Battery Passport for Industrial Battery Manufacturers: Your 18 February 2027 Readiness Guide

Battery passport for industrial battery manufacturers refers to the digital record that Article 77 of the EU Batteries Regulation (EU) 2023/1542 requires for every industrial battery with a capacity above 2 kWh placed on the EU market from 18 February 2027. It is reached through a QR code on the battery and holds identity, composition, compliance, circularity and performance data. The economic operator placing the battery on the market is responsible for it.

Key takeaways

• The date is fixed. 18 February 2027 applies to industrial batteries above 2 kWh. The due diligence postponement to 18 August 2027 did not move it.
• You own it. The operator placing the battery on the market answers for the passport, even if a third party runs it.
• Data is tiered. Some fields are public; others are restricted to authorities and people with a legitimate interest.
• It is a live record. Performance data such as state of health must stay current, and second-life batteries need a new, linked passport.
• Spreadsheets will break. Unique IDs, access control and lifecycle updates at volume need a dedicated platform.

If you build stationary energy storage systems, material-handling traction batteries, or large UPS and telecom backup packs, roughly 15 weeks separate you from the deadline. After that, any in-scope unit without a passport cannot legally be placed on the EU market. This guide covers what the battery passport for industrial battery manufacturers requires, what data you need to collect, and how to judge whether your current setup will hold.

Battery Passport for Industrial Battery Manufacturers: Scope and Ownership

Before collecting any data, confirm which products are in scope and who carries the legal duty.

• Which industrial batteries need a passport
• Who is responsible for issuing and maintaining it

Battery passport scope for industrial batteries

For the battery passport for industrial battery manufacturers, the trigger is capacity, not chemistry. Article 77(1) covers every industrial battery with a capacity greater than 2 kWh, alongside EV and LMT batteries. Industrial batteries at or below 2 kWh fall outside the passport requirement on that basis alone. Country of manufacture does not matter: imported batteries face the same rule as those built in the EU.

Battery passport responsibility: who issues it

The obligation sits with the economic operator that places the battery on the market or puts it into service. For most readers that means you, the manufacturer; for imported packs it can be the importer. That operator may authorise another company in writing to manage the passport, but must still make sure the information is accurate, complete and up to date. For a battery passport for industrial battery manufacturers who rely on cell suppliers and integrators, this means upstream data quality becomes your compliance risk.

A battery without a passport after 18 February 2027 is not a poorly documented product. It is a non-compliant one, open to withdrawal or recall by market surveillance authorities.

Understand which battery categories are in scope, who must comply and the key applicability timelines.

Read the blog to clarify the Battery DPP scope and prepare your business for compliance.

Battery Passport Data Requirements for Industrial Batteries

The passport is a structured data set defined in Annex XIII, split by audience and updated over the battery’s life.

• Five data categories
• Three access tiers
• Lifecycle updates and second life

Battery passport data categories

• General information: manufacturer, model, unique identifier, place and date of manufacture, weight, capacity and chemistry.
• Compliance: EU declaration of conformity, carbon footprint information where it applies, and the due diligence report.
• Materials and composition: hazardous substances, critical raw materials and recycled content.
• Circularity and safety: dismantling, removal and safety guidance for repair and end-of-life operators.
• Performance and durability: rated capacity, expected lifetime and state of health.

In August 2026 the European Commission published guidance listing data points by battery category, showing which are mandatory, optional, or not yet required as of February 2027. Any battery passport for industrial battery manufacturers should map to that document, not to a generic template.

Explore the key data requirements, from battery composition and carbon footprint to supply chain due diligence, performance and sustainability information.

Read the blog to understand the data your business needs to collect, manage and disclose for Battery DPP compliance.

Battery passport access tiers

Article 77(2) separates information for the general public from information for people with a legitimate interest and the Commission, and information reserved for notified bodies and market surveillance authorities. The implementing act defining “legitimate interest” was due by 18 August 2026 and had not been adopted at the time of writing. Choose a system where access rules are configurable, so you can adjust when the act is published.

Battery passport updates through the lifecycle

Stationary storage lives for years, and the passport must follow it. Dynamic values such as state of health need to stay current. When a battery is repurposed or remanufactured, responsibility passes to the operator placing it back on the market, who issues a new passport linked to the original. The passport ends once the battery has been recycled.

Battery Passport Deadlines Industrial Manufacturers Must Track

Four dates shape your plan, and only one of them is the passport itself.

Industry associations have asked lawmakers for a phased passport rollout through the ongoing Omnibus negotiations. As of November 2026, Article 77 is unchanged and carries no conditional extension clause, so plan the battery passport for industrial battery manufacturers on a February 2027 timeline.

Battery Passport Software vs Spreadsheets: Manual vs Platform

Many teams start in Excel. Here is where that approach stops working.

The regulation also requires passport data to rest on open, interoperable standards. That rules out two shortcuts in a battery passport for industrial battery manufacturers: a record frozen at the factory gate, and one locked inside a single vendor.

Battery Passport Readiness with the TraceX DPP Platform

How TraceX helps

Getting a battery passport for industrial battery manufacturers live is a data-collection problem before it is a software problem. The TraceX Battery DPP platform collects multi-tier supplier and material data, maps it to your bill of materials, generates unique identifiers and QR codes, and publishes tiered public and restricted passport views.

TraceX is GDPR, ISO 27001 and SOC 1 and 2 compliant and works with a European law firm on regulatory interpretation.

Be passport-ready before 18 February 2027

Every week you wait shortens the time left for supplier data collection. Start your battery passport for industrial battery manufacturers rollout now.

Battery Passport Evaluation Checklist for Industrial Manufacturers

Use these questions to assess any battery passport for industrial battery manufacturers, including TraceX.

• Does it map to the Commission’s August 2026 data-points guidance for industrial batteries?
• Can suppliers submit composition and recycled-content data with supporting evidence?
• Are access tiers configurable for when the legitimate-interest act is adopted?
• Can it receive state-of-health data from your battery management or monitoring systems?
• Does it issue linked passports for repurposed and remanufactured batteries?
• Is data exportable in open formats if you change providers?
• Does it register identifiers with the EU DPP registry?

Frequently Asked Questions