Battery passport for forklifts, AGVs and material handling equipment
Forklifts, aerial work platforms, AGVs: industrial batteries above 2 kWh, run as fleets and often on rental. 36 mandatory data points, and a state of health that directly drives buy-back value at the end of the contract.
Industrial battery above 2 kWh — 36 of 71 data points mandatory
on 18 February 2027
Material handling equipment are not road vehicles of categories L, M, N or O: their traction batteries fall under the industrial battery regime. The passport is required above 2 kWh — a threshold exceeded by virtually every forklift and platform battery, lead-acid or lithium alike.
Applicable threshold. A 2 kWh threshold. Traction batteries on handling equipment almost always exceed it; low-capacity ancillary batteries may still fall 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
- Traction batteries in electric forklifts and pallet trucks
- Batteries in AGVs and autonomous mobile robots in warehouses
- Batteries in aerial work platforms and compact electric site machinery
- Replacement batteries placed on the market after 18 February 2027
Out of scope
- Ancillary batteries of 2 kWh or less
- Handheld power tools, which fall under the portable battery regime, 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 — lead or lithium — critical raw materials and hazardous substances
- ✓Capacity, voltage, power and expected service life
- ✓State of health and usage history, restricted to legitimate interested parties
- ✓Disassembly, handling and end-of-life 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 — note that the recycled lead threshold, set at 85 % from 2031, bears directly on the lead-acid batteries still dominant on this segment
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 |
|---|---|---|---|
| Battery tray or pack identifier | Traction battery manufacturer | At creation | Public |
| Chemistry and recycled content, lead in particular | Manufacturer and material supplier | At creation | Interested parties |
| Capacity, voltage, warranted cycles | Manufacturer testing | At creation | Public |
| State of health and charge cycles | BMS or connected charger, relayed by fleet management | Continuous | Interested parties |
| Interventions and reassignment between sites | Rental company, maintainer or in-house workshop | 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 batch import 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 connected trucks and AGVs, and on lithium batteries whose BMS is accessible.
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.
The dominant route: connected chargers and the rental company's fleet tools already produce cycle counts and readings, exported in batches.
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 rental company's technician or the in-house workshop scans the battery during visits and when it is reassigned between sites.
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
Long-term rental blurs responsibility
A large share of the installed base is rented. The rental company holds the usage history, the manufacturer carries the passport obligation, and the user operates the machine on its own site. That means three distinct access levels on the same passport.
The shift from lead to lithium
Fleets mix technologies with different requirements, notably on recycled content — 85 % recycled lead expected from 2031. The passport has to carry the right data for the chemistry, rather than a single template.
Multi-site fleets and mobile batteries
Batteries move between sites and between machines as demand dictates. Tracking has to stay with the battery, independent of whichever machine is carrying it at a given moment.
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.
Buy-back value at end of contract
On a five-year rental contract, a documented state of health gives an objective basis for residual value and avoids blind negotiation at handback.
Condition-based maintenance
Tracking real cycle counts and degradation lets you plan replacements before a critical machine in the warehouse goes down.
Consolidated fleet inventory
For a multi-site operator, the passports provide a unified view of the battery fleet, its age and its condition, without depending on each rental company's system.
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 — Material handling
Are forklift batteries subject to the battery passport?+
Yes, where they exceed 2 kWh — which covers virtually every traction battery in material handling. A forklift is not a road vehicle of category L, M, N or O, so its battery falls under the industrial battery regime: 36 of the 71 data points listed by the Commission are mandatory on 18 February 2027.
Are lead-acid batteries covered?+
Yes. The regime depends on the battery's use, not on its chemistry. A lead-acid traction 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.
Who creates the passport for a rented battery?+
The obligation falls on the economic operator placing the battery on the Union market, that is the manufacturer or the importer, whatever the rental arrangement. The rental company and the user do hold usage data that must feed the passport during service, which calls for distinct write permissions.