How many fields does the battery passport require?

From 18 February 2027 the passport must carry the mandatory fields per Annex XIII of Regulation (EU) 2023/1542, covering identity, chemistry and composition, performance and durability, and end-of-life. Carbon footprint, recycled content and supply-chain due diligence phase in later: due diligence from August 2027, the other two once their Commission acts apply. TracePass structures them all: the AI suggests values it can source from datasheets and reference databases, each with its source, for you to approve; the rest are requested from suppliers or entered once and reused across the batch.

Is this different from the EU Battery Directive?

Yes. Regulation (EU) 2023/1542 replaced the 2006 Battery Directive. As a regulation it applies directly in every Member State without national transposition — so the obligations, including the battery passport, land on the same dates across the EU. The older term "Batterierichtlinie" refers to the superseded directive.

We import cells we don't manufacture. Do we need a passport, and can we produce it?

The passport attaches to the finished battery, not to cells or modules. Cells or modules you import as components need no passport of their own; if you assemble the finished battery in the EU, you become its manufacturer and the passport obligation is yours. If you import a finished battery, or a product with one installed, the obligation is yours as the importer. Either way TracePass is built for it: upload the cell maker's datasheet, the platform extracts what it can and requests the supplier-only values through a token-linked portal, so you can compile a compliant passport even when the manufacturer abroad hasn't produced one.

What are the risks of getting the EU Battery Regulation wrong?

The commonest risk is not a missing passport but a misplaced one: Regulation (EU) 2023/1542 imposes three legally distinct information obligations that are easy to conflate. Article 13 is physical marking ON the battery — the separate-collection symbol has applied since 18 August 2025, and the Cd/Pb chemical symbols under Article 13(5). Annex VIII is technical documentation supporting conformity assessment, held and produced on request. Only Article 77 with Annex XIII is the passport itself, mandatory from 18 February 2027. A complete passport behind a missing or undersized label is still a labelling failure. Article 77(4) also puts accuracy, completeness and being up to date on the economic operator placing the battery on the market — a duty that does not transfer to a software vendor, though it may be delegated in writing.

How long must the battery passport stay available?

There is no year count, and quoting one is a common error — the ten-year retention in the Battery Regulation belongs to technical documentation, conformity and due-diligence records (Articles 38(4), 40(3), 41(7) and 48(3)), not to the passport. The passport's rule is event-bound. Article 77(8): a battery passport “shall cease to exist after the battery has been recycled” — recycling is the only terminus. Article 78(e) requires that it “remain available after the economic operator … ceases to exist or ceases its activity in the Union”. So the window runs from placing on the market until the battery is recycled, and it must survive the company that created it. The Battery Regulation does not say how: unlike ESPR Article 10(4), it imposes no back-up copy with a digital product passport service provider, so the operator has to arrange that survival itself, for example through a provider that keeps the passport hosted.

What does battery passport compliance actually cost?

The two biggest variable costs are the PEF (Product Environmental Footprint) study — €8K–€25K via an external assessor, 2–6 weeks — and GS1 membership for a Digital Link resolver at €500–€1,500/year. Internal compliance-team time runs 240–400 person-hours for the first DPP, dropping to 40–80 hours per repeat model once supplier relationships are in place. Software costs are a small fraction: TracePass plans start at €49/month (Basic, ~9 AI extractions included) and €350/month (Starter, ~130 AI extractions a month). The PEF and GS1 setup are the long-lead items — both should start before the data-collection sprint.

EU Battery Regulation 2023/1542 — Compliance Software & Passport

What the EU Battery Regulation requires

From 18 February 2027, every LMT, industrial (>2 kWh), and EV battery placed on the EU market must carry a digital battery passport with the mandatory data fields — reachable from a QR code on the battery and resolvable through a unique GS1 Digital Link identifier. This obligation comes from Regulation (EU) 2023/1542, which replaced the 2006 Battery Directive with directly-applicable rules across every EU Member State, meaning the same passport requirements take effect on the same dates everywhere in the Union without any national transposition needed.

Digital battery passport mandatory from 18 February 2027 for LMT, industrial (>2 kWh), and EV batteries.
Carbon footprint declaration per battery model, with a calculated CO₂e/kWh figure and a defined methodology — applies once the Commission's calculation and format acts are adopted, so it is not in the passport in February 2027.
Recycled-content shares for cobalt, lead, lithium, and nickel — declared from 18 August 2028 at the earliest (LMT batteries: 18 August 2033), then rising to minimum thresholds on the staged timeline.
Supply-chain due diligence: documented policies on the social and environmental risks of raw-material sourcing, applying from 18 August 2027.
State-of-health and durability data for the battery management system, accessible to authorised parties.
Unique identifier + data carrier (QR) resolving to the passport, following the GS1 / EU data-model conventions.

The software

How TracePass builds the battery passport

Sourced suggestions from your datasheets

TracePass reads cell datasheets, safety data sheets, and test certificates and suggests chemistry, capacity, voltage, weight, and safety values where they state them, each with its source and a confidence score — you review and approve, you don't re-type.

Carbon-footprint defaults you can replace later

When you don't yet have a verified LCA, a chemistry-average default fills the CO₂e/kWh field as a placeholder — mark it as estimated and replace it with your measured figure before the carbon-footprint obligation applies.

Request supplier-only data automatically

Scope-1 emissions, exact cobalt provenance, due-diligence attestations — when only the cell maker holds a value, TracePass emails them from a token-linked portal and writes the answer back into the field.

Sourced suggestions for known cells

TracePass reads cell-maker datasheets for models like Panasonic NCR18650B, Samsung, LG, and CATL to extract chemistry, capacity, and performance fields — you start from sourced suggestions to review, not a blank form; anything the datasheet doesn't cover stays for you or your supplier.

Batch passports for the production line

Batch-create up to 100 passports per call, with auto-generated serial numbers and per-unit QR codes ready for the line — importers can build the passport they're legally responsible for from a single OEM datasheet.

Every field carries source, confidence, and an audit trail

Auto-extracted values are suggestions with a source and a confidence score, queued for explicit human review before publishing — so your QA signs off on the passport, and the audit trail shows where every value came from.

Who it's for

Cell manufacturers, pack assemblers, EV / e-bike / industrial-battery brands, and importers compiling battery passports — including for batteries whose cells they don't manufacture themselves.

Looking for the Annex XIII battery passport capability itself? See the battery DPP page.

Article 77, point by point: what the battery passport must contain, and from when.

Exact data point counts per battery type — EV, LMT, and industrial >2 kWh.

EU Battery Regulation — frequently asked

When does the EU battery passport become mandatory?: From 18 February 2027, under Regulation (EU) 2023/1542, every LMT, industrial (>2 kWh), and EV battery placed on the EU market must carry a digital battery passport reachable via a QR code. The data model needs to be in place ahead of that date, not after it.
How many fields does the battery passport require?: From 18 February 2027 the passport must carry the mandatory fields per Annex XIII of Regulation (EU) 2023/1542, covering identity, chemistry and composition, performance and durability, and end-of-life. Carbon footprint, recycled content and supply-chain due diligence phase in later: due diligence from August 2027, the other two once their Commission acts apply. TracePass structures them all: the AI suggests values it can source from datasheets and reference databases, each with its source, for you to approve; the rest are requested from suppliers or entered once and reused across the batch.
Is this different from the EU Battery Directive?: Yes. Regulation (EU) 2023/1542 replaced the 2006 Battery Directive. As a regulation it applies directly in every Member State without national transposition — so the obligations, including the battery passport, land on the same dates across the EU. The older term "Batterierichtlinie" refers to the superseded directive.
We import cells we don't manufacture. Do we need a passport, and can we produce it?: The passport attaches to the finished battery, not to cells or modules. Cells or modules you import as components need no passport of their own; if you assemble the finished battery in the EU, you become its manufacturer and the passport obligation is yours. If you import a finished battery, or a product with one installed, the obligation is yours as the importer. Either way TracePass is built for it: upload the cell maker's datasheet, the platform extracts what it can and requests the supplier-only values through a token-linked portal, so you can compile a compliant passport even when the manufacturer abroad hasn't produced one.
What are the risks of getting the EU Battery Regulation wrong?: The commonest risk is not a missing passport but a misplaced one: Regulation (EU) 2023/1542 imposes three legally distinct information obligations that are easy to conflate. Article 13 is physical marking ON the battery — the separate-collection symbol has applied since 18 August 2025, and the Cd/Pb chemical symbols under Article 13(5). Annex VIII is technical documentation supporting conformity assessment, held and produced on request. Only Article 77 with Annex XIII is the passport itself, mandatory from 18 February 2027. A complete passport behind a missing or undersized label is still a labelling failure. Article 77(4) also puts accuracy, completeness and being up to date on the economic operator placing the battery on the market — a duty that does not transfer to a software vendor, though it may be delegated in writing.
How long must the battery passport stay available?: There is no year count, and quoting one is a common error — the ten-year retention in the Battery Regulation belongs to technical documentation, conformity and due-diligence records (Articles 38(4), 40(3), 41(7) and 48(3)), not to the passport. The passport's rule is event-bound. Article 77(8): a battery passport “shall cease to exist after the battery has been recycled” — recycling is the only terminus. Article 78(e) requires that it “remain available after the economic operator … ceases to exist or ceases its activity in the Union”. So the window runs from placing on the market until the battery is recycled, and it must survive the company that created it. The Battery Regulation does not say how: unlike ESPR Article 10(4), it imposes no back-up copy with a digital product passport service provider, so the operator has to arrange that survival itself, for example through a provider that keeps the passport hosted.
What does battery passport compliance actually cost?: The two biggest variable costs are the PEF (Product Environmental Footprint) study — €8K–€25K via an external assessor, 2–6 weeks — and GS1 membership for a Digital Link resolver at €500–€1,500/year. Internal compliance-team time runs 240–400 person-hours for the first DPP, dropping to 40–80 hours per repeat model once supplier relationships are in place. Software costs are a small fraction: TracePass plans start at €49/month (Basic, ~9 AI extractions included) and €350/month (Starter, ~130 AI extractions a month). The PEF and GS1 setup are the long-lead items — both should start before the data-collection sprint.

Be passport-ready before 18 February 2027

Start from your existing datasheets. TracePass's AI suggests the values it can source, each with its source, for you to approve; you request the rest from your suppliers through the supplier portal, and TracePass publishes a GS1 Digital Link passport per battery.

Get started See the battery passport →

Reviewed by Malin Ivanov, Managing Director — on 2026-06-05

The EU Battery Regulation, handled as a data task