---
title: The EU Battery Regulation, handled as a data task
description: What the EU Battery Regulation (EU) 2023/1542 requires, and the software that fills the 94 battery-passport fields — mandatory from 18 February 2027.
canonical: "https://www.tracepass.eu/battery-regulation"
locale: en
source: "https://www.tracepass.eu/battery-regulation"
---

# The EU Battery Regulation, handled as a data task

> What the EU Battery Regulation (EU) 2023/1542 requires, and the software that fills the 94 battery-passport fields — mandatory from 18 February 2027.

Regulation (EU) 2023/1542 makes a digital battery passport mandatory from 18 February 2027 — 94 fields per battery, from chemistry and carbon footprint to supply-chain due diligence. TracePass reads your datasheets, fills what it can, requests the rest from suppliers, and publishes a GS1-compliant passport per unit. The regulation becomes a structured-data problem, not a compliance scramble.

## 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 94 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.
- Recycled-content shares for cobalt, lead, lithium, and nickel — declared, 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.
- 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.

## How TracePass fills the battery passport

### Fill 94 fields from your datasheets

TracePass reads cell datasheets, safety data sheets, and test certificates and fills chemistry, capacity, voltage, weight, and safety data automatically — you review, you don't re-type.

### Carbon-footprint defaults you can replace later

When you don't yet have a verified LCA, defaults from the Battery Pass Consortium / EU PEF fill the CO₂e/kWh field so the passport is complete — swap in your measured figure later without losing the passport.

### 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.

### Reference-database prefill for known cells

Known cell models (Panasonic NCR18650B, Samsung, LG, CATL) prefill dozens of fields in seconds from reference-database lookups — you start from a populated passport, not a blank form.

### Batch passports for the production line

Batch-create up to 500 passports per run, 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 cells they don't manufacture themselves.

## 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?

94 mandatory fields per Annex XIII of Regulation (EU) 2023/1542, covering identity, chemistry, carbon footprint, recycled content, supply-chain due diligence, performance, and end-of-life. TracePass structures all 94: many populate automatically from datasheets and reference databases; 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. Can we still produce the passport?

Yes — as the importer the passport obligation is yours, and TracePass is built for it: upload the OEM 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 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 for manual entry and €350/month for AI-assisted extraction at mid volume. The PEF and GS1 setup are the long-lead items — both should start before the data-collection sprint.
