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The deadline · Reviewed 30 September 2026

What happens on 18 Feb 2027?

Article 77 of the EU Batteries Regulation requires a battery passport for batteries in scope from that date. This page is about the date: what it applies to, what it does not, and what is worth doing before it.

18 Feb 2027Passport requirement for batteries in scope

What the date requires

From 18 Feb 2027, Article 77 requires a passport for LMT batteries, electric-vehicle batteries and industrial batteries with capacity greater than 2 kWh that are placed on the market or put into service. The passport is an electronic record for the individual battery, reached through a QR code carried on it.

The 2 kWh threshold applies to industrial batteries. It is not a floor under the EV and LMT categories, which are in scope by category rather than by size.

Source: Regulation (EU) 2023/1542, consolidated text

What it does not require

It is not an instruction to retrofit a passport onto every battery already working in a fleet. The requirement attaches to batteries placed on the market or put into service from the date, so the question for an existing fleet is what you will be able to evidence about those batteries — not whether each one needs a passport today.

It does not make a registry entry the record. Detailed information stays with the responsible operator in a decentralised system; the passport points at it.

And it is not a Great Britain obligation. See Great Britain, Northern Ireland and the EU — the distinction matters more than the date for a UK business.

Whether it applies to you

Two questions decide it: the battery’s category and capacity, and your role in the supply chain. The obligation falls on the economic operator placing the finished battery on the market, which is not always whoever manufactured a component of it.

Who is responsible for a battery passport?

What is worth doing before it

The part that takes time is not the passport. It is having a defensible record behind the figures a passport asks for — what the battery reported, when, from which source, and where the history has gaps. That record cannot be assembled retrospectively for a period nothing was collected in.

Check the Commission’s category-specific data guidance against the fields you already capture, and note which ones nothing in your stack currently produces.

Source: European Commission — battery passport requirements and category data

A practical first step

Bring one battery and the claim you need to stand behind.

We will look at what your hardware already reports and whether it is enough to evidence a health claim, and say so if it is not.

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