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.
In brief
The battery passport is the Digital Product Passport for batteries, made mandatory by Regulation (EU) 2023/1542. From 18 February 2027, every industrial battery above 2 kWh, electric vehicle battery or light means of transport (LMT) battery placed on the EU market must have a digital passport accessible via QR code. It must document the carbon footprint (kg CO2-eq/kWh), recycled content (cobalt, lithium, nickel, lead), performance, durability and state of health (SoH) of the battery. It is the first DPP made mandatory in Europe. Arianee, a DPP infrastructure provider in production since 2018 (4M+ passports deployed, 50+ brands), provides the technical layer.
Battery Pass mandatory
18 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.
The Battery Pass in your industry
The category your battery belongs to — LMT, electric vehicle or industrial — determines how many data points are mandatory and which timetable applies. A bicycle and a tram do not fall under the same regime.
LMT battery
Industrial battery
Electric vehicle battery
Electric vehicle battery
Industrial battery
Industrial battery
Industrial battery
LMT or electric vehicle battery
François Pujo
Industrial & Battery Project Manager
François is our Battery Pass expert, working alongside industrial players worldwide to integrate DPP into their production lines and across the entire life of the product.
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?
Official sources
Every requirement stated on this page comes from the following primary texts.
- Regulation (EU) 2023/1542 concerning batteries and waste batteries
Official Journal of the European Union
The founding text of the battery passport. Article 77 establishes the passport; Article 13(6) mandates the QR code giving access to it; Annex XIII sets out the mandatory information.
- Regulation (EU) 2023/1542 — consolidated version
EUR-Lex
Kept up to date with successive amendments. Use this version to check a threshold or deadline currently in force.
- Batteries — EU policy and regulatory framework
European Commission — DG Environment
The Commission's reference page: application timeline, expected delegated acts and guidance documents.
- Regulation (EU) 2024/1781 establishing a framework for ecodesign (ESPR)
Official Journal of the European Union
The general Digital Product Passport framework, of which the battery passport is the first mandatory application. See Article 13 for the central DPP registry.
- Digital Product Passport — methodological framework (JRC145830)
European Commission — Joint Research Centre (JRC)
Reference methodology published on 19 March 2026 (121 pages): DPP data structure, identifiers and data carriers.
Go further on the battery passport
Ten detailed analyses, sourced in Regulation (EU) 2023/1542 and the European Commission guidance of 15 August 2026.
The 71 data points of the Commission guidance
46 mandatory points for EV, 49 for LMT, 32 for industrial — and what must not be filled in.
Who can access which data?
The three access levels of Article 77(2) and the missing implementing act.
Which batteries are in scope?
Article 77(1) scope, portable and SLI exclusions, QR code for all batteries.
The full timeline from 2023 to 2036
Firm deadlines, conditional carbon footprint, recycled content.
Due diligence: the postponement to 18 August 2027
What Regulation (EU) 2025/1561 changes and how it links to the passport.
Who is legally responsible?
Article 77(4), importers, distributors treated as manufacturers, second life.
Unique identifier, QR code and standards
ISO/IEC 15459, GS1 Digital Link, EN 18216 to 18223.
The Article 77(10) obligation
Uploading the unique identifier to the central EU DPP registry.
What are the penalties for non-compliance?
Article 93, market surveillance, withdrawal and recall.
Test your passport before February 2027
Four reference sets and a six-point test plan.
Are you ready for the EU DPP Registry?
Assess your DPP compliance in 10 questions — instant personalised result.