--- title: "Battery passport evidence workflow under EU Regulation 2023/1542" canonical_url: "https://www.sorena.io/artifacts/eu/batteries-regulation/battery-passport-evidence-workflow" source_url: "https://www.sorena.io/artifacts/eu/batteries-regulation/battery-passport-evidence-workflow" author: "Sorena AI" description: "Build a battery passport evidence workflow for Article 77 and Annex XIII: QR code access, access rights, provenance, conformity evidence, lifecycle updates, and ownership." published_at: "2026-05-09" updated_at: "2026-05-09" keywords: - "EU Batteries Regulation" - "Regulation 2023/1542" - "battery passport" - "Article 77" - "Annex XIII" - "QR code" - "access rights" - "EU declaration of conformity" - "battery data provenance" - "Batteries Regulation" - "conformity evidence" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # Battery passport evidence workflow under EU Regulation 2023/1542 Build a battery passport evidence workflow for Article 77 and Annex XIII: QR code access, access rights, provenance, conformity evidence, lifecycle updates, and ownership. *Batteries Regulation* *Evidence workflow* *EU* ## EU battery passport Evidence workflow A workflow for proving that each in-scope battery passport has the Article 77 owner, QR access, Annex XIII data, conformity links, provenance, and lifecycle update controls it needs. Use it to align product compliance, engineering, sustainability, service, and end-of-life teams before passports go live or change status. Regulation (EU) 2023/1542 requires an electronic battery passport for each LMT battery, each industrial battery above 2 kWh, and each electric vehicle battery placed on the market or put into service from 18 February 2027. This workflow turns Article 77 and Annex XIII into an evidence register: who is responsible, which data belongs in the passport, who may see it, what proves conformity, how the QR code resolves, and how updates are handled through re-use, repurposing, remanufacturing, waste, and recycling. ## 1. Confirm passport scope and name the responsible operator Start with a battery-level scope record. Article 77 applies the passport duty to LMT batteries, industrial batteries with capacity greater than 2 kWh, and electric vehicle batteries that are placed on the market or put into service. The evidence owner should be the economic operator placing the battery on the market, because Article 77 makes that operator responsible for keeping passport information accurate, complete, and up to date. If another operator maintains the passport data, keep the written authorisation and the service boundary in the evidence file. - Evidence record: battery category, model identifier, capacity basis, placed-on-market or put-into-service route, and date the passport obligation is triggered. - Owner record: legal entity placing the battery on the market, internal accountable function, authorised data processor or platform operator, and written authorisation if another operator acts on its behalf. - Control check: the passport owner can update the underlying systems for model data, individual-battery data, access rights, and status changes instead of only publishing a static page. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries and waste batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Article 77 identifies the battery categories requiring a passport and assigns accuracy, completeness, and update responsibility to the economic operator placing the battery on the market. - [Circular economy: New law on more sustainable, circular and safe batteries enters into force](https://environment.ec.europa.eu/news/new-law-more-sustainable-circular-and-safe-batteries-enters-force-2023-08-17_en?ref=sorena.io) - Commission overview explaining that the Batteries Regulation uses a full life-cycle approach and that QR codes give access to a digital passport. *Recommended next step* *Placement: after evidence section* ## Build passport evidence before publication Use the workflow to connect Article 77 ownership, Annex XIII data classes, QR access, conformity records, and lifecycle update controls before battery passports go live. - [Open Research Copilot](/solutions/research-copilot.md): Check EU Batteries Regulation passport questions against cited source material. - [Discuss battery passport implementation](/contact.md): Review passport data fields, access rights, ownership, and evidence controls with Sorena. ## 2. Build the Annex XIII data map and access-right matrix Do not treat the passport as one undifferentiated dataset. Annex XIII separates public model information, legitimate-interest model information, information reserved for notified bodies, market surveillance authorities and the Commission, and individual-battery information for legitimate-interest users. For each field, record the source system, data steward, evidence artifact, access class, update trigger, and validation rule. This prevents public-facing passport data from exposing restricted dismantling, test-report, or individual-battery data. - Public model data: Annex VI label information, chemistry, hazardous substances beyond mercury/cadmium/lead, critical raw materials, carbon footprint information, responsible sourcing, recycled content, renewable content, capacity, voltage, power capability, lifetime, warranty, energy efficiency, resistance, C-rate, markings, EU declaration of conformity, and waste-prevention information. - Legitimate-interest model data: detailed composition, cathode/anode/electrolyte materials, spare-part source contacts, dismantling diagrams and sequences, fastening techniques, required tools, damage warnings, cell count and layout, and safety measures. - Authority and notified-body data: test-report results proving compliance with the Regulation or delegated and implementing acts. - Individual-battery data: performance and durability values at market placement and status change, state of health, battery status, charging and discharging cycles, negative events, operating environmental conditions, and state of charge. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries and waste batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Annex XIII lists the passport information groups and separates public, legitimate-interest, authority/notified-body, and individual-battery access classes. - [Regulation (EU) 2023/1542 concerning batteries and waste batteries](https://eur-lex.europa.eu/EN/legal-content/summary/sustainability-rules-for-batteries-and-waste-batteries.html?ref=sorena.io) - EUR-Lex summary confirms that the Regulation covers labelling, QR codes and battery passports as part of the battery information regime. ## 3. Prove QR code, unique identifier, and data provenance controls Article 77 requires passport access through the Article 13 QR code, linked to a unique identifier attributed by the economic operator placing the battery on the market. Annex VI adds the practical QR-code evidence requirement: high contrast, readable size, and readability by commonly available QR readers. Provenance evidence should show how each passport field moves from source system to published record. Article 77 and Article 78 require open standards, interoperability, machine-readable structured searchable data, authentication, reliability, integrity, security, privacy, and fraud avoidance. - QR evidence: artwork file, placement rule, contrast/readability test, scan result, resolved passport URL, unique identifier, and identifier allocation log. - Provenance evidence: source system, source owner, transformation rule, timestamp, reviewer, publication status, and immutable record of changes for each passport field. - Platform evidence: open interoperable format, no vendor lock-in dependency for data exchange, role-based access controls, authentication logs, integrity checks, and privacy/security review for restricted data. - Data-processor evidence: if an authorised operator stores or processes passport data, keep terms showing it cannot sell, re-use, or process the data beyond the passport service. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries and waste batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Article 77 links passport access to the QR code and unique identifier, while Article 78 sets interoperability, storage, access, integrity, security, and privacy requirements. - [Regulation (EU) 2023/1542 concerning batteries and waste batteries](https://eur-lex.europa.eu/EN/legal-content/summary/sustainability-rules-for-batteries-and-waste-batteries.html?ref=sorena.io) - EUR-Lex summary supports the operational focus on QR codes as the access mechanism for battery information and passports. ## 4. Link passport data to conformity and technical evidence The passport evidence workflow should connect published passport claims to the conformity file. Annex XIII includes the EU declaration of conformity in the public passport dataset and reserves test-report results proving compliance for notified bodies, market surveillance authorities and the Commission. Keep the conformity evidence specific to the battery model or individual battery being passported. Annex VIII requires technical documentation that allows assessment of conformity and includes risk analysis, and it requires the EU declaration of conformity to identify the relevant battery model or battery. - Conformity link: EU declaration of conformity identifier, battery model or battery identifier, applicable Articles, harmonised standards or common specifications used, notified-body certificate where applicable, and market-surveillance response owner. - Claim support: carbon footprint report or declaration source, recycled-content documentation source, responsible-sourcing report source, performance and durability test source, state-of-health source, and waste-management information source. - Release gate: do not publish a passport field until the evidence file names the source artifact, approving owner, version, access class, and reason the field is safe to expose to that audience. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries and waste batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Annex XIII requires the EU declaration of conformity in the public passport and reserves test-report results for notified bodies, market surveillance authorities and the Commission. - [Regulation (EU) 2023/1542 concerning batteries and waste batteries](https://eur-lex.europa.eu/EN/legal-content/summary/sustainability-rules-for-batteries-and-waste-batteries.html?ref=sorena.io) - EUR-Lex summary situates passport evidence among the Regulation's sustainability, labelling, conformity, collection, recycling, and lifecycle obligations. ## 5. Maintain lifecycle updates, transfers, and retirement evidence A battery passport is not complete at first publication. Article 77 requires accurate, complete and up-to-date information, and Annex XIII requires individual-battery values when the battery is placed on the market and when its status changes. When a battery is prepared for re-use, prepared for repurposing, repurposed, re-used, or remanufactured, Article 77 transfers responsibility to the economic operator that places that battery on the market or puts it into service. The new passport must be linked to the original passport or passports. When the status changes to waste, responsibility transfers to the producer, appointed producer responsibility organisation, or selected waste management operator. The passport ceases to exist after recycling. - Update triggers: first market placement, putting into service, performance or durability status change, state-of-health change, accident or negative event, operating-condition update, re-use, repurposing, remanufacturing, waste status, and recycling. - Transfer evidence: previous passport identifier, new passport identifier, responsible economic operator, legal basis for transfer, date of status change, authority or customer visibility impact, and data migrated or withheld by access class. - Retirement evidence: waste-status record, responsible producer or waste-management operator, recycling completion evidence, and passport decommissioning record. Sources for this answer: - [Regulation (EU) 2023/1542 on batteries and waste batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Article 77 sets passport update responsibility, transfer rules for re-use/repurposing/remanufacturing and waste, and the rule that a passport ceases after recycling. - [Circular economy: New law on more sustainable, circular and safe batteries enters into force](https://environment.ec.europa.eu/news/new-law-more-sustainable-circular-and-safe-batteries-enters-force-2023-08-17_en?ref=sorena.io) - Commission overview supports the lifecycle framing by explaining that sourcing, manufacturing, use, and recycling are addressed in one law. ## Primary sources - [Regulation (EU) 2023/1542 on batteries and waste batteries](https://eur-lex.europa.eu/eli/reg/2023/1542/oj/eng?ref=sorena.io) - Primary legal source for Article 77 battery passport scope, QR-code access, responsible operator duties, access rights, lifecycle transfer rules, Article 78 technical requirements, and Annex XIII passport data groups. - Quote: "Battery passport" - [Regulation (EU) 2023/1542 concerning batteries and waste batteries](https://eur-lex.europa.eu/EN/legal-content/summary/sustainability-rules-for-batteries-and-waste-batteries.html?ref=sorena.io) - EUR-Lex summary source for the Regulation's battery information regime, including labelling, QR codes, battery passports, conformity, and lifecycle obligations. - Quote: "QR codes and battery passports" - [Circular economy: New law on more sustainable, circular and safe batteries enters into force](https://environment.ec.europa.eu/news/new-law-more-sustainable-circular-and-safe-batteries-enters-force-2023-08-17_en?ref=sorena.io) - Commission overview source for the lifecycle purpose of the Batteries Regulation and the role of QR-code access to a digital passport for consumers and value-chain professionals. - Quote: "A QR code will provide access" ## Related Topic Guides - [Batteries Regulation vs ESPR](/artifacts/eu/batteries-regulation/batteries-regulation-vs-espr.md): Compare EU Batteries Regulation duties with ESPR framework rules: scope, economic operators, DPP overlap, delegated acts, sustainability evidence, and reuse limits. - 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