Battery passports are coming in 2027. What should smaller battery companies do now?

A practical guide for manufacturers, importers and smaller battery companies preparing for the EU Battery Passport — without turning it into a major IT project.

If you sell home batteries, industrial batteries or other covered battery products in Europe, 18 February 2027 is a date worth putting in your calendar.

From that date, every electric vehicle battery, every light means of transport (LMT) battery and every industrial battery with a capacity greater than 2 kWh that is placed on the EU market or put into service must have a battery passport.

For a smaller battery company, that can sound like the start of a major compliance and IT project. It does not have to be. The practical place to start is much simpler:

• Determine whether your batteries are in scope.
• Identify who is responsible for the passport.
• Find out which required product data you already have.
• Identify what is missing and where it must come from.
• Build and test the passport for one real battery model.
• Turn that pilot into a repeatable process before February 2027.

The challenge is usually not creating a webpage with a QR code.

1. Does the Battery Passport apply to us?

The EU Batteries Regulation — Regulation (EU) 2023/1542 — defines which batteries require a battery passport. From 18 February 2027:

This means that many home energy storage batteries fall within the scope because they are industrial batteries with a capacity above 2 kWh.

For companies importing or selling batteries manufactured outside the EU, another question quickly follows: who is actually responsible? Do not simply assume that your overseas manufacturer will take care of everything.

The Battery Passport obligations are linked to the economic operator placing the finished battery on the EU market or putting it into service. Your exact role in the supply chain therefore matters. Before thinking about software, start by mapping:

• Who manufactures the finished battery?
• Who imports it into the EU?
• Under whose brand is it sold?
• Who places it on the EU market?
• Which legal entity is responsible for the required information?

That is the first part of Battery Passport readiness.

2. What information goes into a Battery Passport?

This is where the subject can quickly become overwhelming. The European Commission has published implementation guidance bringing together 71 Battery Passport data points and indicating, for the different battery categories, whether individual data points are mandatory, optional, conditionally applicable or currently not required.

But that does not mean that every company should start by filling in 71 boxes.

Broadly, the information can be understood in several groups.

Battery identity

Information that establishes what the battery is and connects the physical battery to its digital record. This includes model and battery identifiers and information relating to the manufacturer and the individual battery.

Composition and sustainability

Depending on applicability, this can include information relating to battery chemistry, materials, substances of concern, critical raw materials, carbon footprint and responsible sourcing.

Performance and durability

Technical characteristics relating to the battery's performance, capacity and expected durability.

Individual battery information

The Regulation explicitly distinguishes between information relating to the battery model and information specific to the individual battery, including information resulting from its use. That distinction has major implications for how the Battery Passport should be designed.

Circularity and end-of-life

Relevant actors may require information to support activities such as repair, dismantling, remanufacturing, repurposing, second life and recycling.

Compliance and supporting evidence

Some information needs to be supported by declarations, reports, certificates or other evidence. And not all information is necessarily visible to everyone. The Batteries Regulation foresees different access rights for the general public, authorities and other actors with a legitimate interest.

A Battery Passport is therefore more than a public product page.

3. Where are we supposed to find all this data?

For many smaller companies, this is the most important question. The good news is: much of the product data probably already exists. The problem is that it may not exist in one system. A typical battery company might have information spread across:

• an ERP or accounting system;
• Excel or CSV files;
• technical datasheets;
• PDFs and certificates;
• test reports;
• supplier documentation;
• a manufacturer's database;
• serial-number records;
• service and warranty systems;
• emails and shared folders.

And if the batteries are manufactured outside Europe, an important part of the technical information may sit with the manufacturer or its suppliers.

So the first real Battery Passport exercise should not be “How do we create a QR code?” It should be:

That is a data-mapping exercise before it is a publishing exercise.

4. Do we need a new ERP or PIM first?

Not necessarily. A Battery Passport should not automatically become an ERP replacement project. For a smaller company, a pragmatic first implementation can start with the systems and files that already exist. For example:

These sources can be mapped into a structured product-data layer and connected to the appropriate digital identities. As volumes grow, manual imports can progressively be replaced with APIs and direct ERP, PIM or other system integrations.

You do not need to solve your entire IT architecture before you can start preparing for Battery Passports. You do need a data architecture that can grow with you.

Explore product data & integrations →

5. One battery model can mean thousands of individual Battery Passports

This is one of the most important architectural aspects of the Battery Passport. The Batteries Regulation requires information relating to the battery model as well as information specific to the individual battery.

Imagine a home battery called HOME 10. Some information is identical for every HOME 10 battery:

• product model;
• chemistry;
• technical specifications;
• manufacturer information;
• documentation.

But the company may sell thousands of physical HOME 10 batteries. Each physical battery can have its own identity:

The architecture therefore needs to distinguish between shared model-level data and individual battery data. You should not need to maintain thousands of independent copies of the same static information.

Instead, individual battery identities can reference shared model data while carrying the information that is genuinely specific to that battery. This is one reason why choosing the right Digital Product Passport architecture matters before scaling.

Explore model, batch and item identity →

6. Is the QR code the Battery Passport?

No. The QR code or other data carrier is the bridge between the physical battery and its digital identity. Behind it sits a wider architecture:

The Batteries Regulation also requires the Battery Passport architecture to be interoperable with other Digital Product Passports required under EU law. The passport must remain accessible free of charge to the relevant actors according to their access rights.

So while the QR code is what a user sees on the battery, the real implementation challenge sits behind it.

7. What about the EU Digital Product Passport Registry?

The European Commission's DPP Registry became operational on 20 July 2026, together with a testing environment. The Registry should not be confused with the Battery Passport itself.

The European system follows a decentralised architecture. The Registry acts as an EU-level indexing service and stores unique identifiers, registration information and high-level metadata rather than simply becoming a central database containing every piece of passport information.

The underlying product data remains the responsibility of the relevant economic operator and can be hosted by that operator or through a Digital Product Passport service provider.

For battery companies, this means that preparing a Battery Passport involves more than designing a consumer-facing page. The physical battery, unique identifier, product data, access rights, data carrier and EU infrastructure ultimately need to work together.

8. A practical 90-day Battery Passport plan

If you have not started yet, the most important advice is:

Weeks 1–2 — Determine the scope

Choose one representative battery model. Establish:

• whether it falls within the Battery Passport requirement;
• which legal entity places it on the EU market;
• where it is manufactured;
• how it is currently identified;
• annual volumes;
• and which suppliers hold relevant information.

Weeks 2–4 — Create a data inventory

Map the applicable Battery Passport requirements against your existing data. For every relevant data point, ask:

• Do we have it?
• Where is it stored?
• Who owns it?
• Is there supporting evidence?
• Is it model-level or individual-battery-level information?
• How often can it change?

Weeks 4–6 — Perform the gap analysis

Identify:

• missing information;
• information that must come from the manufacturer;
• missing evidence;
• data-quality issues;
• identifier requirements;
• and processes that do not yet exist.

The result should be a practical list of gaps, owners and actions.

Weeks 6–10 — Build one real Battery Passport pilot

Create the passport architecture for the selected battery. Connect actual product data. Create individual battery identities. Generate and test the data carrier. Test what different users should be able to access.

Do this with real data rather than a mock-up.

Weeks 10–12 — Make it operational

Once the pilot works, define how it becomes part of normal operations. For example:

• How does supplier data enter the system?
• When is an individual battery identity created?
• How is the data carrier generated?
• Who can update information?
• How are changes logged?
• How will Registry workflows be handled?
• How will the process scale from 10 batteries to 10,000?

At that point, the Battery Passport stops being a compliance experiment and becomes an operational process.

9. Don't wait for every technical detail to be final

Battery Passport implementation is still evolving. The European Commission continues to publish guidance and implementation material, and some technical and access-right details are still being finalised.

That is not a reason to wait. The fundamental work that smaller battery companies need to do now is already clear:

None of that work is wasted when further technical details are published.

The closer we get to 18 February 2027, the more companies will be asking the same manufacturers and suppliers for the same missing information. Starting early gives you time to solve those gaps without turning compliance into an emergency project.

Start with a Battery Passport readiness scan

Not sure where to begin? Quifactum can start with one of your actual battery models and map it against the applicable Battery Passport requirements. Together, we identify:

• which requirements apply to your battery;
• which data you already have;
• where that information currently lives;
• what is still missing;
• what must come from your manufacturer or suppliers;
• how model and individual battery data should be structured;
• and what is needed to move from a pilot to production.

The result is a practical implementation roadmap — not another compliance report.

You do not need to start with your entire catalogue. Start with one real battery.

Talk to us about your first Battery Passport →

This guide is based on the official information available on 26 September 2026. Battery Passport implementation continues to evolve, so companies should always verify the latest applicable requirements. This article provides general information about Digital Product Passport implementation and is not legal advice.

Published by Quifactum. Last updated 26 September 2026. Regulatory content is reviewed against primary EU sources before publication.