Above 2 kWh, your battery is "industrial" — and it needs a passport.

From 18 February 2027, every industrial battery above 2 kWh placed on the EU market must carry a battery passport under Regulation (EU) 2023/1542. The category is far wider than the word "industrial" suggests: forklifts, AGVs, construction machinery, UPS systems, marine batteries and stationary storage are all inside it, and 2 kWh is a low bar. If you make, integrate or import anything with a serious battery in it, this page is about you.

In one line: any battery above 2 kWh that is not an EV, LMT or portable consumer battery is almost certainly an industrial battery — and from 18 February 2027 it cannot be placed on the EU market without a compliant battery passport.

What counts as an industrial battery

Regulation (EU) 2023/1542 sorts batteries into categories — portable, SLI, LMT, EV and industrial. Industrial is effectively the category for serious batteries that are not in vehicles or consumer devices, and it explicitly includes batteries used for stationary energy storage. Article 77 attaches the battery passport obligation to every industrial battery with a capacity above 2 kWh placed on the EU market from 18 February 2027.

Two kilowatt-hours is a low threshold. A single traction pack in a pallet truck, one storage module, a modest UPS string — all clear it comfortably. If your product contains a battery measured in kilowatt-hours rather than watt-hours, assume you are in scope until proven otherwise.

The breadth people underestimate

"Industrial" reads narrower than it is. The category reaches across a dozen sectors:

Intralogistics — electric forklifts, pallet trucks, AGVs and AMRs.
Construction and agriculture — electrified equipment and machinery with traction packs.
Cleaning and facility machines — ride-on scrubbers, sweepers.
Ground support and port equipment — tugs, loaders, cranes.
Power continuity — UPS systems, telecom and data-centre backup.
Marine — batteries for vessels and inland shipping.
Stationary storage — commercial and residential battery energy storage, off-grid and solar-coupled systems.

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

Who carries the duty

Responsibility follows whoever places the battery on the EU market:

Battery manufacturers selling packs into the EU carry it directly.
Integrators and OEMs who build packs from cells or modules and put them into machines are, in practice, the battery manufacturer for those packs.
Importers of finished machinery — the regulation applies to batteries incorporated into products, so a forklift or storage cabinet imported with its battery inside makes the importer the responsible economic operator.

In multi-tier chains the data lives upstream (cell chemistry, carbon footprint, due diligence) but the legal duty lives downstream, with whoever puts the battery on the market. Closing that gap is the actual compliance work.

The data, the deadline, the way through

A battery passport carries roughly 110+ data points — identity, chemistry and materials, carbon footprint, supply-chain due diligence, performance and durability, circularity — behind a GS1 Digital Link QR code, kept accessible for the battery's regulated lifetime. Machinery sold in 2027 is being specified and ordered now, so supplier data requirements belong in current contracts. PassPer builds registered, eIDAS-sealed battery passports from the documents your suppliers already produce — spec sheets, test reports, declarations — using AI extraction with human review, hosted on EU-sovereign infrastructure, from €79/month with a free 30-day pilot. See solutions for importers if your batteries arrive inside finished machines.

Frequently asked questions

We build machines around 5 kWh packs assembled in-house from imported cells. Who makes the passport?

If you assemble cells or modules into a battery and place that battery on the EU market — including inside your own machine — you are, in practice, acting as the battery manufacturer for passport purposes. The passport duty sits with you, using data from your cell suppliers plus your own pack-level information.

Does the 2 kWh threshold apply per battery or per machine?

The threshold applies to the battery, not the machine. A machine with one 4 kWh battery is caught; how modular systems with several separate batteries are assessed depends on what is placed on the market as "the battery". Indicative guidance such as DIN DKE SPEC 99100 works at battery level — if your architecture is modular, get the scoping question answered early rather than assuming you are out.

We import forklifts and the battery arrives inside the truck. Does the passport still apply?

Yes. The Batteries Regulation explicitly applies to batteries incorporated into products. As the importer placing the forklift — and the industrial battery inside it — on the EU market, you are the responsible economic operator from 18 February 2027.

Do second-life or repurposed industrial batteries need passports?

The regulation treats batteries that have been repurposed or remanufactured as newly placed on the market, so passport obligations are expected to attach to them from 18 February 2027 as well. If you repurpose EV or storage batteries, plan for passport creation as part of that process.

See where you stand — three ways, all free.

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