Policy Briefing — EU Battery Regulation sets 2027 go-live for digital battery passports
Regulation (EU) 2023/1542 locks a February 2027 deadline for battery passports on industrial and EV batteries above 2 kWh, requiring unique identifiers, QR codes, and lifecycle data uploads to the EU registry.
Executive briefing: The EU Battery Regulation (EU) 2023/1542 entered into force in August 2023 and establishes a digital battery passport regime that becomes mandatory on 18 February 2027 for industrial and electric vehicle batteries with a capacity greater than 2 kWh (Article 77). Each covered battery must carry a scannable QR code tied to an electronic record containing manufacturing, chemistry, carbon footprint, performance, and due-diligence data accessible to economic operators and market surveillance authorities.
Key obligations
- Digital identity. Assign a unique battery identifier (UBI) and QR code linked to the EU battery passport platform, with data fields defined in Annex XIII and forthcoming implementing acts.
- Data population and access. Upload state-of-health, expected lifetime, reparability, recycled content, and due-diligence statements; ensure role-based access for authorities, second-life operators, and end users.
- Carbon footprint disclosures. Embed the calculated life-cycle carbon footprint class (Articles 7–8) and maintain evidence of third-party verification.
- Updates over lifecycle. Keep passport data current after repurposing, major repairs, or ownership transfer, and preserve records for at least 10 years after placing on the market.
Implementation timeline
- 18 Feb 2027. Battery passport requirement applies to industrial and EV batteries >2 kWh placed on the EU market or put into service.
- 2025–2026 implementing acts. The Commission will adopt data specifications and interoperability rules; early drafts align with the Global Battery Alliance passport schema.
- Sequenced obligations. Carbon footprint declarations for EV/industrial batteries already apply from February 2025; due-diligence rules under Articles 48–59 apply from August 2025.
Program actions
- Build data pipelines. Map ERP, manufacturing execution, and telematics systems to passport data fields (capacity, chemistry, state-of-health, carbon footprint class, recycled content).
- Design labels. Prototype QR code labels that survive operating conditions and remain readable at end of life; validate linking to the EU registry.
- Governance and assurance. Set up evidence folders for carbon footprint calculations and supply-chain due diligence to support market surveillance requests.
- Second-life readiness. Plan for data transfers to repurposers and recyclers, including secure role-based access to state-of-health and safety information.
Sources
- Regulation (EU) 2023/1542 on batteries and waste batteries
- European Commission Battery Regulation Q&A
- Global Battery Alliance battery passport framework
Zeph Tech prepares bill-of-materials, carbon data, and QR labelling workflows to meet the EU’s 2027 passport deadline.
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