Industrial batteries above 2 kWh: passport required from 18 February 2027.
The industrial category is where the battery passport reaches furthest into ordinary manufacturing. It is not a rule for battery companies alone: a forklift, a mobile elevating work platform, an electric construction machine, a marine propulsion pack, a data-centre UPS string and a grid-scale storage system all contain industrial batteries, and above 2 kWh each one needs its own passport. The obligation lands on whoever places the battery on the EU market — very often the machine builder, not the cell maker.
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In one line: above 2 kWh, every industrial battery placed on the EU market from 18 February 2027 needs its own passport — and if you build machines containing those batteries, the obligation is ordinarily yours, because you place them on the market.
Where the 2 kWh line falls
Regulation (EU) 2023/1542 applies the battery passport to industrial batteries with a capacity above 2 kWh. That threshold is low in industrial terms — it is comfortably exceeded by forklift traction batteries, electric construction machinery, airport ground-support equipment, marine propulsion packs, automated guided vehicles, agricultural robots, mobile elevating work platforms, UPS strings and every commercial or grid storage system.
Because Article 1 extends the Regulation to batteries incorporated into products, the machine is the vehicle for the obligation. If you place an electric machine on the EU market, you place its battery on the market too.
Item-level, not model-level
A frequent planning error is to treat the passport as a datasheet published once per model. It is not. The passport is issued per battery and reached from a unique identifier carried on that battery, typically a QR code following the GS1 Digital Link structure. Two identical packs leaving the same production line get two passports.
That has a practical consequence for manufacturers used to model-level conformity documentation: the passport has to be generated as part of the production or commissioning flow, with serial-level identity captured, rather than assembled once by the compliance department.
Which data you hold, and which you do not
Split the mandatory field set into three buckets and the workload becomes visible:
Yours already. Battery identity, manufacturer and place of manufacture, category, weight, capacity, voltage, intended application, and much of the performance and durability data from your own testing.
Your supplier's. Cell chemistry detail, the carbon footprint declaration, recycled content shares for cobalt, lithium, lead and nickel, and supply-chain due-diligence information. This is the material you must request, chase and verify.
Operational. State-of-health and usage data that only exists once the battery is in service, which is why the passport is a living record rather than a document filed at launch.
What to do first if you build machines
Machine builders generally discover three surprises: the obligation is theirs rather than their supplier's, the passport is per unit rather than per model, and the supplier data takes months. A sensible order of work:
List every product line containing a battery above 2 kWh, and identify the pack and cell supplier for each.
Check whether your existing serialisation can carry a unique battery identifier, or whether one must be added.
Request the supplier-held fields in writing now, field by field, rather than asking for "battery passport data".
Decide how the QR carrier is physically applied and how it survives the product's service life.
Only then choose how the passport is hosted, updated and kept reachable for the regulated lifetime.
Frequently asked questions
Does the 2 kWh threshold apply per cell, per module or per battery?
It applies to the battery as placed on the market — the pack or system, not the individual cell. A traction pack assembled from many small cells is assessed on its total capacity.
We build machines and buy batteries from a supplier. Whose obligation is the passport?
Ordinarily yours. The obligation attaches to the economic operator placing the battery on the EU market, and by placing a machine containing that battery on the market you place the battery on the market. Your supplier holds much of the data, but you hold the accountability.
Is one passport per model enough?
No. The passport is issued per individual battery and reached through a unique identifier on that battery. Two identical packs need two passports, which is why serial-level identity has to be captured in production rather than assembled centrally afterwards.
Do stationary storage systems and UPS installations count as industrial batteries?
Yes, where they exceed 2 kWh. Commercial and grid-scale storage systems and data-centre UPS strings fall in the industrial category, so the passport requirement from 18 February 2027 applies to them.