Sector guide
Your home battery is an industrial battery — and it needs a passport by 2027.
It surprises almost everyone in the sector: under Regulation (EU) 2023/1542, a residential energy storage system is an industrial battery. The regulation classes stationary storage as industrial regardless of who buys it, and above 2 kWh — which is virtually every home battery sold — the battery passport becomes mandatory from 18 February 2027. If you make, brand or import home storage systems, or supply the installers who fit them, the countdown is running.
In one line: residential storage above 2 kWh is legally an industrial battery, so from 18 February 2027 every home battery placed on the EU market needs a compliant battery passport — and for imported systems, that duty belongs to the importer.
Why a wall-mounted home battery counts as "industrial"
The Batteries Regulation sorts every battery into one of five categories: portable, SLI (starter), LMT (light transport), EV, or industrial. A 5–15 kWh wall-mounted home battery is far too large for the portable category and is not a vehicle battery — and the regulation explicitly places batteries for stationary energy storage in the industrial category, whoever the end customer is.
That classification has one big consequence: Article 77 requires a battery passport for every industrial battery above 2 kWh placed on the EU market from 18 February 2027. Since virtually no residential system ships below 2 kWh, in practice the entire home-storage market is in scope.
Who in the home-storage chain carries the duty
- EU manufacturers of storage systems carry the passport duty directly for the batteries they place on the market.
- Importers — a large share of home batteries are manufactured outside the EU. The regulation applies to batteries incorporated into products, so importing a finished storage system means placing the battery inside it on the EU market. The passport is the importer's responsibility.
- White-label and own-brand sellers sourcing from non-EU factories carry manufacturer-level obligations for the battery inside.
- Distributors supplying installers should verify passports exist before stock moves — non-compliant units cannot lawfully be sold on.
Installers themselves are generally not placing batteries on the market — but their suppliers are, and installers will quickly learn to ask for the passport.
What a home-battery passport must contain
A battery passport is a structured digital record of roughly 110+ data points: identity (unique identifier, model, manufacturer), chemistry and materials including recycled content, carbon footprint, supply-chain due diligence, performance and durability data, and circularity information for dismantling and end of life. It is accessed through a GS1 Digital Link QR code on the battery and must remain available for the battery's regulated lifetime — up to 15 years, which for a product warrantied for a decade on a customer's wall is not a theoretical requirement. The DIN DKE SPEC 99100 guidance standard describes how to structure the content.
February 2027 and your sales pipeline
Home batteries move through distribution: stock ordered in 2026 will still be selling through installers in 2027, and from 18 February 2027 any unit placed on the market without a compliant passport cannot lawfully be sold — customs can detain imported shipments and authorities can order withdrawal. The data you need already exists in your factory's spec sheets, test reports and declarations. PassPer extracts it with AI, applies human review, and publishes registered, eIDAS-sealed battery passports on EU-sovereign hosting — from €79/month, no setup fees, with a free 30-day pilot. Start with the free readiness check or see the broader picture at DPP for energy storage.
Frequently asked questions
Our home battery sells to consumers. How can it be an "industrial" battery?
Because the Batteries Regulation assigns categories by technical definition, not by who buys the product. Home storage systems do not fit the portable, SLI, LMT or EV categories, and the regulation explicitly treats stationary energy storage as industrial. Above 2 kWh, the battery passport applies from 18 February 2027 — regardless of the consumer branding on the box.
We import complete storage systems from Asia and the manufacturer says they will comply. Is that enough?
The manufacturer holds most of the data, but the legal responsibility for a compliant passport sits with the economic operator placing the battery on the EU market — for imported finished systems, that is you, the importer. Verify per shipment that passports exist and are accurate; delegate the work in writing if you like, but the accountability stays with you.
Do systems already installed in homes before February 2027 need passports?
No. The obligation attaches to batteries placed on the EU market from 18 February 2027 onwards. Units already sold and installed before that date are not retroactively caught — but any stock you place on the market from that date forward is.
Our system is modular — does every module need its own passport?
The passport attaches to the battery placed on the market, so the answer depends on whether you sell a complete battery system or individual modules. Indicative guidance such as DIN DKE SPEC 99100 works at battery level; if modules are sold separately and each exceeds 2 kWh, plan for passports at module level. Get this scoping question settled early — it shapes your data model.
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