EU Battery Regulation 2023/1542 — Article 77

From 18 February 2027, a battery without a passport does not clear customs.

Every electric vehicle, industrial and light means of transport battery placed on the EU market must carry a battery passport from that date. There is no transitional period. Certus DPP prepares your product data, publishes the passport and keeps it current.

— days until the battery passport becomes mandatory
Specimen record
ESPR / DPP
CategoryLMT battery
ChemistryLi-ion NMC
Capacity0.63 kWh
StatusRegistry-linked
Cell chemistry and capacity collected from your supplier
Composition and critical raw materials declared
Passport published and resolving from the QR carrier
Registered in the EU product passport registry
QR ON CELL, MODULE OR PACK · RESOLVING PASSPORT URL — illustrative only
Regulation(EU) 2023/1542
Deadline18 February 2027
ScopeEV · Industrial >2 kWh · LMT
CarrierQR on cell, module or pack
Transitional periodNone
Why it matters

The battery passport is the first product passport the EU actually enforces.

Everything else under the Ecodesign Regulation is still waiting on a delegated act. Batteries are not: the date is fixed in the Battery Regulation itself, and it is checked where goods enter the market.

What it holds

Battery identity, cell chemistry and material composition, critical raw materials, capacity, performance and durability, state of health and end-of-life handling — as a structured, machine-readable record.

How it is reached

A QR code on the cell, module or pack resolves to the passport. Market surveillance authorities, recyclers and customs read the same record the buyer does.

What happens without one

A battery whose QR code does not resolve to a valid passport cannot lawfully be placed on the EU market from 18 February 2027, and can be stopped at customs clearance.

Who must comply

The obligation follows whoever puts the battery on the EU market.

This is where most supply chains get caught out. The manufacturer holds the data, but the party that owes the passport is often someone else entirely.

MANUFACTURER OUTSIDE THE EU

You hold the data

Cell chemistry, capacity, sourcing and footprint all originate with you. You may not be the party legally on the hook, but your EU customers cannot comply without what you supply — and they will start asking well before 2027.

IMPORTER INTO THE EU

You carry the obligation

If you are the one placing the battery on the EU market, the passport is your responsibility, including for products you did not manufacture. You must obtain the data from your supplier and be able to show it.

DISTRIBUTOR

You must check before selling

You are expected to verify that a passport exists and resolves before making the product available. Selling a battery without one exposes you, not only the party upstream.

How it works

Four steps, handled for you.

You tell us what you sell and who places it on the market. We work out what applies, gather the data, publish the passport and keep it current.

01

Scope

Which of your batteries are in scope, which entity in your chain carries the obligation, and what your real deadline is per product line.

~15 min
02

Collect

We request the required fields from your cell supplier or manufacturer and chase what is missing — usually composition detail and critical raw material data.

2–6 weeks
03

Publish

The passport goes live on an established platform, the QR carrier resolves to it, and the product is registered where the regulation requires.

Days
04

Maintain

Data changes as models change. We keep the record accurate and flag the categories that come into scope after batteries.

Ongoing
Built for

Anyone whose battery reaches an EU buyer.

E-bike and e-scooter brands
EU importers of light electric vehicles
Battery pack assemblers
Industrial battery suppliers above 2 kWh
Cell manufacturers outside the EU
Consultancies handling several exporter clients
Rollout timeline

One date is fixed. The rest are still being written.

The battery passport comes from the Battery Regulation and its date is already law. Every other category waits on an Ecodesign delegated act, and those dates have moved before.

18 Feb 2027

Batteries — fixed

EV batteries, industrial batteries above 2 kWh and LMT batteries, such as those in e-bikes and scooters, must carry a passport. No transitional period for products placed on the market from that date.

2026–2027

Iron and steel — expected

First product-specific delegated act under the Ecodesign Regulation, with compliance following 18 to 24 months after adoption.

2028–2029

Textiles — expected

Delegated act anticipated in 2027 covering fibre composition, recycled content and durability, with compliance most likely in late 2028 or 2029.

2029–2030

Furniture, electronics and beyond

Further categories phase in through the Ecodesign working plan, which is reviewed in 2028.

How we work

A facilitation service, not a software vendor.

We don't build the passport platform. We do the part that takes the time: working out what applies to you, getting the data out of your supply chain, and keeping the record right.

What we do

Establish which of your products are in scope and who owes the passport, collect and structure the required data, publish it through an established platform, and keep it accurate afterwards.

What we don't do

We are not a certification or conformity assessment body, and we do not take on your obligations as an economic operator. The product and its compliance remain yours.

Why it's structured this way

The platforms already work. What breaks a battery passport project is the data — getting composition and sourcing detail out of a cell supplier who has never been asked for it, in time. That is the work.

Certus DPP is a compliance facilitation service operated by TwoRocks OÜ, Estonia. Passports are hosted on established platforms; Certus DPP prepares the data and manages the process on behalf of clients.
Questions

Frequently asked

What is an LMT battery?

LMT stands for light means of transport: wheeled vehicles powered by an electric motor and weighing under 25 kg. In practice this means e-bikes, e-scooters, electric mopeds and similar. Their batteries are in scope from 18 February 2027 with no minimum capacity threshold, unlike industrial batteries where the threshold is 2 kWh.

Does my e-bike battery really need a passport?

If it is placed on the EU market on or after 18 February 2027, yes. The date comes from the Battery Regulation rather than the Ecodesign Regulation, which is why it is already fixed while other product categories are still waiting on delegated acts.

We manufacture outside the EU. Whose problem is this?

Legally, the obligation sits with whoever places the battery on the EU market — usually your importer or your EU entity. Practically it is your problem too, because they cannot produce the passport without data only you hold. Most of the work is getting that data assembled.

What data does the passport have to contain?

Manufacturer and battery identity, chemistry and material composition, hazardous substances, critical raw materials, capacity and performance, durability, state of health, safety and end-of-life handling. Not everything lands at once: carbon footprint declarations and responsible sourcing information are held back at the February 2027 date because their passport format depends on an implementing act that has not been adopted yet. Anyone telling you a full carbon footprint is due in February 2027 is ahead of the legislation.

What happens at customs without one?

The passport must resolve from the QR code on the cell, module or pack. A battery whose code does not resolve to a valid passport cannot lawfully be placed on the market, and can be stopped at clearance. There is no grace period for products placed on the market from the deadline onwards.

We sell textiles or furniture, not batteries. When does this reach us?

Later, and the dates are not final. Those categories fall under the Ecodesign Regulation and each needs its own delegated act, followed by 18 to 24 months before compliance bites. Current expectations put textiles around 2028 to 2029. Preparation is worthwhile; panic is not.

Get started

Find out whether the deadline applies to you.

Tell us what you sell and who places it on the EU market. We'll tell you which of your products are in scope, who carries the obligation, and what has to happen before February 2027.

No payment required at this stage. We'll confirm what applies to you and what it takes, directly.
Prefer email? Write to info@certusdpp.com.