Which Batteries Need an EU Battery Passport?

Three battery categories need a passport from 18 February 2027: light means of transport (LMT) batteries, industrial batteries above 2 kWh, and electric vehicle batteries. Portable and SLI batteries are excluded — but they do not escape the QR code, which Article 13(6) imposes on all batteries on the same date. This is the most misread scope rule in Regulation (EU) 2023/1542.

What does Article 77(1) say?

The text is short and admits no exception: "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')."

Two words matter. "Each": the obligation applies to the individual unit, not the model — one passport per physical battery. "Placed on the market or put into service": access to the Union market triggers the obligation, regardless of where the battery was made.

How does the Regulation define each category?

The definitions sit in Article 3 and rest on weight and use, not on commercial names.

The line between LMT and electric vehicle battery is drawn at 25 kg for category L vehicles, and between portable and industrial at 5 kg. These are definitional thresholds, not tolerances: a misclassification shifts the entire set of obligations.

Are portable and SLI batteries really exempt?

They are exempt from the passport, not from the QR code. Article 13(6) is explicit: "From 18 February 2027, all batteries shall be marked with a QR code as described in Part C of Annex VI."

What the QR code must open then depends on the category:

The operational conclusion: no battery placed on the Union market from 18 February 2027 escapes a digital obligation. The question is not "am I in scope", but "which level of digital obligation applies to each of my references".

Four scope traps

1. The 2 kWh threshold applies only to industrial batteries. There is no capacity threshold for LMT or electric vehicle batteries. A small e-scooter battery is in scope exactly like a van traction pack.

2. An industrial battery range can straddle the threshold. Two references in the same catalogue, one at 1.8 kWh and one at 2.4 kWh, fall under two different regimes. Sorting happens reference by reference, not range by range.

3. Second life creates a new passport. Article 77(7) requires, for a battery subject to preparation for re-use, repurposing or remanufacturing, a new passport linked to the original passport, and transfers responsibility to the operator placing it back on the market. Article 77(8) closes the cycle: the passport ceases to exist after the battery has been recycled.

4. Placing on the market beats place of manufacture. A manufacturer established outside the Union is not exempt: under Article 77(4) it is the economic operator placing the battery on the Union market that must ensure the information is accurate, complete and up to date. It may authorise a third party in writing to act on its behalf, without shedding its own responsibility.

In short

Battery passport scope reads in two steps. First Article 77(1): three categories — LMT with no threshold, industrial above 2 kWh, electric vehicles — and one obligation per unit from 18 February 2027. Then Article 13(6): a QR code on all batteries at the same date, with reduced content for the categories outside the passport. The Article 3 definitions, built around the 5 kg and 25 kg thresholds, decide which regime applies to each reference.

Arianee provides the infrastructure covering both regimes — full passport or digital access point — with a unique identifier per unit. See our Battery Pass page, the 71 data points of the Commission guidance, or request a demo.

Sources: Regulation (EU) 2023/1542, Articles 3, 13 and 77 (EUR-Lex) · Guidance Document: Digital Batteries Passport – data points by category, v2.0, 15 August 2026 (European Commission) · Digital Product Passport — Batteries, European Commission.