Batteries used for propulsion and auxiliary power in vessels and rail vehicles are industrial batteries under Regulation (EU) 2023/1542. The EV category in the regulation is tied to type-approved road vehicles of categories L, M and N, so ships and trains do not fall under the EV definition — their batteries are treated as industrial batteries instead. Above 2 kWh, which marine and rail propulsion packs comfortably exceed, they fall within the Article 77(1) passport obligation from 18 February 2027.
Not EV batteries — industrial batteries
It is a common misconception that any traction battery is an EV battery. The EV category is defined by reference to road-vehicle type approval. Marine and rail batteries sit outside that definition and are classified as industrial. The practical effect is the same passport obligation above 2 kWh, with the carbon-footprint and performance/durability requirements attaching at that threshold and the data set following Annex XIII.
| Application | Category | Passport |
|---|---|---|
| Marine propulsion battery | Industrial | Required > 2 kWh, from 18 Feb 2027 |
| Marine auxiliary / hotel load | Industrial | Required > 2 kWh, from 18 Feb 2027 |
| Rail propulsion battery | Industrial | Required > 2 kWh, from 18 Feb 2027 |
| Rail auxiliary battery | Industrial | Required > 2 kWh, from 18 Feb 2027 |
Article 77(1) requires one passport per physical battery. A vessel or train system built from multiple battery units cannot share a single passport — each battery placed on the market carries its own unique identifier (Annex VI Part C) and resolves to its own passport via the QR code. Builders and integrators should drive issuance from serial data rather than authoring passports by hand.
Frequently asked
Are marine and rail batteries EV batteries under the regulation?
No. The EV category is defined by reference to type-approved road vehicles of categories L, M and N. Ship and train batteries fall outside that definition and are treated as industrial batteries, which carry the passport obligation above 2 kWh.
Do marine and rail batteries need a passport?
Yes, where they exceed 2 kWh — which propulsion and most auxiliary packs do. As industrial batteries above the threshold they are within the Article 77(1) digital passport obligation from 18 February 2027, one passport per physical battery.