EU battery passport or QR code? A manufacturer’s 2027 checklist

From 18 February 2027, batteries placed on the EU market or put into service must carry a QR code. What a buyer should see after scanning it depends on the battery category. For light means of transport (LMT), electric vehicle (EV) and industrial batteries above 2 kWh, the code opens an individual battery passport. For other batteries, the code gives access to the applicable information listed in Article 13(6). Read Articles 13 and 77 of the EU Batteries Regulation.

Which route applies to my battery?

• 625 Wh e-bike pack. If it qualifies as an LMT battery, it needs a passport. The industrial capacity threshold does not apply to LMT batteries.
• 1.8 kWh industrial pack. Follow the QR information route. The same applies at exactly 2 kWh.
• 3 kWh industrial pack. Its capacity exceeds 2 kWh. Each battery needs a passport.
• EV traction battery. Each EV battery needs a passport. Check the statutory category before treating a vehicle’s separate starter battery as an EV battery.
• Portable or starter, lighting and ignition battery. Follow the applicable QR information route, including access to the declaration of conformity. Article 13(6) specifies additional information for certain starter batteries.

Who owns the passport if our factory is outside the EU?

Identify the economic operator placing the battery on the EU market. Article 77 assigns that operator responsibility for accurate, complete and up-to-date passport information. It can authorise another operator in writing to act on its behalf. Before shipping, agree who assigns each identifier, who maintains the record and who can correct supplier data.

What should we ask the supplier for first?

1. Identify the pack. Request the model, intended use, manufacturer, rated capacity and supporting specification. Record the category decision for each model.
2. Map the evidence. Start with the technical file and declaration of conformity. Ask the cell or pack supplier for the composition and performance evidence missing from your Annex XIII field list. Record the source, version and owner for each field.
3. Test one unit. Scan a pilot label. Confirm that it opens the correct individual record, that public users see the public fields and that restricted information requires the right access.

Two identical e-bike packs can share model-level evidence. Each in-scope pack still needs its own identifier and individual record. A QR code pointing both units to the same generic PDF misses that distinction. Check the information and access groups in Annex XIII.

For a product range with mixed battery types, share a model list, capacities and one sample technical file. Explore EcoComply’s battery passport service and request a free scoping assessment.

Digital product passport guide for manufacturers · EU battery removability rules