The digital battery passport becomes mandatory from February 2027
Under the EU Battery Regulation, in-scope batteries must have an active digital battery passport to be legally placed on the EU market or put into service from 18 February 2027.
The EU battery passport tracks batteries throughout their lifecycle
The EU battery passport records information from raw material extraction through manufacturing, use, repair, repurposing and recycling, helping support circular economy objectives.
Every battery passport requires a unique QR code and identifier
Each battery passport must be linked to a durable QR code and unique identifier, providing access to key identity, sustainability, performance and recycled content data.
The EU battery passport supports supply chain transparency
The EU battery passport helps manufacturers demonstrate traceability, responsible sourcing and regulatory compliance through verifiable data and supporting evidence.
Battery passport regulation places legal responsibility on economic operators
Battery passport regulation requirements remain the responsibility of the organisation placing the battery on the EU market, even when using third-party software platforms.
Under the EU Batteries Regulation, a digital battery passport is mandatory from 18 February 2027. It applies to all electric vehicle (EV) batteries, light means of transport (LMT) batteries, and industrial batteries with a capacity greater than 2 kWh placed on the European market. Each battery must feature a physical QR code linking to its unique online digital record.
The European Union Battery Regulation (EUBR) was introduced to address the environmental, economic and geopolitical pressures of global electrification, ensuring that batteries placed on the European market are sustainable and safe throughout their lifecycle.
These requirements are mandatory as of 18 February 2027, from which time any in-scope batteries cannot legally be placed on the EU market or put into service without an active passport that adequately meets the numerous requirements.
Batteries in scope include:
Portable batteries are currently exempt, but this might change in future revisions of the EU Battery Regulation.
The battery passport system aims to maximise the lifecycle value of a battery by tracking it from raw material extraction to secondary usage (repair and repurposing) and end-of-life recycling. With battery demand growing, the EU will rely on this system to trace materials like lithium, cobalt, nickel and lead. This ensures these elements can be effectively recovered and fed back into European manufacturing loops via mandatory recycled content quotas.
The EUBR mandates that the party placing the battery on the EU market must generate an electronic record providing different user groups with customised data-access permissions to safeguard commercial confidentiality. The three tiers of access are:
Every battery must be physically marked with a durable, readable QR code linked to its unique identifier (UID).
The battery passport must record data across several main categories:
As well as the core objective to guarantee that batteries are safe and sustainable throughout their entire lifecycle, a battery passport is a key enabler of the circular economy as it supports battery reuse, repurposing, remanufacturing and recycling. However, achieving this requires complete visibility across the entire supply chain, as buyers will hesitate to engage with suppliers who cannot demonstrate certified compliance.
Organisations must therefore provide empirical data to back up their compliance assertions, and every compliance parameter must be fully verifiable. Each regulatory requirement should be supported by appropriate evidence, such as technical documentation, calculations, declarations, test reports or traceable data records, depending on the nature of the requirement.
As the regulation is implemented, several challenges have emerged. Firstly, an assurance gap exists between software vendors, which build battery passport platforms, and manufacturers, which have legal liability. Battery passports require robust architecture linking data to verified tests, not static spreadsheets, but manufacturers often lack such audit-ready compliance proof.
Secondly, complexity makes cross-disciplinary alignment difficult, as it must span multiple specialist teams. Data architecture must meet strict quality standards for reliability, platform compatibility and version control, including clean installation and rollback procedures. Security is also a major hurdle, as organisations must demonstrate secure-by-design data handling and protect against unauthorised access, fraud and inappropriate reuse of passport data. Relevant cybersecurity and digital product passport standards such as EN 18216:2026, EN 18239 and EN 18246 may support this, depending on the system architecture and risk profile.
To mitigate EU battery passport compliance risks and ensure uninterrupted market access, TÜV SÜD advises the following practical steps:
Address the assurance gap by proactively building an internal source of audit-ready compliance evidence. Do not assume that purchasing a battery passport software solution automatically shifts or fulfils your legal compliance burden.
Ensure that any battery passport management systems adhere to a strict, defined security process spanning the plan, build, test and release phases. Incorporate secure-by-design principles to address potential data vulnerability vectors.
Mandate that all product and user documentation associated with your batteries is complete, correct, consistent and easily understandable. Ensure that data systems allow for clear version identification and clean updates.
Map every regulatory requirement to a dedicated test with transparent, verifiable pass/fail metrics to establish end-to-end traceability.
Break down organisational silos so that legal compliance, supply chain procurement, battery engineering and software development teams address multiple EUBR requirements together.
Digital battery passports will become a critical requirement for organisations placing batteries on the European market. As the February 2027 deadline approaches, manufacturers, importers and other economic operators must demonstrate EU Battery Regulation (EUBR) compliance, traceability, supply chain transparency and data integrity. Independent third-party verification helps strengthen confidence in battery passport data, supports regulatory readiness and provides credible evidence that compliance requirements have been met across the battery value chain.
TÜV SÜD provides end-to-end technical verification and battery testing services for manufacturers, importers, distributors and other economic operators. Our certification services are delivered by TÜV SÜD’s recognised Certification Bodies in an independent and impartial manner, separated from advisory and testing services.
TÜV SÜD’s certification mark demonstrates that the battery passport has been independently assessed for quality, conformity and alignment with applicable regulatory requirements. Such third-party verification can help manufacturers, importers and digital battery passport service providers demonstrate credibility, data integrity and EUBR compliance readiness across the battery value chain.
You can also read our article to learn more about EU Battery Regulation (2023/1542) Article 7.
Prepare for EU battery passport requirements with independent verification, testing and certification services designed to support EUBR compliance and market access.
Contact TÜV SÜD’s experts today to discover how our EU battery regulation services can help you ensure that your batteries are safe, reliable and compliant with the EUBR.
Site Selector
Global
Americas
Asia
Europe
Middle East and Africa
