Compliance with Article 77(1) is binary per battery: either an in-scope unit placed on the EU market from 18 February 2027 has a conformant passport, or it does not. This checklist turns the requirement into items you can tick off.
Readiness checklist
| Area | What must be in place | Done when |
|---|---|---|
| Scope | Confirmed the battery is LMT, industrial >2 kWh, or EV | Scope decision recorded |
| Identifier | Per-item unique identifier conforming to ISO/IEC 15459 | Every unit has a distinct ID |
| Data set | Full Annex XIII / Annex VI attribute set collected | No required field left blank |
| Access tiers | Each field mapped to public / legitimate interest / authority / Commission | Tier assignment reviewed |
| Data carrier | Print-grade QR (ISO/IEC 18004) on or with the battery | QR scans to the passport |
| Hosting | Permanent URL that survives the retention period | Slug fixed and published |
| Lifecycle | Process to update state of health, repurpose, recycle | Update path defined |
Common gaps
- Using a single model-level or batch-level passport instead of one per physical battery.
- Leaving restricted fields exposed on the public page rather than enforcing tiers server-side.
- No plan for updating dynamic data after the battery leaves the factory.
- A QR printed too small or at too low an error-correction level to survive a label.
Work through scope first, then data, then identifiers and tiers. A self-serve passport platform covers identifiers, tiers, QR and hosting in one flow, and helps with the data itself by mapping your existing files and requesting missing fields from suppliers. Collecting that data is the part that needs your lead time.
Frequently asked
When should we start preparing the checklist?
Start with data collection now. Carbon footprint, recycled content and due-diligence data take the longest to assemble; identifiers, tiers, QR and hosting can be set up quickly once the data exists.