The battery inside your product needs a passport — and it's your job.

A common and expensive misunderstanding: "the battery passport is a rule for battery importers — we import e-bikes / machines / vehicles, not batteries." The regulation says otherwise. Regulation (EU) 2023/1542 explicitly applies to batteries that are incorporated into or added to products. When you import a finished product containing an in-scope battery, you are placing that battery on the EU market — and from 18 February 2027, that battery must carry a compliant battery passport.

In one line: if the battery enters the EU inside your product, the economic operator placing it on the market is you — the importer of the finished product — and ensuring a compliant, accurate battery passport exists is your legal responsibility, not your Asian factory's.

What the regulation actually says

Regulation (EU) 2023/1542 (the Batteries Regulation) applies to all batteries placed on the EU market — and Article 1 makes the scope explicit: it also applies to batteries incorporated into or added to products. The battery passport obligation (Article 77) attaches from 18 February 2027 to every EV battery, every LMT (light means of transport) battery — e-bikes, e-scooters, e-mopeds — and every industrial battery above 2 kWh.

Responsibility follows the battery, not the packaging: the economic operator placing the battery on the market must ensure the passport exists and that its data is accurate, complete and kept up to date. For a finished product manufactured outside the EU and imported with its battery inside, that operator is the EU importer of the product.

Who this catches — usually by surprise

E-bike and e-scooter importers — every LMT battery needs a passport, with no capacity threshold.
Machinery and equipment importers — electric forklifts, cleaning machines, AGVs, construction and agri equipment with >2 kWh industrial batteries.
Vehicle importers — EVs, micro-cars, e-motorcycles.
Brands and private-label sellers — if the goods come from outside the EU and you place them on the market, you carry manufacturer-level obligations for the battery inside.

Not caught: ordinary portable batteries (laptops, power tools, phones) — those face labelling and collection rules, but not the battery passport.

What you actually have to produce

A battery passport is a structured digital record — over a hundred data points across identity, materials and chemistry, carbon footprint, supply-chain due diligence, performance and durability — carried by a QR code on the battery, registered and kept current for the battery's life. Your factory holds much of the data; the legal duty to assemble, publish and maintain it sits with you. That is exactly the gap PassPer closes: our AI reads the documents your supplier already has — spec sheets, test reports, declarations — and builds the registered, eIDAS-sealed passport, with an Importer Shield that shows per-shipment verdicts before customs asks.

The clock

18 February 2027 is not a soft target: no compliant passport means the battery — and therefore the product it is inside — cannot lawfully be placed on the EU market. Customs can detain goods; market-surveillance authorities can force withdrawal. If your 2027 season stock ships from the factory in late 2026, your compliance work starts now, not in 2027.

Frequently asked questions

We import e-bikes, not batteries. Does the battery passport apply to us?

Yes. The Batteries Regulation explicitly applies to batteries incorporated into products, and every LMT battery — the kind in e-bikes and e-scooters — needs a passport from 18 February 2027. As the importer placing the product (and the battery inside it) on the EU market, you are the responsible economic operator.

Can't our manufacturer just handle it?

Your manufacturer holds most of the data, but the legal responsibility for the passport being present, accurate and current sits with the economic operator placing the battery on the EU market — for imported finished products, that's you. You can delegate the work (in writing) but not the accountability.

Which batteries inside products are in scope?

All EV batteries, all LMT batteries (e-bikes, e-scooters, e-mopeds — no size threshold), and industrial batteries above 2 kWh (machinery, equipment, stationary uses). Portable consumer batteries — laptops, phones, power tools — are out of the passport's scope.

What happens if a product arrives without a compliant battery passport?

From 18 February 2027 the battery cannot lawfully be placed on the market — so the product can't be sold. Customs can detain shipments, authorities can order withdrawal, and member states set fines. The commercial damage — a season's stock stuck in a warehouse — usually dwarfs the fine.

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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