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Battery Regulation 2023/1542 — article-by-article coverage

The EU Battery Regulation's digital battery passport becomes mandatory 18 February 2027 under Regulation (EU) 2023/1542, Annex XIII, Art. 77 — covering EV, industrial batteries above 2 kWh, and LMT batteries. This page maps Articles 7, 8, 11, 14, and 77 to the TracePass fields that satisfy each requirement, showing the coverage status where an implementing act is still refining the detail.

Regulation (EU) 2023/1542 of the European Parliament and of the Council concerning batteries and waste batteries

Status

  • Modeled

    First-class fields in the schema; no further implementing-act dependency.

  • Partial

    Modeled to draft, but an implementing act continues to refine methodology or thresholds.

  • Pending act

    Not modeled; awaiting the implementing act before we add fields.

Article 7

Carbon footprint

Pending act

Tell buyers how much CO₂ your battery's whole life puts in the air, broken down by stage, with a link to your study and a class rating.

Requirement

Carbon footprint declaration for electric-vehicle, light-means-of-transport (LMT), and rechargeable industrial batteries above 2 kWh: total CF and per-lifecycle-stage breakdown, plus a study URL and a performance class.

TracePass fields

  • carbonFootprintTotal
  • cfRawMaterialAcquisition
  • cfMainProductProduction
  • cfDistribution
  • cfEndOfLifeRecycling
  • carbonFootprintPerformanceClass
  • carbonFootprintStudyUrl
  • carbonFootprintLabel

Notes

The calculation methodology and the performance classes come from acts under Article 7 that are not yet adopted. The Commission's battery-passport guidance (v2.0, August 2026) lists the carbon-footprint data points as not to be filled at the February 2027 start. The schema already holds the fields, marked as anticipated, so they can be filled once those acts apply.

EUR-Lex

Article 8

Recycled content

Pending act

Say what share of the cobalt, lithium, nickel, and lead in your battery came from recycling, and back it up with proof.

Requirement

Declared recycled content for cobalt, lithium, nickel, and lead in industrial, EV, and SLI batteries — supported by documentation that the recycled fraction is verifiable.

TracePass fields

  • recycledContentCobalt
  • recycledContentLithium
  • recycledContentNickel
  • recycledContentLead
  • recycledContentDocumentation

Notes

The Commission's battery-passport guidance (v2.0, August 2026) lists the four recycled-content shares as not to be filled as of February 2027: they apply in line with Article 8 and its delegated act on calculation and verification, which is not yet adopted. The schema holds them as anticipated fields. The minimum-share thresholds come later (from August 2031, stepping up again in 2036); checking a declared value against the threshold in force is the customer's responsibility, not the vendor's.

EUR-Lex

Article 11

Removability and replaceability

Modeled

Users must be able to take the battery out and swap it themselves. Document how to remove it, what spare parts are available, and how to handle it safely at end of life.

Requirement

Portable batteries shall be readily removable and replaceable by end-users — with documentation on removal procedure, dismantling, available spare parts, and end-of-life safety.

TracePass fields

  • batteryRemovabilityReplaceability
  • removalInformation
  • dismantlingInformation
  • sparePartsInformation
  • safetyInformationEndOfLife
EUR-Lex

Article 14

State of health and lifetime

Partial

Track how the battery is aging — health, remaining capacity, how it's been charged, what temperatures it's seen — and make that data available to the right people for the battery's entire life.

Requirement

For industrial batteries above 2 kWh and EV batteries: state-of-health, remaining capacity, fade values, charging history, and historical thermal conditions — accessible to authorised parties throughout the battery's life.

TracePass fields

  • stateOfHealth
  • stateOfCertifiedEnergy
  • remainingCapacity
  • remainingPowerCapability
  • remainingEnergy
  • currentInternalResistancePack
  • internalResistanceIncrease
  • capacityFade
  • powerFade
  • roundTripEfficiencyFade
  • evolutionOfSelfDischargeRate
  • numberOfFullEquivalentChargingCycles
  • numberOfChargingEvents
  • dateOfServiceEntry
  • negativeEvents
  • currentStateOfCharge
  • temperatureConditionsHistorical

Notes

Measurement methodology for state-of-health and the cycle-life test (Annex IV of the regulation, plus implementing acts) continues to evolve. Fields are present; reporting against newer methodology versions is a re-measurement at the customer level, not a schema migration.

EUR-Lex

Article 77

Battery Passport

Modeled

Every battery you sell in the EU needs its own digital passport behind a QR code, with a unique ID, who made it, when and where, what type it is, and where it is in its life.

Requirement

Each LMT, industrial (>2 kWh), and EV battery placed on the EU market shall have a unique digital passport accessible via QR code, containing identifier, manufacturer details, manufacturing date and place, battery category, and lifecycle status.

TracePass fields

  • batteryUniqueIdentifier
  • batteryIdDmcCode
  • batteryPassportIdentifier
  • manufacturerName
  • manufacturerTradeName
  • manufacturerPostalAddress
  • manufacturerEmail
  • manufacturerWebAddress
  • manufacturingDate
  • manufacturingPlace
  • batteryCategory
  • batteryStatus

Notes

Article 77 mandate becomes binding 18 February 2027 — the data carrier (QR / GS1 Digital Link), the Annex XIII data spec, who must comply (manufacturer or importer), and the public/restricted/authority access tiers. The dedicated Article 77 page sets out the requirement in full.

EUR-LexFull Article 77 requirements

Where this fits: see the buyer's guide

/buyers-guide →

Reviewed by Malin Ivanov, Managing Director — on