Battery Passport for EU Market Compliance
From 18 February 2027, EV, light transport, and industrial batteries above 2 kWh sold in the EU must carry a battery passport.
See how structured Battery Passport data comes together
The Digital Battery Passport is an information system, not just a QR code. Explore an illustrative view of how battery identity, carbon footprint, material composition, and lifecycle information can be organised into a single passport record, with different access levels for different stakeholders.
Who needs a Battery Passport?
The EU Battery Regulation applies to batteries placed on the EU market or put into service in the EU. The Battery Passport expectation affects companies across the battery value chain, including economic operators responsible for covered batteries. The list below is illustrative, not exhaustive.
Which battery categories are covered?
EV batteries
Digital passports for electric vehicle batteries placed on the EU market or put into service in the EU.
LMT batteries
Digital passports for light means of transport batteries, including e-bike and e-scooter battery systems.
Industrial batteries above 2 kWh
Digital passports for industrial batteries with a capacity greater than 2 kWh, including stationary and commercial energy storage systems.
Battery Passport indicative data elements
A Digital Battery Passport may include the following elements. Final fields depend on battery category, Annex XIII, and pending implementing acts:
The real challenge is the data behind the QR code
The QR code is only the access point. The Battery Passport itself is an information system, and the real work is keeping the data behind it complete and up to date.
Most companies already hold parts of the required information, but it sits across supplier files, bills of materials, certificates, test reports, spreadsheets, ERP systems, PLM tools, and carbon calculations.
Circuland pulls that fragmented battery data into one passport structure, so teams can spot gaps early and prepare before the February 2027 deadline.
Where battery data typically lives today
- Supplier files
- Bills of materials
- Certificates
- Test reports
- Spreadsheets
- ERP systems
- PLM tools
- Carbon calculations
Common Battery Passport data gaps
Many battery companies already have some of the required information, but not always in the right format or in one place.
Supplier data gaps
Missing or inconsistent information from cell suppliers, material suppliers, and tier-n partners.
Carbon data gaps
Carbon footprint data that is not linked to the correct battery model, production setup, or reporting method.
Material data gaps
Incomplete material composition, critical raw material, or recycled content information.
Lifecycle data gaps
Limited visibility into repair, reuse, second-life, and end-of-life records.
Access control gaps
No clear process for deciding which passport fields are public, restricted, or available only to authorised actors.
Circuland surfaces these gaps early, so teams know what to fix before the passport is due.
Where Battery Passport data actually comes from
Battery Passport preparation usually starts from documents and existing enterprise data, not a clean data model.
Relevant information may sit inside:
- Supplier declarations
- Bills of materials
- Product specifications
- Safety documents
- Carbon reports
- Test reports
- Certifications
- ERP exports
- PLM records
- Spreadsheets
Circuland extracts and maps this information into a passport structure, cutting manual work and flagging what is complete, missing, or needs review.
Different access levels in a Battery Passport
Battery Passport information is expected to be available at different access levels, subject to Regulation (EU) 2023/1542 and implementing measures that are still pending finalisation. Not every field is expected to be visible to everyone.
Public-level data
Publicly accessible information may include items such as battery identification, model information, basic manufacturer details, selected sustainability information, and certain end-of-life guidance. Final public-level fields will be defined in the applicable legal acts.
Restricted-level data
Restricted information may include more detailed technical or commercially sensitive data, available only to authorised actors under the access rules in Regulation (EU) 2023/1542 and any applicable implementing measures.
Circuland is designed to support different access levels so that each stakeholder can access the information made available to them. Examples of potentially authorised actors include public users, authorities, repairers, second-life operators, and recyclers - the final list of roles is defined by the regulation and implementing measures.
Battery Passport implementation roadmap
Map your battery portfolio
Identify which EV, LMT, and industrial batteries are in scope.
Review required data fields
Compare your current product, supplier, carbon, and lifecycle data against Battery Passport requirements.
Collect supplier data
Engage cell suppliers, material suppliers, pack assemblers, and tier-n partners.
Structure the data
Map PDFs, spreadsheets, certificates, test reports, and BOM data to a single passport data model.
Create QR-linked passports
Issue unique identifiers and QR-readable passport records linked to the relevant battery.
Manage updates over time
Keep passport data updated across production, operation, repair, second life, and recycling.
Battery Passport readiness checklist
Before choosing a Battery Passport platform, battery teams should assess how complete, structured, and up to date their data is today.
- 1Do you know which battery models are in scope?
- 2Do you know which suppliers hold the required data?
- 3Do you have structured BOM data for each battery model?
- 4Do you have carbon footprint data linked to the correct battery model and production setup?
- 5Do you track recycled content by material?
- 6Do you have state of health and performance data available?
- 7Do you know which data should be public and which should be restricted?
- 8Do you have a process for updating passport data over time?
- 9Can your current systems connect product, supplier, compliance, and lifecycle data?
Battery Passport use cases
For battery manufacturers
Create structured passport records from product, supplier, carbon, and compliance data.
For importers and distributors
Check whether covered batteries entering the EU market have the required passport information and documentation.
For automotive OEMs
Validate battery passport data across suppliers and connect battery records to vehicles placed on the EU market.
For energy storage companies
Manage passports for industrial batteries above 2 kWh, including state of health, lifecycle records, and second-life data.
For recyclers and second-life operators
Access relevant material composition, dismantling, safety, and end-of-life information to support reuse, recovery, and recycling.
Why start before February 2027?
Battery Passport readiness depends on both data availability and system and process readiness, not just software setup.
Starting early gives teams time to find gaps, test the process, and avoid a February 2027 scramble.
The work that often takes the longest includes:
- Finding missing supplier information
- Mapping BOMs to required data fields
- Collecting carbon footprint data
- Validating recycled content data
- Structuring lifecycle records
- Setting up access control
- Keeping passport records updated over time
Why Circuland?
Circuland is designed to support Battery Passport implementation beyond a basic QR code.
With Circuland, teams can:
- Map existing documents to Battery Passport data fields
- Extract data from supplier files and compliance documents
- Track missing information
- Connect passport data with PIM, PLM, ERP, and document systems
- Manage public and restricted data access
- Keep passport records updated over time
- Support multiple Digital Product Passport use cases from one platform
Frequently Asked Questions
From 18 February 2027, covered batteries placed on the EU market or put into service in the EU are expected to be accompanied by a battery passport, including EV batteries, LMT batteries, and industrial batteries above 2 kWh, subject to the applicable provisions of Regulation (EU) 2023/1542.
Yes. The requirement can apply to batteries manufactured outside the EU if they are placed on the EU market or put into service in the EU, subject to Regulation (EU) 2023/1542.
No. The QR code is the access point. The passport itself is an information system, so compliance depends on the complete, up-to-date data behind it.
A Battery Passport is expected to cover elements such as battery identity, manufacturer information, material composition, carbon footprint, recycled content, supply chain due diligence, state of health, safety information, repair guidance, and end-of-life information. Final field-level obligations depend on battery category, access rules, Annex XIII, and pending implementing acts.
From 18 February 2027, EV batteries, light means of transport batteries, and industrial batteries above 2 kWh placed on the EU market or put into service in the EU are expected to be accompanied by a battery passport, subject to the applicable provisions of Regulation (EU) 2023/1542.
Circuland structures supplier data, carbon footprint records, material composition, lifecycle documentation, and QR-linked passport access into a single passport record, designed to support compliance with Regulation (EU) 2023/1542.