Battery passport for electric buses and trucks
Legally the same regime as passenger cars — 51 mandatory data points — but a radically different operating context: depot fleets, availability contracts, packs swapped mid-life, and public tenders that already demand traceability.
Electric vehicle battery — 51 of 71 data points mandatory
on 18 February 2027
Buses fall under categories M2 and M3, trucks under N2 and N3. Their traction batteries therefore meet the definition of an electric vehicle battery in Article 3, under the same regime as passenger cars: 51 of the 71 data points mandatory on 18 February 2027, and no capacity threshold.
Applicable threshold. No capacity threshold. The criterion is the category of the vehicle being driven, not the size of the pack — which brings low-capacity plug-in hybrid configurations into scope.
Source: Regulation (EU) 2023/1542 and the European Commission guidance document "Digital Batteries Passport – data points by category", version 2.0 of 15 August 2026, which lists 71 data points and their applicability by battery category.
What is in scope, and what is not
Subject to the passport
- Traction packs in electric city buses and coaches (M2, M3)
- Traction packs in electric trucks and road tractors (N2, N3)
- Batteries in plug-in hybrid configurations of those categories
- Replacement packs fitted in service after 18 February 2027
Out of scope
- Ancillary batteries and SLI batteries in combustion vehicles, outside Article 77
- Traction batteries in non-road machinery, which fall under the industrial battery regime
What you actually have to produce on 18 February 2027
Not every data point in the passport is due when it opens. The Commission guidance distinguishes, for each battery category, what is mandatory at the deadline from what is still waiting for its legal framework. Scoping the project against the full list means over-investing; ignoring the distinction means rebuilding in two years.
Mandatory at the deadline
- ✓Unique identifier per pack and economic operator identifier
- ✓Manufacturer, model, date and place of manufacture
- ✓Chemistry, critical raw materials and hazardous substances
- ✓Capacity, energy, power and expected cycle life
- ✓State of health and usage history, restricted to legitimate interested parties
- ✓Disassembly instructions and end-of-life information
Not yet due — and why
- ○Carbon footprint declaration: on hold pending adoption of the delegated act on calculation methodology
- ○Responsible sourcing: the Article 48 due diligence obligation is postponed to 18 August 2027
- ○Recycled content declaration: due from 18 August 2028, with minimum thresholds on 18 August 2031
Also worth tracking: supply chain due diligence obligations (Article 48), postponed to 18 August 2027 by Regulation (EU) 2025/1561, with an exemption for companies with a turnover below EUR 40 million.
Where the data comes from in this sector
The hard part of a Battery Pass project is almost never the passport itself: it is knowing who holds each piece of data, how often it changes, and who is entitled to read it. Article 77 and Annex XIII impose tiered access — not every mandatory data point is public.
| Data | Who holds it | Frequency | Access |
|---|---|---|---|
| Pack identifier and configuration | Vehicle manufacturer and traction system integrator | At creation | Public |
| Chemistry and critical raw materials | Cell maker, through the manufacturer | At creation | Interested parties |
| Capacity and contractual service life | Manufacturer testing and warranty commitments | At creation | Public |
| State of health per vehicle and per pack | BMS, relayed by the depot fleet management system | Continuous | Interested parties |
| Pack swaps and major interventions | Operator or contracted maintainer workshop | Per intervention | Interested parties |
| End of life and treatment route | Manufacturer and approved recycler | At creation | Public |
How state of health gets in when the battery is not connected
State of health is the only passport data that has to stay alive after the battery is placed on the market. The market talks about connecting to the BMS as if it were a given — it is not: most batteries in service report nothing continuously. Three routes coexist, and on this segment it is bms connection that is the realistic default.
The BMS reports state of health continuously, through vehicle telematics or site supervision. The finest-grained option, but it assumes connected equipment and a data flow that already exists.
Fleet telematics are already in place at virtually every depot: per-pack readings travel through them natively.
With Arianee — Event-based write API: each reading updates the passport of the battery concerned, with no re-issuance, timestamped and attributed to its source.
Readings are extracted periodically from an existing system — supervision, fleet management, connected chargers, ERP — and loaded in batches. The realistic route when the data exists but is not exposed in real time.
Extraction from the depot management system, useful when several maintainers share the fleet.
With Arianee — Bulk import from the Management Hub or by API: one file or feed updates thousands of passports in a single operation, with a per-line error report.
The technician scans the battery's QR code and enters or confirms the reading on the spot — in the workshop, in store, in the plant room. The only route when the battery is not connected, and the most reliable evidence that an intervention took place.
In the workshop, particularly when packs are swapped between vehicles, to record the allocation and the condition at removal.
With Arianee — Passport Portal: the scan opens the battery's passport with the technician's rights, and they write their reading and their intervention. Works for a network of third-party workshops without opening the rest of the fleet to them.
The three routes feed the same passport and are not mutually exclusive: a mixed estate usually combines a BMS feed on recent equipment, a batch import for the installed base, and a field reading for anything that comes through the workshop. Every write is timestamped and attributed to its source, which is what makes the history hold up under inspection.
The three hard parts specific to this sector
The pack does not stay in the same vehicle
Across a bus fleet, packs are swapped between vehicles as downtime and uneven degradation dictate. The passport is attached to the battery: the system has to track which vehicle a pack is assigned to over time, without conflating the two objects.
Availability contracts and shared responsibility
The manufacturer places the battery on the market and carries the passport obligation, but it is usually the contracted maintainer that holds the usage history. Passport writing has to be opened to a third party without giving them access to everything.
Requirements already in the tender documents
Transport authorities ask for sustainability and traceability commitments well before the regulatory deadline. The passport becomes a contractual deliverable before it becomes an obligation.
What the passport gives you beyond compliance
A battery passport reduced to an obligation stays a cost. The same data, properly structured, serves operations and the residual value of the fleet.
Managing degradation across the depot
Comparing state of health across packs in one fleet exposes the differences driven by duty cycles, and lets you rebalance rotations before degradation turns into downtime.
End of contract and buy-back value
On multi-year contracts, the buy-back value of the vehicles depends directly on the documented condition of the batteries. The passport provides that evidence in a form that can be relied on.
Answering public tenders
Documenting battery traceability and regulatory compliance at bid stage turns a regulatory constraint into a commercial differentiator.
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 — Buses & trucks
Do electric buses and trucks fall under the same regime as cars?+
Yes. Buses fall under categories M2 and M3, trucks under N2 and N3: their traction batteries meet the definition of an electric vehicle battery in Article 3 of Regulation (EU) 2023/1542. The regime is identical to passenger cars — 51 of the 71 data points mandatory on 18 February 2027, with no capacity threshold.
Does a pack swapped between two vehicles need a new passport?+
No. The passport is attached to the battery, not to the vehicle. A pack removed from one bus and fitted to another keeps its passport and its unique identifier; what changes is the vehicle assignment, and that assignment has to remain traceable in the history.
Does the fleet operator have to create the passports?+
No. The obligation falls on the economic operator placing the battery on the Union market, that is the manufacturer or the importer. The operator does hold part of the data to be maintained during service — state of health, interventions — and therefore needs to be able to write to the passport without owning it.
What about buses bought before February 2027?+
The obligation attaches to batteries placed on the market from 18 February 2027. Vehicles delivered before that date need no retrospective passport, but any replacement pack acquired afterwards is covered.