This article summarises the regulation and is not legal advice. Produktpass helps you with the battery passport and the battery QR code under Regulation (EU) 2023/1542. The plugin's texts, templates and notes are not legal advice. You remain responsible for your duties and for the accuracy of your data. For a binding answer on your own case, ask a lawyer.
1. The duty depends on your role
The duties fall on whoever places a battery on the EU market, that is, makes it available on the Union market for the first time (Art. 3). For every battery the role is one of three: manufacturer (also as a retailer with an own brand), importer from a third country, or reseller of a branded battery bought within the EU. As a reseller you do not place the battery on the market and do not have to create a battery passport for it (Art. 3).
The economic operator who places the battery on the market is responsible for the accuracy of the passport; they may mandate another operator in writing (Art. 77(4)). Who that is in your business, and whether a supplier takes on parts of it, belongs on the checklist.
2. Every battery product belongs to a group
Assign every battery product to a group, including batteries built into devices. From 18.02.2027 LMT batteries, industrial batteries above 2 kWh and electric-vehicle batteries need a battery passport (Art. 77(1)); all batteries need the QR code (Art. 13(6)). The details are in the article Which batteries need a battery passport?.
In the shop it pays to keep category and energy as attributes in JTL-Wawi right away. Then the sorting can be evaluated per product at any time, and a plugin can choose the matching template from it.
3. The QR code comes from the factory
The QR code is printed or engraved on the battery; where that is not possible, on the packaging and the accompanying documents (Art. 13(7)). Who applies the code and which address it holds is settled with the supplier or the factory.
The label with the information of Annex VI Part A applies from 18.08.2026 or 18 months after the implementing act on labelling enters into force, whichever is later (Art. 13(1)). Label and QR code draw on the same information; record it once and use it for both.
4. The passport needs data in three parts
The battery passport has three parts: information open to the public, information for persons with a legitimate interest and information for authorities (Art. 77, Annex XIII). It is kept up to date and ends when the battery is recycled. The data is open, interoperable and machine-readable, available for the long term and protected against change (Art. 78).
In practice that means a list of the fields, each with the source of its value: merchandise management, supplier or data sheet. The information includes six waste-information texts under Art. 74(1)(a) to (f). What does not apply should be marked as such with a reason, not simply left empty.
5. Registry and standards are still developing
Battery passports are registered in the EU's registry (Implementing Regulation (EU) 2026/1778, Art. 1(1)(b)). Registration is at the level the relevant Union law sets, through the registry's web interface or its API (Art. 8(2) and (6)). Only verified economic operators register, a legal person established in the EU with a qualified electronic seal or a qualified electronic attestation of attributes (recital 6). It is still open whether passports on the shop's own domain must be registered from 18.02.2027.
Six harmonised standards on the product passport are published (Implementing Decision (EU) 2026/1736), from EN 18216 to EN 18223. Exportable data fits both developments.
6. Other products follow the Ecodesign Regulation
Product passports for other product groups come with the Ecodesign Regulation (EU) 2024/1781, each only with a delegated act of its own (Art. 9 to 13). Then every retailer must make the passport easily accessible to customers, also in distance selling (Art. 31(2)). There is no such act for batteries.
Produktpass covers points 2 to 5 in the shop
Produktpass covers points 2 to 5 in the shop: it chooses the template from category and energy, takes values from JTL-Wawi attributes or from a CSV file with a dry run, fills in the six waste-information texts as drafts that you check and confirm, and creates the passport page and the QR code. The overview counts the days to 18.02.2027 and shows what is still missing per product. For point 5 the plugin exports the data as CSV and JSON. Battery passport duty 2027 gives the full overview.
Frequently asked questions
Is there a printable checklist?
Yes, as a page of its own that prints as an A4 document or saves as a PDF: checklist for online retailers.
Where do I start?
With your role per battery (Art. 3) and the sorting of your range; that shows for which products you need a passport and a QR code.
What if a field does not apply to my battery?
Mark it as “not applicable” with a reason. Produktpass knows this state for every field.
Do I have to write the waste information myself?
Produktpass fills in the six texts of Art. 74(1) as drafts; you check and confirm each one before you publish.
What applies to products other than batteries?
Product passports come there only with a delegated act of the Ecodesign Regulation (EU) 2024/1781; there is none for batteries.
Sources
- Regulation (EU) 2023/1542, Art. 3, 13, 74, 77, 78, Annexes VI and XIII
- Regulation (EU) 2024/1781, Art. 9 to 13 and 31
- Implementing Regulation (EU) 2026/1778; Implementing Decision (EU) 2026/1736
Produktpass: Battery passport and battery QR code