The February 2027 Mandate.
By February 18, 2027, every LMT battery, industrial battery > 2kWh, and EV battery sold in the EU must carry a digital Battery Passport. Most supply chains are not ready.
What is the Battery Passport?
The EU Battery Passport is a digital record that stores and communicates critical information about a specific battery model (and in some cases, individual batteries) across its lifecycle. It acts as a digital twin, accessible via a physical QR code printed or engraved on the battery itself.
Conceived as a cornerstone of the European Green Deal and the Circular Economy Action Plan, the passport's intent is radical transparency. It forces manufacturers to disclose the exact chemical composition, carbon footprint, recycled content, and durability metrics of their cells.
Read the full explainerWho does this affect?
-
EV Manufacturers Electric vehicle batteries are strictly regulated, requiring per-model and eventual per-unit passports.
-
Light Means of Transport (LMT) E-bikes, e-scooters, and mopeds fall under the exact same stringent requirements.
-
Industrial Batteries (>2kWh) Grid storage, telecom backups, and heavy machinery power systems.
The Data Requirements
The regulation mandates approximately 90 distinct data attributes to be collected, verified, and hosted. These are grouped into distinct categories governing materials, performance, and circularity.
| Category | Key Attributes | Access Level |
|---|---|---|
| General Info | Manufacturer details, manufacturing facility, date of manufacture, weight, battery category. | Public |
| Material Composition | Chemistry type, hazardous substances, critical raw materials (Cobalt, Lithium, Nickel, Lead). | Public |
| Carbon Footprint | Total carbon footprint declaration, carbon footprint performance class, share of carbon footprint per life cycle stage. | Public |
| Recycled Content | Share of Cobalt, Lithium, Nickel, and Lead recovered from waste present in active materials. | Public |
| Performance & Durability | Rated capacity, nominal voltage, expected cycle life, internal resistance. | Restricted (Operators/Authorities) |
| End of Life (EoL) | Manual for removal/dismantling, safety instructions for repurposing. | Restricted (Recyclers) |
Decentralized by Design
The EU does not provide a central database to host your data. Instead, the regulation mandates a decentralized system. Manufacturers must host their own passport data (or use a third-party SaaS provider) and ensure it is accessible via standard protocols.
The data must be machine-readable, utilizing open standards for interoperability. Furthermore, the system must support granular access control (Role-Based Access Control), as certain data fields are public while others are restricted to regulatory authorities or certified recyclers.
Architecture GuidelinesThe Carbon Footprint Hurdle
First Declarations Due
Before the digital passport itself goes live in 2027, manufacturers must begin submitting Carbon Footprint Declarations. For EV batteries, this requirement begins as early as February 18, 2025.
This is arguably the most mathematically complex requirement of the regulation. You cannot use generic industry averages. You must calculate the footprint specific to your manufacturing facility and supply chain, measuring CO2 equivalents per kWh of battery energy.
Calculate your exposure
Use our estimator to understand the data points required for a compliant PEF (Product Environmental Footprint) calculation.
Open Carbon EstimatorCommon Implementation Failures
Ignoring Sub-Tier Suppliers
Tier 1 assembly data is insufficient. You need primary data tracing back to the mine for critical raw materials (Li, Ni, Co) to prove recycled content and environmental impact.
Guide: Supplier MappingStatic PDF Thinking
The passport is not a PDF uploaded to a website. It is a live, machine-readable dataset requiring an API. Hardcoding static HTML pages will fail compliance audits.
Guide: API RequirementsOverlooking Due Diligence
Alongside technical data, Annex X requires a comprehensive supply chain due diligence policy addressing human rights and environmental risks in sourcing.
Guide: Due Diligence PoliciesComplete Guide Index
Core Concepts
Technical Execution
Environmental Metrics
Frequently Asked Questions
Does this apply to consumer electronics?
Who is responsible for creating the passport?
Are PDFs allowed for documentation?
"Transparency is no longer a marketing exercise. It is a strict market entry requirement for the European Union."
The Path to Compliance
Don't wait for 2027
Supply chain data integration takes an average of 14-18 months. Start evaluating your readiness today.
Latest Technical Guides
How to build a decentralized, API-first hosting environment for your battery data that complies with EU interoperability standards.
A deep dive into the methodology required for the 2025 EV battery carbon footprint declarations.
Master the Regulation
Start by reading our foundational explainer, which breaks down the entire 300+ page regulation into actionable technical requirements.
Read: What is the Battery Passport?