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.
From 18.02.2027 the QR code and the battery passport apply
Regulation (EU) 2023/1542, the Batteries Regulation, replaces the old Batteries Directive and applies directly in every member state. Two of its rules take effect on 18.02.2027 and concern everyone who sells batteries, above all whoever places them on the EU market.
First, the QR code. Under Art. 13(6), from that day every battery carries a QR code (Annex VI Part C). It leads to the battery passport or, for batteries without a passport duty, to the label's information, the declaration of conformity, the due diligence report and the information on disposal. The code is on the battery itself or, where that is not possible, on the packaging and the accompanying documents (Art. 13(7)).
Second, the battery passport. Under Art. 77(1), every LMT battery (light means of transport such as e-bikes and e-scooters), every industrial battery above 2 kWh and every electric-vehicle battery needs an electronic battery passport. It has three parts: public information, information for persons with a legitimate interest, and information for authorities (Annex XIII).
The duty falls on manufacturers, own brands and importers
The duties fall on the economic operator who places the battery on the EU market, that is, makes it available on the Union market for the first time (Art. 3). That is the manufacturer who has a battery designed or made and markets it under their own name or brand, also as a retailer with an own brand, and the importer who is established in the EU and places a battery from a third country on the market.
The economic operator who places the battery on the market is responsible for the accuracy of the battery passport; they may mandate another operator in writing (Art. 77(4)).
Whoever buys a branded battery within the EU and resells it, on the other hand, does not place it on the market and does not have to create a battery passport for it (Art. 3). Many online retailers are therefore responsible for one part of their range and not for another: the own brand yes, the bought-in branded battery no. The line often runs right through the shop.
In the shop it starts with the range, the data and the address
The first step is an inventory: which products contain batteries, who placed them on the market, and which group do they belong to? An LMT battery under your brand needs a battery passport and a QR code; a portable battery under your brand needs a QR code that leads to the battery's information; a bought-in branded battery is the responsibility of its manufacturer or importer.
The second step is the data. A battery passport holds the fields of Annex XIII: manufacturer, category, chemistry, capacity, weight, carbon footprint, information on disposal and more. Many of these values are with your supplier or in your merchandise management. Who supplies which value, and who puts the QR code on the battery or the packaging, is therefore worth settling early.
The third step is where the passport lives. The regulation asks that the QR code leads to a unique identifier (Art. 77, ISO/IEC 15459) and that the data is open, machine-readable and available for the long term, even when the economic operator no longer exists (Art. 78).
Registration in the EU registry is still open
Battery passports are among the product passports registered in the EU's registry of digital product passports (Implementing Regulation (EU) 2026/1778, Art. 1(1)(b) and Art. 8). Whether that is needed from 18.02.2027 for passports on the shop's own domain, and at which level (model, batch or individual battery), is not settled yet. If registration becomes necessary, the registry may require a qualified electronic seal of your company (recital 6).
Passport data that can be exported can be registered as soon as the rules are settled, without entering it again.
Produktpass creates passport and QR code in JTL-Shop
Produktpass is a plugin for JTL-Shop 5. It creates battery passport pages and battery QR codes on your shop's domain, with the fields of Annex XIII, and takes data from JTL-Wawi attributes. Every field says what it means and which article asks for it. The plugin chooses the template from category and energy: “T-BAT-PASS” for batteries with a passport duty, “T-BAT-INFO” for all others.
Published passports get a public page and a JSON output at a GS1 Digital Link address; you download QR codes as SVG or as PNG at 600 dpi. Your passports stay online even if you cancel, as long as the plugin stays active. Which batteries exactly need a passport is explained in Which batteries need a battery passport?; the points to tick off are in the battery passport checklist.
Frequently asked questions
From when does the battery passport duty apply?
From 18.02.2027 (Art. 77(1) of Regulation (EU) 2023/1542). From the same day every battery carries a QR code (Art. 13(6)).
Do I need a battery passport as an online retailer?
If you place batteries on the EU market as a manufacturer or importer, also under an own brand, the duty applies to you for those batteries. If you buy branded batteries in the EU and resell them, you do not place them on the market (Art. 3). Whether the duties apply to you, you decide for your products.
Which batteries need a passport?
LMT batteries, industrial batteries above 2 kWh and electric-vehicle batteries (Art. 77(1)). All other batteries need the QR code from 18.02.2027.
Who is responsible for the data in the passport?
The economic operator who places the battery on the market. They may mandate another operator in writing (Art. 77(4)).
Must I register the passports in the EU registry?
For passports on the shop's own domain that is not settled yet (Implementing Regulation (EU) 2026/1778). Produktpass exports the data as CSV and JSON so that you can register it later.
Sources
- Regulation (EU) 2023/1542 (Batteries Regulation), Art. 3, Art. 13(6) and (7), Art. 77, Art. 78, Annexes VI and XIII
- Implementing Regulation (EU) 2026/1778, Art. 1(1)(b), Art. 8, recital 6
Produktpass: Battery passport and battery QR code