EU battery passport requirements: due 18 February 2027.
Regulation (EU) 2023/1542, Article 77(1): “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’).”
If you place the battery on the EU market, the passport is yours (Article 77(4)). It opens from a QR code on the battery (Article 13(6)). We build it, label it and host it.
What is a battery passport?
A digital record for one battery, kept for its whole life. Anyone can open its public part from the QR code on the battery. Repairers, recyclers and authorities see more.
One ID, many readers
- One ID for every battery
- A QR code, and our chip, that open it
- Each reader sees only their part
- Open standards, so systems connect
- Every version signed and checkable
- Kept and updated for 10 years
- Ready for the EU registry
The battery's whole story
- Maker, model and battery ID
- Compliance, labels and certificates
- Materials and hazardous substances
- Performance and lifetime
- Health and status
- Repair, second life and recycling
- Carbon footprint and due diligence, as they come due
Data without a trusted system is scattered. A system without good data is an empty shell. Aeroz brings both.
Who needs a battery passport: three battery classes.
Article 77 attaches a battery passport to the categories that move through complex, multi-owner lifecycles — the ones where identity is hardest to keep intact.
Light means of transport
Batteries powering e-bikes, scooters, and similar light electric vehicles placed on the EU market.
Industrial > 2 kWh
Industrial batteries with a capacity above 2 kWh, including stationary energy storage.
EV batteries
Electric-vehicle traction batteries, each requiring its own passport at unit level.
Battery passport deadline: 18 February 2027. The real one is earlier.
A battery placed on the EU market on or after 18 February 2027 must carry its passport on day one. Packs built in Asia ship by sea (five to seven weeks to a European port) and Chinese New Year falls on 6 February 2027, so the last practical production window for a compliant pack is early January 2027. Work back from there.
| Date | What happens | Where it comes from |
|---|---|---|
| 18 Aug 2026 or later | General battery labels apply from 18 August 2026 or 18 months after the Commission’s implementing act on label content, whichever is later. That act has not been adopted (draft December 2025), so the general labels do not apply yet. | Article 13(1)–(3) |
| Oct – Nov 2026 → Q4 2026 | The Commission expects to publish its draft implementing act on who may see the non-public passport data for public feedback in October or November 2026, with adoption planned for Q4 2026. The 18 February 2027 date is unaffected. | Article 77(9); Commission batteries FAQ |
| Oct – Nov 2026 | Cell-supplier data requests out, field-by-field. Supplier data is the slowest part of a passport, not the software. | Aeroz working calendar |
| Early Jan 2027 | Last practical production date for a pack shipped by sea to arrive and be placed on the market with a passport. | Sea transit + Chinese New Year (6 Feb 2027) |
| 18 Feb 2027 | Battery passport required for every LMT, EV and industrial >2 kWh battery placed on the market or put into service. QR code data carrier on the battery. Passports go into the EU DPP registry, live since 20 July 2026. | Article 77(1), Article 13(6); Implementing Regulation (EU) 2026/1778 |
| 18 Aug 2027 | Battery due-diligence obligations apply (postponed by two years from 18 August 2025). | Articles 48–52 as amended by Regulation (EU) 2025/1561 |
| Not yet set | Carbon footprint declaration for EV batteries: applies 12 months after the Commission adopts the calculation method, which it has not done yet. | Article 7 |
| 18 Aug 2028 | Documentation of recycled cobalt, lithium, nickel and lead content per battery model and plant. | Article 8(1) |
Sources: Regulation (EU) 2023/1542 · European Commission battery passport guidance, 21 August 2026. Checked 23 October 2026; the general-label row was last checked 27 September 2026.
Battery passport data requirements: 71 fields. 49 are mandatory for an LMT battery.
The Commission’s guidance (v2.0, August 2026) lists 71 data points across Annex XIII. For a light-means-of-transport battery, 49 are marked mandatory on day one, including the state-of-health fields (remaining capacity, remaining power, round-trip efficiency, self-discharge, ohmic resistance). Eleven are not filled for LMT and the rest apply only in specific cases. Article 77(2) sets three access levels.
Anyone who scans
Manufacturer and battery identification, chemistry and weight, rated capacity, voltage and power, hazardous substances, expected lifetime, the declaration of conformity and the end-of-life information. Carbon footprint and recycled content join when those rules apply.
Repairers, remanufacturers, recyclers
Detailed composition, dismantling and safety information, and the performance and durability data: capacity fade, power fade, internal resistance, round-trip efficiency, state of health, and the battery’s status (original, repurposed, reused, remanufactured, waste).
Notified bodies and market surveillance
Results of tests and the due-diligence report, once the due-diligence obligations apply in August 2027.
The sample passport is a fictional battery from a fictional maker, built to show every field and access level. Counts follow the Commission’s data-point table, LMT column, checked line by line on 25 September 2026.
Value across the chain.
One record, read differently by everyone who handles the battery.
Fill the data once and reuse it for every customer.
Meet Article 77 and show which packs are yours.
Check a pack is genuine before you sell it.
See what is inside, how healthy it is and how to recycle it.
Open the repair and safety data the law lets you see.
Know a battery's health and history before you buy it.
Find the chemistry and dismantling information in one scan.
See the conformity and test data the law reserves for them.
The QR code requirement meets the law. It doesn't stop a copy.
A printed code can be photographed and stuck on a fake, and the fake opens your real passport. Our Verify chip sits beside the QR and answers every tap with a new code, so a copy doesn't verify.
QR for the law · chip for your profit
The battery passport, by battery class.
Battery passport for EV batteries
The requirements, the dates and the module-level gap.
Read the guide → LMTBattery passport for e-bikes
What micromobility brands must build for e-bikes, e-scooters and e-cargo.
Read the guide → IndustrialBattery passport for energy storage
What storage integrators and operators must prepare.
Read the guide → Second lifePassports for second-life batteries
Repurposed batteries need a new passport linked to the original.
Read the guide → QR or chipNFC or QR for battery passports
Where the printed code is enough, and where it falls short.
Read the guide → ChecklistThe 49-field checklist
Every LMT field to collect, as a free PDF.
Get the checklist →Your Article 77 gap report — $2,500.
A written readiness report against Regulation (EU) 2023/1542 Article 77: the Annex XIII fields you must carry, what your systems and suppliers hold today, and a plan to close the gap with cost and timeline.
What's included
- Article 77 readiness for LMT, industrial >2 kWh, or EV batteries.
- Annex XIII data inventory mapped to the fields you must carry.
- Supplier gaps listed field by field, with who has to send what.
- Your real deadline, worked back from where you make and how you ship.
- A fixed quote for passports, labels and chips on your volume.
From the Aeroz blog
- The EU Battery Mandate Clock is Ticking…Are You Even Prepared?
- The EU Missed Its Own Battery Passport Deadline. Yours Did Not Move.
- Almost all DPP Deadline Dates Have Been Solidified.
- What a QR code proves, and what an NFC chip proves
More answers: EU battery passport questions in the compliance FAQ
The EU Battery Passport, answered.
When is the EU Battery Passport required?
18 February 2027. Under Article 77 of the EU Battery Regulation (EU) 2023/1542, every LMT battery, industrial battery over 2 kWh, and EV battery placed on the EU market must carry a digital Battery Passport.
Which batteries need a Battery Passport?
LMT (light means of transport) batteries, industrial batteries above 2 kWh, and electric-vehicle batteries placed on the EU market. Each requires a unique identifier and a QR-code data carrier linking to its passport.
What data must the Battery Passport contain?
The Annex XIII information. The Commission’s table has 71 data points; 49 are mandatory for an LMT battery on 18 February 2027, including identification, chemistry, capacity and power with their fade, internal resistance and the state-of-health fields. Carbon footprint and recycled content are not filled in on that date; their own rules apply later. The public sees some; repairers and recyclers with a legitimate interest see more; authorities see the rest.
Who is responsible for the passport?
The economic operator placing the battery on the EU market (Article 77(4)): the pack maker or the importing brand. If your drive-system supplier issues the passport for its battery, it is theirs to maintain; if you build or import your own packs, it is yours.
Is an NFC chip required?
No. The law requires a QR code on the battery that resolves to the passport (Article 77(3), Article 13(6)). Our chip goes beside it. The QR meets the law; our Verify chip answers every tap with a new code, so you can tell your pack from a copy and refuse a fake warranty claim.
My packs are made in Asia. When do I really need to be ready?
Early January 2027. Sea freight to a European port takes five to seven weeks and Chinese New Year falls on 6 February 2027, so a pack produced after early January is unlikely to be placed on the market before 18 February with its passport in place. Supplier data collection should start in October 2026.
How does Aeroz support second life and recycling?
When a battery is repurposed, it needs a new passport linked to the original (Article 77(7)). Aeroz keeps the two linked, so the battery's history follows it into second life and recycling.
Does Aeroz replace my existing systems?
No. Aeroz runs the passport on its own, and connects to the systems you already run through open standards (GS1 Digital Link and EPCIS 2.0), so nothing is ripped out.