Batteries Regulation Article 78 explained: technical design of the battery passport

Battery passport technical design and what companies must do

Article 78 of the EU Batteries Regulation sets out the technical and operational requirements for the battery passport. These rules are essential for companies placing batteries on the EU market, as they establish how the system must work, who can access it, and how data must be managed. Understanding these requirements is critical for compliance, especially as the battery passport becomes the first mandatory Digital Product Passport from 18 February 2027.

Interoperability across EU digital product passports

The battery passport cannot exist in isolation. Article 78 requires that the system must be technically compatible and interoperable with other EU digital product passports. This means three layers of integration:

• Technical interoperability: The battery passport must use compatible systems, data formats and IT infrastructure so information can be shared and understood across different digital passport platforms.
• Semantic interoperability: Data definitions, naming conventions and information structures must align so that battery data has the same meaning whether it appears in a battery passport, a textiles passport, or any future EU digital product passport.
• Organizational interoperability: The governance, processes and frameworks for operating the battery passport must work alongside other EU digital passport schemes.

For companies, this means the battery passport system you implement cannot be proprietary or isolated. You must ensure your data submission, storage and retrieval systems can communicate with broader EU digital infrastructure. This reduces fragmentation and helps create a seamless experience for users accessing multiple product passports.

Free access for authorized users

The battery passport must be accessible free of charge to all authorized users. This includes consumers, economic operators (manufacturers, distributors, retailers), and other relevant actors defined by the regulation. There can be no paywall or subscription model blocking access to battery information.

Access rights, however, are role-based and differentiated. Not everyone can see or modify all information. A consumer may view the environmental or safety data of a battery they own, while a manufacturer can edit technical specifications. A recycler may access end-of-life information relevant to their operations. The system must authenticate users, verify their role, and grant access accordingly. This ensures transparency while protecting commercially sensitive or personal data.

Data storage and governance by the responsible company

Article 78 establishes a clear principle: the company responsible for placing the battery on the market—or authorized agents acting on their behalf—must control the data stored in the battery passport. This responsibility includes both the technical operation of the database and compliance with data protection rules.

Critically, data governance is restricted to the service role. The responsible company or their authorized operators cannot:

• Sell battery passport data to third parties
• Reuse information for purposes unrelated to managing and maintaining the battery passport
• Transfer data to unauthorized processors
• Leverage the data for marketing, analytics or other secondary purposes

This is a significant constraint on data use. Many companies are accustomed to mining product data for business intelligence. The battery passport framework prohibits this. Your role is custodian and servicer, not data owner or analytics asset. If you employ third-party service providers—cloud hosts, IT consultants, or data managers—they too are bound by these restrictions and must sign agreements limiting their use of battery data to provision of the passport service only.

Continuity of access after business closure

One unique requirement in Article 78 is that the battery passport must remain accessible even after the responsible company ceases operations or leaves the EU market. This is a critical consumer and environmental protection measure. A battery may remain in use or require recycling years after its manufacturer exits the market. Users must still be able to access its passport data.

This creates practical challenges for companies. You cannot simply shut down your passport database when you exit a market or close your business. Instead, you must:

• Plan for data transition or handover before closure
• Ensure another authorized party can take over passport operations
• Maintain data in a format that allows continuity of service
• Inform authorities of your exit plan well in advance

The regulation will specify the detailed mechanisms for this transfer, but the principle is clear: your commercial lifecycle does not override the need for permanent, accessible battery information.

Security, authentication and data integrity

Article 78 requires high standards for security, privacy and fraud prevention. This means:

• Authentication: All data in the battery passport must be verified as genuine and traceable to its source.
• Integrity protection: Information must be protected against unauthorized alteration or corruption.
• Security standards: The system must meet robust cybersecurity requirements to prevent unauthorized access or data breaches.
• Fraud prevention: Measures must be in place to detect and prevent false or misleading passport entries.
• Privacy protection: Personal data must be handled in accordance with GDPR and other EU privacy laws.

For companies, this translates into investment in secure IT infrastructure, regular security audits, encryption, access controls and staff training. The battery passport is a high-value target for fraud (as it certifies product compliance and environmental claims), so security cannot be an afterthought.

Practical implications for your business

Article 78 signals that the battery passport is not a simple online database you can build and forget. It is a regulated, interoperable, secure, role-based system with strict data governance and long-term operational obligations. Companies must design their passport systems with these technical and legal requirements in mind from the outset, not retrofit them later. Collaboration with IT partners, data governance specialists and legal teams is essential to meet these standards by the 18 February 2027 deadline.

Frequently asked questions

Can we use our own proprietary database for the battery passport?

Only if it meets the interoperability requirements set out in Article 78. Your system must be technically, semantically and organizationally compatible with other EU digital passports. Purely proprietary or closed systems are unlikely to satisfy this requirement. You should expect to work within broader EU digital infrastructure frameworks.

Are we allowed to use battery passport data for market research or analytics?

No. Article 78 restricts data use to the provision and maintenance of the battery passport service itself. Secondary uses like marketing analytics, market research or business intelligence are prohibited. If you want to conduct analytics on your business, you must use other, separate data channels—not the passport system.

What happens to passport data if our company goes out of business?

The battery passport must remain accessible. You cannot simply delete the data or shut down access. Before ceasing operations, you must arrange for another authorized party to take over passport management, or hand over the data to a designated custodian. The regulation will provide further detail on this process, but the principle is non-negotiable.

Can we charge consumers a fee to access the battery passport?

No. Free access is a requirement of Article 78. You may not implement subscription models, paywalls or usage fees. Access must be free for all authorized users.

What level of cybersecurity is required?

Article 78 requires high standards for security, authentication and fraud prevention, but does not specify exact technical standards. You should expect that detailed implementing rules will provide more guidance. Industry best practices for authentication, encryption, access control and intrusion detection are a baseline. Consultation with cybersecurity experts is recommended.

Official text (Batteries Regulation Article 78): “battery passport shall be fully interoperable with other digital product passports required by Union law” — Regulation (EU) 2023/1542, EUR-Lex

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