EU Battery Regulation compliance that scales with the mandate

The responsible economic operator is the company that places the battery on the EU market or puts it into service. Usually, that is the EU manufacturer or the importer. For direct sales from outside the EU, it is the seller. Because this company carries the legal responsibility, it must make sure the passport is created, kept up to date and registered in the EU DPP Registry. It can give written permission to another company, such as a cell maker or a service provider, to do the work. The responsibility still stays with the operator.

One per finished battery. A finished battery is a complete, safely working product, and it can contain several cells, modules or packs. Packs that share a BMS or other common components and work as one battery need a single passport. Packs that each work on their own need one each. The 2 kWh threshold follows the same logic: independent units are assessed one by one, and an integrated system by its combined capacity. This is assessed case by case.

Responsibility generally sits with whoever places the finished, fully functional battery on the EU market, and that can shift depending on where final assembly happens. If a customer assembles imported modules into a finished pack, the customer typically becomes the responsible operator at that point, not the party that imported the individual modules.

Because this varies by supply chain structure, it’s worth mapping your specific setup rather than assuming a default.

In February 2027, a battery passport must include the core identity and product data. This covers the unique ID, who made the battery, and where and when it was made. It also covers chemistry, hazardous substances, performance and durability values, the EU declaration of conformity, dismantling information and the battery’s status. Dynamic data applies where relevant.

However, carbon footprint, recycled content and due diligence data are not required yet. The carbon footprint format is still to be set in implementing acts. Recycled content follows Article 8 and its delegated act. The due diligence report is currently required from August 2027. A passport only needs these data when a battery is placed on the market after each requirement applies. Since fields vary by category, check the Commission’s data point guidance.

With a BMS, the passport must carry dynamic data such as state of health and cycle counts. No update frequency is set. At a minimum, update the data when the battery’s status changes or a change is being considered, for example before it is reused, remanufactured or recycled. More frequent updates are needed only when they are technically possible and in proportion to the need.

Without a BMS, the requirement for state of health data does not apply. Status, performance and durability values must still be provided, both when the battery is placed on the market and at every status change. Other usage fields, such as cycle counts and temperature records, have no legal exemption. However, the Commission’s data point guidance marks them “if applicable”, so check which ones are relevant. These fields can be empty when a new battery is first placed on the market.

A simple repair does not need a new passport. Remanufacturing or repurposing does, and so does a waste battery that is prepared for reuse. In these cases, a new operator usually takes over, and the new passport must be linked to the previous one (Article 77(7)). A battery placed on the market before February 2027 also needs a passport if it is remanufactured after the requirement applies, although some exceptions can apply, for example for carbon footprint, performance and durability.

When a battery becomes waste, responsibility passes to the producer, the producer responsibility organisation or the waste operator. Once it is recycled, the passport ceases to exist.