Battery Pass: the mandatory battery passport from February 2027
Regulation (EU) 2023/1542 requires a digital passport for every industrial battery, electric vehicle battery and light transport battery placed on the EU market. This Battery Pass is part of the broader context of ESPR, which makes the Digital Product Passport mandatory for all product categories. The Battery Pass must document the carbon footprint, recycled content, performance and durability of each battery. Arianee provides the technical infrastructure to prepare your Battery Passes ahead of the February 2027 deadline.
Battery Pass mandatory
1 February 2027
What is the Battery Pass?
The Battery Pass is the Digital Product Passport specific to batteries, made mandatory by Regulation (EU) 2023/1542 on batteries and battery waste. It applies to all rechargeable industrial batteries with a capacity exceeding 2 kWh, electric vehicle batteries and light transport batteries (scooters, electric bicycles).
The Battery Pass is a structured set of data associated with each battery via a unique identifier and QR code. It must be accessible at any time by market surveillance authorities, recyclers and consumers. The data covers the full lifecycle: from manufacture to second life or recycling.
Arianee is positioned as a DPP infrastructure provider for the battery segment, with specific expertise in BMS (Battery Management System) data integration and real-time State of Health updates.
Battery Pass key figures
- Entry into force
- August 2023
- Battery Pass mandatory
- February 2027
- Carbon footprint declaration
- February 2025
- Recycled content thresholds
- 2031 (phase 1), 2036 (phase 2)
- Batteries concerned
- > 2 kWh industrial, EV, light transport
JRC145830 methodology: According to the Commission study, the Battery Regulation (EU 2023/1542) mandates an explicitly defined DPP with the first applicable rules from early 2027.
See also: Full regulations hub • ESPR methodology • JRC publication
Data required in a Battery Pass
The Battery Pass structures data into several categories covering the battery's full lifecycle. Some data is entered at manufacture, other data is updated continuously.
| Category | Data | Source | Frequency |
|---|---|---|---|
| Identity | Manufacturer, model, serial number, manufacturing date | Manufacturer | At creation |
| Chemical composition | Cell chemistry, active materials, hazardous substances | Manufacturer | At creation |
| Carbon footprint | kg CO2-eq/kWh, breakdown by lifecycle phase | Certified LCA | At creation |
| Recycled content | % recycled cobalt, lithium, nickel, lead | Supply chain | At creation |
| Performance | Nominal capacity, energy, power, internal impedance | Manufacturer tests | At creation |
| Durability | Guaranteed cycles, minimum residual capacity at 1,000/1,500 cycles | Manufacturer tests | At creation |
| State of Health (SoH) | Residual capacity, internal resistance, usage history | BMS / telemetry | Continuous |
| End of life | Dismantling instructions, recoverable materials, recycling channel | Manufacturer | At creation |
Mandatory recycled content thresholds
Regulation (EU) 2023/1542 introduces minimum recycled content thresholds for critical raw materials used in batteries. These thresholds apply in two phases: 2031 and 2036. The Battery Pass must document actual recycled content percentages in a verifiable and auditable manner.
Supply chain traceability is essential to prove compliance. The Arianee DPP allows recycled material origin certificates to be recorded and made accessible to market surveillance authorities.
| Material | 2031 threshold | 2036 threshold |
|---|---|---|
| Cobalt | 16% | 26% |
| Lithium | 6% | 12% |
| Nickel | 6% | 15% |
| Lead | 85% | 85% |
Carbon footprint and performance classes
Since February 2025, manufacturers must declare the carbon footprint of each battery according to the rules of delegated act (EU) 2023/1791. The footprint is calculated over the full lifecycle and expressed in kg CO2-eq per kWh of nominal capacity.
Ultimately, maximum carbon footprint thresholds will be defined by battery category, and an energy performance class system (A to E) will allow consumers to compare batteries. The Battery Pass is the digital medium for this information.
Carbon declaration phases
- Phase 1 (Feb. 2025)Mandatory carbon footprint declaration by the manufacturer
- Phase 2 (Feb. 2026)Introduction of carbon performance classes (A to E)
- Phase 3 (Feb. 2028)Maximum carbon footprint thresholds by category
State of Health (SoH) and dynamic data
A key distinction of the Battery Pass compared to other DPPs: battery health data must be continuously updated throughout its lifespan. The State of Health (SoH) is a key indicator measuring the battery's residual capacity relative to its nominal capacity.
SoH determines the battery's residual value, its ability to access a second life (stationary storage, for example) and recycling decisions. The Battery Pass must make this data accessible in real time.
Arianee integrates data flows from BMS (Battery Management Systems) to update the Battery Pass in real time: residual capacity, number of cycles, operating temperature, critical events. This integration relies on standardised APIs compatible with the main BMS providers on the market.
How Arianee meets Battery Pass requirements
Arianee provides the technical infrastructure to create, manage and update Battery Passes aligned with Regulation (EU) 2023/1542 requirements.
Unique battery identifier
Each battery receives a unique identifier linked to a QR code readable throughout its lifespan, including in second life.
Structured carbon footprint
Carbon footprint data is stored according to the schemas defined by delegated act (EU) 2023/1791, with breakdown by lifecycle phase.
Real-time BMS integration
Standardised APIs to connect Battery Management Systems and continuously update SoH, cycles and critical events.
Materials traceability
Verifiable recording of recycled content (cobalt, lithium, nickel, lead) with origin certificates from the supply chain.
Second life and recycling
The Battery Pass follows the battery in second life: new owner, new application, updated performance. Dismantling instructions for recyclers.
Regulatory compliance
Structured data access for market surveillance authorities. Export in formats required by the European Commission.
Frequently asked questions about the Battery Pass
When does the Battery Pass become mandatory?
What data must a Battery Pass contain?
How is a battery's carbon footprint calculated?
What are the recycled content requirements for batteries?
How does Arianee help prepare for the Battery Pass?
Ready for the Battery Pass?
Our experts support you in implementing your Battery Pass aligned with Regulation (EU) 2023/1542 before the February 2027 deadline.
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