EU Battery Regulation compliance made simple

Frequently asked questions about the EU Battery Passport

Answers to our clients' most frequent questions. Can't find your question? Get in touch with us directly.

When will the secondary legislation for the Battery Passport be published?

The EU Battery Regulation provides the legal basis for 32 Delegated Acts and 15 Implementing Acts. Of these, 18 will be adopted according to the timeline set in the Regulation to define specific implementation rules, while the remainder may be adopted at the Commission's discretion as the market and technical standards evolve.

Which batteries need a full Battery Passport, and which only a QR code?

A full Battery Passport is mandatory for LMT (light means of transport) batteries, industrial batteries over 2 kWh, and electric-vehicle batteries. All other batteries require a QR code giving access to core information — basic data, the separate-collection symbol, the Declaration of Conformity, the due-diligence report, and waste-management information. The QR code must be printed or engraved clearly and indelibly (per ISO/IEC 18004:2015); if the battery is too small, it goes on the packaging and accompanying documents.

We export one battery model used for different purposes. Do we need a passport for all of them?

Likely yes. The Battery Passport obligation depends on the battery's category — LMT, industrial (>2 kWh), or EV — and the definition of 'industrial battery' effectively captures batteries that don't fall under the LMT or EV definitions. Because the category can even change over a battery's life (e.g. an EV battery repurposed for stationary storage), batteries that could be used in passport-requiring applications should be treated accordingly.

How are supply-chain due diligence and carbon footprint handled if they apply later than the passport?

Until those requirements take effect, they do not need to be included in the Battery Passport. Once they apply, the information must be added to the existing passport or attached as a new passport via the QR code. As these are largely static, organisation-level 'paper compliance' items, work should begin as soon as the EU methodology is published, so the documentation can be incorporated before February 2027.

How do OEM / white-label battery manufacturers ensure compliance?

Under Article 3(33), whoever markets a battery under their own name or trademark is considered the 'manufacturer' — even for white-label products — and carries the full manufacturer obligations. So a company selling a re-branded battery takes on the same compliance responsibilities as the original maker.

Who is responsible for the passport after a battery is resold to end-users?

Responsibility for the accuracy, completeness, and timeliness of the Battery Passport rests with the economic operator placing the battery on the market or putting it into service. When an EU customer takes ownership of a battery and sells it on to end-users, that customer assumes responsibility for the passport.

How should e-commerce platforms handle Battery Passport compliance?

Two roles matter. The importer or fulfilment centre that physically holds the goods is an economic operator and must be able to appear as such on customs declarations. The e-commerce seller operating the sales account must ensure a Battery Passport is provided for each product sold, and may also have repair and recycling reporting obligations requiring system access for lifecycle events.

How should a customer's EU sales company handle compliance?

It depends on their role under the Regulation. If they import batteries and place them on the EU market, they are the economic operator placing the battery on the market and carry the corresponding passport responsibilities. Where compliance spans several entities, it is often handled most reliably by centralising it with one party that holds the complete documentation and can provide consistent legal, audit, and customer-service support.