Battery passport implementation under EU Batteries Regulation Article 77

The passport build starts by classifying the battery. Article 77 applies from 18 February 2027 to each LMT battery, each electric vehicle battery, and each industrial battery with a capacity greater than 2 kWh that is placed on the market or put into service.

An LMT battery is sealed, weighs 25 kg or less, and is specifically designed to power wheeled vehicles driven by an electric motor alone or together with human power; it must not fall within the electric vehicle battery category. Record the design purpose, weight, vehicle category, and capacity before deciding which passport rule applies.

Do not scope the implementation only at model level. Article 77 requires both information relating to the battery model and information specific to the individual battery, including information resulting from use of that battery, as set out in Annex XIII.

Article 77 makes the battery passport accessible through the Article 13 QR code. The QR code must link to a unique identifier attributed by the economic operator placing the battery on the market.

Teams need more than QR-code placement: assign identifiers durably, check QR quality, and maintain a resolver or lookup path that keeps the correct battery passport reachable.

Annex XIII is the practical data map. Public model-level fields include core battery information, material composition, carbon-footprint information, responsible-sourcing information, recycled content, renewable content, capacity, voltage, power capability, lifetime, warranty, efficiency, resistance, EU declaration of conformity, and waste-prevention and waste-management information.

Restricted fields require role-based access. Detailed composition, spare-part sources, dismantling sequences, tools, warnings, safety measures, individual battery state of health, status, use data, and accident-related data are not public fields. Test-report results are reserved for notified bodies, market surveillance authorities, and the Commission. The Article 77(9) implementing act determines which legitimate-interest persons receive which fields and what they may download, share, publish, or re-use, so those permissions must remain configurable.

Article 77 makes the economic operator placing the battery on the market responsible for ensuring that passport information is accurate, complete, and up to date. That operator may authorize another operator in writing, but the Article 77 responsibility still needs to be visible in the governance record.

Article 78 adds technical and governance requirements: open standards, interoperable format, open interoperable data exchange without vendor lock-in, machine-readable, structured and searchable data, free access according to access rights, stored data under the responsible operator or authorized operators, and controls for integrity, privacy, security, and fraud prevention.

Article 77 changes passport responsibility when a battery is prepared for re-use, prepared for repurposing, repurposed, or remanufactured. The operator placing that changed battery on the market or putting it into service takes responsibility for passport accuracy and must create a new battery passport linked to the original passport or passports. 'Re-used' remains a valid Annex XIII status value, but it is not an extra operation in the Article 77(7) transfer list.

When the battery becomes waste, responsibility moves to the producer, an appointed producer responsibility organisation, or the selected waste management operator. The passport ceases to exist after the battery has been recycled.

The DPP connection should be treated as an interoperability requirement, not as permission to replace the battery-specific rulebook. Article 78 requires the battery passport to be fully interoperable with other Union-law digital product passports concerning eco-design; the New Legislative Framework page lists both the Batteries Regulation and the Ecodesign for Sustainable Products Regulation as aligned product legislation and identifies digital product passports as part of future product-rule digitalisation.