Battery passport for data centres, UPS and standby power
This is the segment most often overlooked, although the volumes are considerable: UPS and standby batteries above 2 kWh are industrial batteries, subject to the passport from 18 February 2027.
Industrial battery above 2 kWh — 36 of 71 data points mandatory
on 18 February 2027
A UPS or standby battery performs an energy storage function in a professional environment: it falls within the industrial battery category of Regulation (EU) 2023/1542. Above 2 kWh — a threshold crossed by virtually every data centre and commercial site installation — the passport becomes mandatory on 18 February 2027.
Applicable threshold. A 2 kWh threshold, assessed on the battery placed on the market. Data centre battery cabinets exceed it comfortably; small desktop UPS units may stay below.
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
- UPS and uninterruptible power supply batteries above 2 kWh
- Battery cabinets and racks in computer rooms
- Standby batteries on industrial, hospital and telecom sites
- Replacement batteries placed on the market after 18 February 2027
Out of scope
- Individual desktop UPS units of 2 kWh or less
- Portable batteries built into IT equipment, outside Article 77
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 and economic operator identifier
- ✓Manufacturer, model, date and place of manufacture
- ✓Chemistry — sealed lead-acid or lithium — critical raw materials and hazardous substances
- ✓Capacity, voltage, autonomy and expected service life
- ✓State of health and usage history, restricted to legitimate interested parties
- ✓Disassembly, safety and end-of-life handling instructions
Not yet due — and why
- ○Carbon footprint declaration: on hold pending the delegated act on calculation methodology
- ○Responsible sourcing: due diligence postponed to 18 August 2027
- ○Recycled content declaration: due from 18 August 2028, with a recycled lead threshold of 85 % 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 |
|---|---|---|---|
| Block or rack identifier | Battery manufacturer, distinct from the UPS manufacturer | At creation | Public |
| Chemistry and recycled content | Battery manufacturer and material supplier | At creation | Interested parties |
| Capacity, autonomy, expected service life | Manufacturer testing | At creation | Public |
| State of health and discharge test results | Site supervision and periodic test campaigns | Periodic | Interested parties |
| Block replacement | Maintenance contractor | Per intervention | Interested parties |
| Take-back 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 field agent 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.
On recent lithium cabinets, whose BMS is wired into site supervision.
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.
Feed from the building management system or site supervision, by replacement wave and by site.
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.
The structural route: discharge test campaigns are already planned and carried out on site. The contractor scans the block and records the result, which is enough to keep state of health current.
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
An estate renewed in waves
Blocks are replaced every four to eight years, in batches, site by site. The passport has to accompany a continuous flow of replacements rather than a single placing on the market, and the infrastructure has to absorb those waves without a project each time.
Outsourced maintenance
Test campaigns and replacements are contracted out. The most reliable state of health data is held by a third party, who must be able to write to the passport without accessing the rest of the estate.
A segment that does not know it is in scope
Data centre operators do not see themselves as battery industry actors. The first piece of work is scoping: identifying which of their installations cross the 2 kWh threshold.
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.
Evidence for site audits
Operating certifications and customer audits call for traceability of critical equipment. The passport provides a verifiable inventory of the batteries and their condition.
Anticipating replacements
A consolidated state of health history across the estate turns replacement campaigns into something you budget for rather than something you absorb.
Lead take-back and recycling
The lead recycling chain is mature and the recycled content threshold will be high. Documenting the origin and destination of blocks secures compliance and the relationship with the recycler.
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 — Data centres & UPS
Are UPS batteries subject to the battery passport?+
Yes, above 2 kWh. An uninterruptible power supply battery performs an energy storage function in a professional environment and falls within the industrial battery category of Regulation (EU) 2023/1542. The passport becomes mandatory for such batteries placed on the market from 18 February 2027, with 36 of the 71 data points listed by the Commission.
Does a data centre operator have to create the passports for its batteries?+
No, unless it imports the batteries itself. The obligation falls on the economic operator placing the battery on the Union market — manufacturer or importer. The operator does have an interest in requiring compliant passports from its suppliers contractually, and in being able to feed in the usage data held by its maintenance contractors.
Are sealed lead-acid batteries covered?+
Yes. Chemistry does not determine the regime: a lead-acid standby battery above 2 kWh is an industrial battery subject to the passport. Lead is also subject to the highest recycled content threshold in the Regulation, 85 % from 18 August 2031.