Under Regulation (EU) 2023/1542 the obligation to provide a digital passport sits with the economic operator that places the battery on the EU market. For batteries manufactured outside the EU, that operator is usually the importer. "Placing on the market" means the first making available in the Union, so the importer cannot assume a foreign manufacturer has discharged the obligation.
Which imported batteries need a passport
The passport is required for the four categories in Article 77(1): EV batteries, LMT batteries, industrial batteries above 2 kWh, and (under the regulation as it develops) the batteries within its scope as the relevant provisions apply. Portable batteries are outside the Article 77 passport obligation. The deadline is 18 February 2027.
| Imported battery | Passport obligation falls on |
|---|---|
| EV battery from a non-EU maker | Importer placing it on the EU market |
| LMT / e-bike battery imported | Importer |
| Industrial battery > 2 kWh imported | Importer |
| Battery sold via an EU authorised rep | Authorised representative / the operator placing it on market |
In practice an importer must collect the Annex XIII data from the manufacturer, then generate and host a compliant per-battery passport, with a QR code on each battery and the correct access tiers. Importers handling diverse product lines from multiple suppliers benefit most from automated, self-serve issuance rather than per-supplier integration projects.
Frequently asked
If my supplier already made a passport, do I still need one?
The obligation is on the operator placing the battery on the EU market. If you are the importer, you are responsible for ensuring a compliant passport exists for each battery you place on the market, even if a supplier provides data or a partial passport.
Does importing portable batteries trigger the passport obligation?
No. Portable batteries are outside the Article 77 digital passport obligation. The passport applies to EV, LMT and industrial (> 2 kWh) batteries.