The battery passport checklist: eight months of work, one hard deadline.

From 18 February 2027, Article 77 of Regulation (EU) 2023/1542 makes the battery passport mandatory: no compliant passport, no lawful placing on the EU market. Whether you manufacture batteries, import them, or import products with batteries inside, the work splits into a handful of concrete areas — scope, data, evidence, carrier, seal and registration, and long-term persistence. Use this checklist to find your gaps while there is still time to close them.

In one line: confirm which of your batteries are in scope, assemble the ~110 required data points from supplier evidence, attach a QR data carrier with unique identifiers, seal and register the passport, and keep it accessible for the battery's regulated lifetime — all before 18 February 2027.

1. Scope check: which of your batteries are caught

EV batteries — all of them, no threshold.
LMT batteries — e-bikes, e-scooters, e-mopeds; no capacity threshold, so even small packs are in.
Industrial batteries above 2 kWh — machinery, forklifts, AGVs, stationary storage.
Batteries inside products — the regulation explicitly covers batteries incorporated into or added to products; if you import a finished product with an in-scope battery, the passport duty is yours as the operator placing it on the market.
Out of scope: portable consumer batteries (laptops, phones, power tools) — labelling and collection rules apply, but no passport.

Output of this step: a definitive list of SKUs and battery models that must carry a passport on 18 February 2027.

2. Data families: the ~110 data points to assemble

Work through each family and mark what you hold, what your supplier holds, and what does not exist yet:

Identity & general — manufacturer, battery model and category, manufacturing place and date, weight, status.
Chemistry & materials — composition, critical raw materials, recycled content shares, hazardous substances.
Carbon footprint — lifecycle carbon footprint per functional unit, with the underlying study.
Due diligence — supply-chain due diligence policy and report covering raw-material sourcing.
Performance & durability — capacity, power, round-trip efficiency, expected lifetime, state-of-health parameters.
Circularity — dismantling information, spare parts, collection and recycling information.

DIN DKE SPEC 99100 is the guidance standard most teams use to structure the full set. Note that access is tiered: some fields are public, others restricted to authorities and legitimate-interest operators — your system must handle both.

3. Supplier evidence: carbon footprint and due diligence first

Two data families routinely take the longest, so start them first:

Carbon footprint — requires a lifecycle calculation backed by manufacturing data only the cell maker holds. Request the study now and make it a contractual deliverable in every purchase order.
Due diligence — evidence of responsible sourcing for the battery's raw materials, flowing from your supplier's own upstream chain. Chasing this after the goods ship is too late.

For the rest, the evidence usually already exists as spec sheets, test reports, material declarations and certificates. The bottleneck is extraction, not existence — which is where PassPer's AI reads the documents you already have, a human reviews every field, and the gap list tells you precisely what to request from which supplier.

4. Carrier, seal, registry — and keeping it alive

QR data carrier — a GS1 Digital Link QR (or Data Matrix) on the battery, resolving to the passport for anyone who scans it.
Unique identifiers — each passport needs identifiers that unambiguously tie the record to the physical battery and its model.
Integrity seal — PassPer applies an eIDAS qualified seal so the passport's authenticity and integrity are verifiable.
Registration — the EU registry opens for registration on 19 July 2026; filing is part of the workflow, not an afterthought.
Persistence — passports must remain accessible for the product's regulated lifetime, up to 15 years, with backup custody so the record survives supplier changes or your own platform migrations.
Updates — the passport is living data: repairs, repurposing and status changes must be reflected.

If most boxes above are unticked, run the free readiness check — it maps your catalogue against the deadline in minutes, and the 30-day pilot is free.

Frequently asked questions

Which batteries need a passport from 18 February 2027?

Every EV battery, every LMT battery (e-bikes, e-scooters, e-mopeds — no capacity threshold) and every industrial battery above 2 kWh. The obligation covers batteries incorporated into products, so finished goods with an in-scope battery inside are caught too. Portable consumer batteries — laptops, phones, power tools — face labelling and collection rules but not the passport.

How many data points does a battery passport contain?

Around 110 or more, spanning identity, chemistry and materials, carbon footprint, supply-chain due diligence, performance and durability, and circularity. Some are public to anyone scanning the QR code; others are restricted to authorities and operators with a legitimate interest. DIN DKE SPEC 99100 is the practical guidance standard for structuring them.

What if our supplier cannot provide some of the data?

Start the request now — carbon footprint studies and due diligence documentation are the slowest items to obtain, and a factory answering in weeks is normal. Make the data deliverables contractual per order. PassPer's AI extraction reads the documents suppliers already have (spec sheets, test reports, declarations) and flags exactly which fields are still missing, so you chase gaps instead of guessing.

Is being ready in early 2027 soon enough?

Usually not. Stock manufactured and shipped in late 2026 arrives under the 2027 rules, and a non-compliant battery cannot lawfully be placed on the market — customs can detain goods and authorities can order withdrawal. Working backwards from your first 2027-bound shipment, data collection needs to start months ahead, which for most businesses means now.

See where you stand — three ways, all free.

Take the 2-minute readiness check, watch the 10-minute interactive walkthrough, or download the full 2026 compliance guide. No account needed.

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