EU Battery Passport: Scope and Responsibilities Under the EU Battery Regulation

The EU Battery Regulation (EUBR) makes batteries the first product category that needs a mandatory Digital Product Passport. Under Article 77 of Regulation (EU) 2023/1542, every in-scope battery placed on the market or put into service from February 18, 2027, must have a battery passport. The passport is an electronic record, accessible via QR code, that links regulated information to the individual battery. 

The deadline is often framed as a task for battery manufacturers. In practice, it also reaches vehicle OEMs, e-mobility brands, importers, energy storage integrators, and industrial equipment makers. What a company needs to prepare depends on two things, the batteries it places on the EU market and the role it takes for each of them. 

Batteries that need a battery passport from February 2027

The passport obligation applies to three battery categories: 

• EV batteries are traction batteries for passenger cars, buses, vans, and trucks.
• LMT batteries power e-bikes, e-scooters, e-mopeds, and similar light means of transport, provided the battery weighs no more than 25 kg.
• Industrial batteries above 2 kWh include stationary battery energy storage systems as well as onboard batteries in machinery such as forklifts and automated guided vehicles. 

The obligation is triggered when a battery is placed on the EU market or put into service. Putting into service covers the first use of a battery in the EU without a prior placing on the market. 

Note: Portable batteries and SLI (starting, lighting, and ignition) batteries remain subject to other EUBR obligations, such as labeling and QR code requirements, but they fall outside the February 2027 passport obligation. 

Same deadline, different starting points 

The legal date is identical for every in-scope battery, and the effort to reach readiness varies by battery type. 

• EV batteries typically follow the most structured data chain. Cells come from nominated suppliers, packs are integrated into a defined vehicle architecture, and the battery can stay linked to the vehicle through identifiers such as the VIN.
• Energy storage systems often involve several legal entities across cell and module production, system integration, import, and site commissioning. The entity placing the system on the market or putting it into service carries the passport, while much of the required data sits with upstream suppliers.
• LMT batteries are frequently sourced from outside the EU and sold under the brand of a mobility company. Supplier data maturity varies, and smaller companies in this segment often underestimate the obligation.
• Industrial equipment with onboard batteries is a practical risk scenario within the industrial battery category. When a battery above 2 kWh is managed internally as a machine component, the passport obligation can go unnoticed until late. 

Who is responsible for the battery passport 

The EU Battery Regulation assigns obligations to economic operators, a role family that includes manufacturers, authorized representatives, importers, and distributors. Passport responsibility sits with the economic operator that places the in-scope battery on the EU market or puts it into service. Responsibility therefore follows the role a company takes for a specific battery, regardless of how it describes its own business. 

Under Article 44, an importer or distributor is treated as the manufacturer in three cases: 

• The first is when it places a battery on the market under its own name or trademark.
• The second is when it modifies a battery already on the market in a way that may affect compliance.
• The third is when it changes the battery's purpose. 

In practice, these actors are most likely to carry passport responsibility: 

• Battery manufacturers whose name or trademark appears on the battery.
• Automotive OEMs that source batteries and place them on the EU market under their own label.
• Energy storage system integrators that place systems on the EU market or put them into service.
• Importers that bring non-EU batteries onto the EU market, as well as importers or distributors that rebrand or modify batteries.
• Industrial equipment manufacturers that import onboard batteries above 2 kWh, place them on the market under their own name, or modify them. 

Two points are often overlooked. First, composition, sourcing, and performance data may originate several tiers upstream, yet the responsible economic operator remains accountable for the passport. Second, the same applies when a software provider builds and operates the passport platform. The manufacturer or importer still holds legal responsibility for the passport's accuracy, completeness, and updates. 

The osapiens Battery Passport guide, developed with insights from TÜV SÜD, looks at each battery scenario and the assurance questions behind passport responsibility.  

What the battery passport covers

Annex XIII sets out the passport content. It ranges from identity and material data, such as chemistry, capacity, and critical raw materials, to performance values, state of health, and dismantling information. Access is tiered. Some information is public via the QR code, while more detailed data is reserved for persons with a legitimate interest and for authorities. Some fields, including the carbon footprint declaration and recycled content shares, follow at a later stage according to Commission guidance. 

Which fields apply to each battery category, and where each one comes from, is where most of the preparation work sits. 

The osapiens Battery Passport guide

The osapiens Battery Passport guide brings together osapiens' product data perspective and TÜV SÜD's expertise in testing, certification, and technical verification. It covers four areas.

• Battery scenarios for EV, ESS, LMT, and industrial equipment, with the data workload each one creates
• Passport content and access across the Annex XIII data categories and access tiers
• The assurance gap between software providers and manufacturers, from TÜV SÜD's perspective
• A four-phase runway to February 18, 2027, from data inventory to go-live

The guide also shows how the osapiens HUB for Digital Product Passport builds each passport on the product, supplier, and compliance data companies already manage.