EU Batteries Regulation (Regulation (EU) 2023/1542) Battery passport implementation

The passport obligation begins on 18 February 2027 for the in scope categories. The same date also matters for QR code access under Article 13(6). Before then, teams should already have model and instance identifiers, data ownership, and plant specific declaration integrations prepared.

Do not wait for the final quarter before go live. The passport depends on labeling, data model, supplier inputs, and system design choices that take time to stabilize.

Article 77 requires the battery passport to be accessible through the QR code referred to in Article 13(6), linked to a unique identifier attributed by the economic operator placing the battery on the market. The Regulation points to ISO or IEC identifier standards for the QR code and unique identifier route.

Design the resolver as an infrastructure service. The QR should resolve predictably, survive supplier changes, and keep working even if the business model or storage provider changes.

The passport is not fully public. Public users, persons with a legitimate interest, notified bodies, market surveillance authorities, and the Commission do not see the same information. The architecture therefore needs granular access control, clear lawful purpose handling, and audit logging on restricted fields.

The Commission will further specify legitimate interest access in an implementing act, so the access model should be flexible enough to absorb later detail without redesign.

Article 77 transfers responsibility to the economic operator that places on the market or puts into service a battery after preparation for re use, preparation for repurposing, repurposing, or remanufacturing. That battery must have a new passport linked to the original passport or passports. The passport ceases to exist after recycling.

That means your implementation needs a status model, lineage graph, and closure logic. Without these, second life operations will be error prone.

Article 78 adds the architectural standards. The passport must be fully interoperable with other Union digital product passports, free of charge to the relevant users within their access rights, stored by the responsible operator or its authorized service provider, protected against unauthorized reuse of the data by service providers, and designed to ensure security, privacy, and fraud prevention.

These are product requirements, not just legal niceties. They should appear in the system specification and the vendor contract.