Traction batteries for forklifts, pallet trucks, reach trucks and other material-handling equipment are industrial batteries under Regulation (EU) 2023/1542. They are designed for industrial use and routinely exceed 2 kWh in capacity, which places them within the Article 77(1) digital passport obligation that takes effect on 18 February 2027.
Why the 2 kWh threshold is almost always met
The full passport, carbon-footprint and performance/durability requirements apply to industrial batteries with a capacity greater than 2 kWh. Forklift and material-handling traction packs are typically far above this threshold, so they attract the complete passport regime rather than any lighter treatment. Lead-acid and lithium traction batteries alike are caught where they meet the industrial definition and capacity.
| Equipment | Typical capacity | Passport |
|---|---|---|
| Counterbalance forklift | > 2 kWh | Required from 18 Feb 2027 |
| Reach truck / order picker | > 2 kWh | Required from 18 Feb 2027 |
| Powered pallet truck | > 2 kWh (usually) | Required from 18 Feb 2027 |
| Small material-handling battery | <= 2 kWh | Outside the > 2 kWh passport scope |
Article 77(1) requires one passport per physical battery. A fleet of identically specified forklift batteries cannot share a single passport — each pack carries its own unique identifier under Annex VI Part C and resolves to its own passport via the QR code. For fleet operators and battery suppliers this means issuance has to be driven from serial data rather than authored by hand.
Frequently asked
Are forklift traction batteries in scope of the passport?
Yes. They are industrial batteries, and where capacity exceeds 2 kWh — which is typical for traction packs — they fall under the Article 77(1) digital passport obligation from 18 February 2027.
Can one passport cover a fleet of identical forklift batteries?
No. Article 77(1) requires a passport for each individual battery. Each pack needs its own unique identifier and its own resolvable passport, regardless of identical specification.