. Instead, access is controlled based on who is asking and what they legitimately need to know.

Public access: General consumers and the general public can access basic, non-sensitive information about the battery. This typically includes safety warnings, correct use instructions, expected lifespan, and recycling guidance. The aim is to empower end-users to handle batteries safely and responsibly.

Authority and regulator access: Member State authorities, regulators, and enforcement bodies can access a wider set of information restricted from the public. This allows them to monitor compliance, investigate non-conformity, and enforce the Batteries Regulation effectively across the EU.

Legitimate-interest access: Certain authorized parties—repair shops, remanufacturers, recycling facilities, and similar operators—can access specialized information they need to perform their specific function. A recycler might need detailed information about battery chemistry and hazardous content; a repair service might need performance data or replacement part compatibility information. Each party sees only what is necessary for their role.

Who manages the passport?

The manufacturer is the primary responsible party. You must ensure that the passport is created, remains accurate and complete, and is kept current throughout the battery’s life. However, Article 77 allows manufacturers to authorize other parties to manage the passport on their behalf—such as importers, distributors, or specialized service providers. This flexibility recognizes that large manufacturers may delegate administrative tasks, but responsibility ultimately remains with you.

When a battery moves through its lifecycle—from first sale, through use, to potential refurbishment or remanufacturing—the passport must transfer to the new operator. If a battery is refurbished or remanufactured, the new owner or operator takes over responsibility for keeping the passport up to date. Once a battery is recycled and no longer exists as a unit, the passport record ends.

Data standards and interoperability

A critical requirement of Article 77 is that all battery passport data must be held and transmitted using open standards. This prevents companies from locking battery information into proprietary systems that only they can access or modify. The data must be machine-readable—meaning software and automated systems can process it directly—and transferable without technical barriers.

This requirement has a dual purpose. It protects against vendor lock-in, ensuring that if you change IT providers or systems, your battery data is not trapped in a closed format. It also ensures that authorities, recyclers, and other legitimate users can access and use the information they need without depending on a single company’s goodwill or commercial terms.

Practical implications for your business

If you manufacture batteries for the EU market, you need to plan for implementation well before February 2027. This means:

• Building or integrating systems to generate and host digital passport records for each battery or model you produce
• Implementing tiered access controls so that different users see different information based on their role
• Generating QR codes and attaching them to your products or packaging
• Ensuring your data conforms to open standards and is machine-readable
• Establishing procedures to keep passport data accurate and current over the battery’s lifespan
• Planning for data transfers when batteries are refurbished, remanufactured, or recycled
• Training staff and, if necessary, third parties you authorize to manage passports on your behalf

If you import or distribute batteries, you need to understand how the passport requirement affects your supply chain. You may be responsible for ensuring passports are present and functional at the point of sale, and you may need systems to verify and validate passport data.

Why this matters

The battery passport is not a compliance box to tick. It is a tool that shapes how the entire battery ecosystem operates. It increases transparency, allows regulators to enforce safety and environmental standards more effectively, enables recyclers to extract value and hazardous materials safely, and gives consumers the information they need to use and dispose of batteries responsibly.

For manufacturers and distributors, it is an investment in systems and processes, but it also opens opportunities. Accurate passport data can support marketing claims about sustainability, help you track and manage recalls more efficiently, and build consumer trust through transparency.

Frequently asked questions

Do all batteries need a passport from February 2027?

No. Article 77 applies to large batteries, industrial batteries exceeding 2 kWh, and electric vehicle batteries. Smaller consumer batteries (like AA or AAA cells) and batteries under the 2 kWh threshold are not included in this requirement.

Can manufacturers use their own QR code system?

Yes, but the underlying data must conform to open standards and be machine-readable. You cannot use proprietary formats that lock data into your system or prevent others from accessing and understanding it.

What happens if a battery is sold second-hand?

The passport remains attached to the battery. When the battery transfers to a new owner (refurbishment or remanufacturing scenario), responsibility for maintaining the passport transfers too. The new operator must ensure it remains current.

Who enforces Article 77?

Member State authorities and market surveillance bodies enforce compliance. They can access restricted information in the passport and take action against non-compliant manufacturers and distributors.

What if I authorize a third party to manage my passports?

You remain ultimately responsible. Any third party you authorize must manage the passport according to Article 77 requirements, and you must ensure they do so accurately and on time.

Official text (Batteries Regulation Article 77): “from 18 February 2027 each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market or put into service shall have an electronic record ('battery passport')” — Regulation (EU) 2023/1542, EUR-Lex

Related: The battery passport · What is a Digital Product Passport?