Most of a battery passport is written once: chemistry, carbon footprint, due diligence — facts fixed at manufacture. State of health is different. It changes with every year of service, and the passport is required to keep up. From 18 February 2027, that turns the battery passport from a birth certificate into a living record — and raises a hard operational question: who may update it, and how is that controlled?
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The battery passport mandated by Regulation (EU) 2023/1542 — required from 18 February 2027 for every EV battery, every LMT battery and industrial batteries above 2 kWh — carries over a hundred data points. Most are static: cell chemistry, material origins, carbon footprint, due diligence. They describe the battery as it left the factory and never change.
Performance and durability data breaks that pattern. State of health — in essence, how much of the battery's rated capacity remains available today — is only meaningful if it is current. A five-year-old passport showing factory-fresh capacity is not merely stale; it is wrong, and misleading to every downstream reader from buyers to recyclers. The regulation therefore treats the passport as a record to be kept up to date across the battery's life, not filed once and forgotten.
SoH is usually expressed against the baseline set at manufacture: rated capacity, versus the capacity the pack actually delivers now. That single ratio drives most of the commercial decisions made about a used battery:
A record that changes needs rules about who changes it. The framework's answer is authorisation: dynamic passport fields are written by the responsible economic operator and by operators authorised to update battery data — think qualified repairers, remanufacturers and second-life operators — rather than by anyone who scans the code. The exact roles and their permissions are defined by the regulation and its implementing rules, so the honest summary is: writing is a privilege attached to a regulation-defined role, and any serious passport platform enforces that rather than inventing its own scheme.
The corollary matters as much as the rule: every update must be attributable. An SoH figure is only worth what its provenance is worth — who measured it, when, in what role.
Handling dynamic data cleanly is a systems problem, and it is where passport platforms earn their keep. The ingredients: role-based write access, so only authorised actors can touch dynamic fields; versioning, so the passport shows current SoH without erasing history; an immutable audit trail recording every change with author and timestamp; and longevity, because the record must stay accessible for the battery's regulated lifetime. PassPer builds passports this way from the start — eIDAS-seal-ready (QTSP onboarding in its final stage), served via GS1 Digital Link QR, with authorised-update flows and a complete change log — so the passport you register for 18 February 2027 is still trustworthy when the pack starts its second life. See where you stand with the free readiness check.
Count down to 18 February 2027 and work backwards to when each step has to start for your SKU count.
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