Electric vehicle (EV) batteries are one of the four categories named in Article 77(1) of Regulation (EU) 2023/1542 that require a digital battery passport. From 18 February 2027, an EV battery may not be placed on the market or put into service unless it has a passport, and the obligation rests with the economic operator that places the battery on the market (typically the manufacturer or its authorised representative).
The passport is per battery, not per model or batch
Article 77(1) is explicit: the passport is established for "each battery". A model-level or batch-level passport is not compliant. Each physical EV pack carries a unique identifier and resolves to its own passport via the QR code printed on the battery (Article 13 and Annex VI Part C). For manufacturers shipping thousands of packs, this means passport issuance has to be automated against production data, not authored by hand.
| Attribute | Requirement under 2023/1542 |
|---|---|
| Scope | EV batteries (traction batteries for L, M, N category vehicles) |
| Passport granularity | One passport per physical battery (Art. 77(1)) |
| Carrier | QR code on the battery linking to the passport (Art. 13, Annex VI) |
| Deadline | 18 February 2027 |
| Data retention | Passport available for the battery lifetime; data kept until end of life |
| Access tiers | Public, legitimate interest + Commission, notified bodies + authorities (Annex XIII) |
What data the passport must expose
Annex XIII defines the data set and, crucially, who may see each field. Some information is public (battery chemistry, manufacturer identity, carbon footprint class, recycled content). Other information is restricted to parties with a legitimate interest and the Commission, or to notified bodies, market surveillance authorities and the Commission. A compliant passport enforces these access tiers at the data level rather than publishing everything.
Frequently asked
Can one passport cover a whole production run of identical EV batteries?
No. Article 77(1) requires a passport for each individual battery. Identical specification does not allow a shared passport; each pack needs its own unique identifier and its own resolvable passport.
Who is legally responsible for the EV battery passport?
The economic operator placing the battery on the EU market. For a manufacturer selling directly into the EU that is the manufacturer; otherwise it can be an authorised representative or, for imports, the importer.