Battery energy storage systems (BESS) — both grid-scale and behind-the-meter — are classified as industrial batteries under Regulation (EU) 2023/1542. The regulation defines an industrial battery as one designed for industrial uses, and it specifically notes that batteries for energy storage are industrial batteries. As industrial batteries with a capacity above 2 kWh, they fall squarely within the Article 77(1) passport obligation.
Why the 2 kWh threshold matters
Several obligations in the regulation, including the carbon footprint declaration and performance/durability requirements, apply to industrial batteries with a capacity greater than 2 kWh. Stationary storage systems are well above this threshold, so they attract the full set of passport and information requirements rather than the lighter portable-battery regime.
| Battery type | Capacity | Digital passport required? |
|---|---|---|
| Stationary storage (industrial) | > 2 kWh | Yes — from 18 Feb 2027 |
| Industrial battery | > 2 kWh | Yes — from 18 Feb 2027 |
| EV battery | Any | Yes — from 18 Feb 2027 |
| LMT battery | Any | Yes — from 18 Feb 2027 |
| Portable battery | Any | No passport obligation under Art. 77 |
Because a single installed BESS can be made up of many discrete battery units, operators need to decide what constitutes "the battery" for passport purposes and issue one passport per such unit. Article 77(1) again requires per-battery granularity — a single passport for an entire site is not compliant.
Frequently asked
Are stationary storage systems portable or industrial batteries?
Industrial. Regulation (EU) 2023/1542 treats batteries designed for energy storage as industrial batteries, which means the passport obligation under Article 77 applies once capacity exceeds the relevant thresholds.
Does each rack or module need its own passport?
You issue a passport for each battery as placed on the market. Where each module or pack is the unit placed on the market, each needs its own unique identifier and passport; a single site-wide passport is not compliant.