Backup batteries for telecom sites and uninterruptible power supplies (UPS), including data-centre and critical-infrastructure backup, are industrial batteries under Regulation (EU) 2023/1542. They are designed for industrial and stationary use, and the larger systems exceed 2 kWh, so they fall within the Article 77(1) digital passport obligation that applies from 18 February 2027.
Stationary backup is treated as industrial
The regulation treats batteries designed for energy storage and stationary backup as industrial batteries, which places UPS and telecom backup systems alongside other industrial batteries for passport purposes. The carbon-footprint and performance/durability requirements again attach above the 2 kWh threshold, so larger telecom and UPS installations carry the full information set under Annex XIII.
| Backup application | Typical capacity | Passport |
|---|---|---|
| Data-centre UPS | > 2 kWh | Required from 18 Feb 2027 |
| Telecom site backup | > 2 kWh | Required from 18 Feb 2027 |
| Building / facility UPS | > 2 kWh | Required from 18 Feb 2027 |
| Small UPS unit | <= 2 kWh | Outside the > 2 kWh passport scope |
As with all passport categories, Article 77(1) requires per-battery granularity: one passport per physical battery placed on the market, with its own unique identifier and QR code. A telecom estate or a data-centre hall made up of many discrete battery units cannot share a single passport — each unit placed on the market needs its own.
Frequently asked
Are UPS and telecom backup batteries portable or industrial?
Industrial. They are designed for industrial and stationary backup use, so above 2 kWh they fall under the Article 77 digital passport obligation rather than the portable-battery regime.
Does each backup string or module need its own passport?
You issue a passport for each battery as placed on the market. Where each module or unit is the battery placed on the market, each needs its own unique identifier and passport; a single site-wide passport is not compliant.