The battery passport: scope and what to prepare

Which batteries need a passport

Under Article 77, from 18 February 2027 a battery passport is required for each of these batteries placed on the market or put into service:

• electric vehicle batteries;
• light means of transport (LMT) batteries, such as batteries for e-bikes and e-scooters, whatever their capacity;
• industrial batteries with a capacity above 2 kWh.

The duty sits with the operator that places the finished battery on the market. If you import e-bikes or other products with a finished battery inside, that can be you. Suppliers of cells or modules normally do not need a passport of their own.

Portable batteries, such as those in phones or power tools, do not need a battery passport. They still have labelling, substance and other duties, and from the same date every battery needs a QR code. See the guide to the battery QR code.

One passport per battery

Unlike many future ESPR passports, the battery passport belongs to each individual battery. Every battery in scope gets its own unique identifier and its own passport, reached through the QR code on the battery. The identifier must also be registered in the EU digital product passport registry, which opened on 20 July 2026 under Implementing Regulation (EU) 2026/1778.

What it contains

Annex XIII of the regulation lists the information. Broadly, it covers:

• general information about the manufacturer, the battery model and its manufacturing date and place;
• chemistry, hazardous substances and critical raw materials;
• the carbon footprint, where required for that battery category;
• recycled content and responsible sourcing (due diligence) information;
• performance and durability, including capacity and expected lifetime;
• information for dismantling, repurposing and recycling.

The passport has three levels of access. Some information is public. Some is only for people with a legitimate interest, such as repairers, remanufacturers and recyclers. Some is only for notified bodies, market surveillance authorities and the Commission.

The implementing act that sets out who has a legitimate interest and how access works was due by 18 August 2026 and has not been adopted yet. The Commission now plans it for the fourth quarter of 2026. The Commission also publishes guidance on the data points per battery category, which is not legally binding.

What Polarpass does not provide

Polarpass does not provide a battery passport under Article 77 and Annex XIII of the Batteries Regulation. In particular, it has:

• no restricted access level for people with a legitimate interest or for authorities. Information in a DPP Ready passport is either public or kept internal;
• no structured data model for the Annex XIII information;
• no registration of passports in the EU registry.

If you place EV, LMT or industrial batteries over 2 kWh on the market, use a provider that is built for the battery passport. A Polarpass passport, at item level or any other level, is not a substitute for it.

What to prepare now

If you place LMT or industrial batteries on the market, or integrate them into products you sell:

• confirm the category and capacity of each battery, as this decides whether it is in scope;
• find out who places the finished battery on the market, and so who is responsible for the passport;
• agree with your cell or pack supplier who provides which Annex XIII data;
• set up serial numbers that you can print in a QR code on every battery;
• collect the declaration of conformity, safety test reports and substance information.

Polarpass’s Batteries category gives review prompts and a place to keep these documents. That helps you organise evidence, but it is not a battery passport and it does not certify anything.