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.
One regulation covers the whole single market
Regulation (EU) 2023/1542, the Batteries Regulation, applies directly in all member states. A shop that sells e-bike batteries to customers in Germany, Austria and France follows one set of rules, not three. Two of its rules start on 18.02.2027: the QR code on every battery (Art. 13(6)) and the battery passport (Art. 77(1)).
The passport is required for 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. All other batteries need the QR code, which then leads to the label's information, the declaration of conformity, the due diligence report and the information on disposal.
Importers and own brands are responsible themselves
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). Two roles matter for online shops. The manufacturer is whoever has a battery designed or made and markets it under their own name or brand; that includes a retailer selling under an own brand, even when a factory abroad makes the battery. The importer is whoever is established in the EU and places a battery from a third country on the market.
Many online shops buy batteries directly from factories outside the EU, often under their own brand. In that case the shop itself is responsible for the passport and the QR code. Whoever buys a branded battery within the EU and resells it, by contrast, does not place it on the market and does not have to create a battery passport for it (Art. 3). The responsible operator may mandate another operator in writing, but stays responsible for the accuracy of the data (Art. 77(4)).
The passport has three parts
The battery passport has three parts (Annex XIII): information open to the public, information for persons with a legitimate interest, and information for authorities. The public part covers, among others, the manufacturer, the battery category, the chemistry, the capacity, the weight, the carbon footprint and the information on disposal. The QR code leads to a unique identifier under ISO/IEC 15459, parts 1 to 6 (Art. 77); a common form is a GS1 Digital Link address with the product's GTIN.
The data must be open, interoperable and machine-readable, with free access according to the access rights, available even when the economic operator no longer exists, and protected against change (Art. 78). The passport is kept up to date and ends when the battery is recycled.
The passport page appears in German and English
Customers across the EU scan the same code. A passport page that can show its information in more than one language helps them. Produktpass serves the public passport page in German and in English; when a value is missing in the visitor's language, a fallback order applies: first your shop's default language, then English, then German. Texts such as the six waste-information texts of Art. 74(1) have one value per language.
Registration in the EU registry is still open
Battery passports are 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 a shop's own domain, and at which level (model, batch or individual battery), is not settled yet. If it becomes necessary, the registry may require a qualified electronic seal of your company (recital 6). Exportable passport data can be registered once the rules are clear.
Category, energy and role decide the duty per product
It starts with the range: for each battery product its category, for industrial batteries its energy, and your role (manufacturer, importer or reseller). That tells you which products need a passport and a QR code and which only a QR code. Then come the data from the suppliers and the question of who applies the code to the battery or, where that is not possible, to the packaging and the accompanying documents (Art. 13(7)).
The detailed walk-through is in battery passport duty 2027, and the category rules in Which batteries need a battery passport?.
Produktpass publishes the passports from JTL-Shop
If your shop runs on JTL-Shop 5, Produktpass 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 or a CSV file. Every published passport gets a public page and a JSON output at a GS1 Digital Link address; QR codes come as SVG or as PNG at 600 dpi. Your passports stay online even if you cancel, as long as the plugin stays active.
Frequently asked questions
When does the EU battery passport start?
On 18.02.2027 (Art. 77(1) of Regulation (EU) 2023/1542), together with the QR code on every battery (Art. 13(6)).
I import batteries from outside the EU. Am I responsible?
If you are established in the EU and place a battery from a third country on the market, you are the importer under Art. 3, and the duties apply to you for that battery.
Does the regulation differ between member states?
No. As a regulation it applies directly in all member states.
Which batteries need a passport?
LMT batteries, industrial batteries above 2 kWh and electric-vehicle batteries (Art. 77(1)); all batteries need the QR code.
In which languages is the passport page shown?
Produktpass serves it in German and English, with a fallback order when a value is missing in the visitor's language.
Sources
- Regulation (EU) 2023/1542, Art. 3, Art. 13(6) and (7), Art. 74(1), Art. 77, Art. 78, Annex XIII
- Implementing Regulation (EU) 2026/1778, Art. 1(1)(b), Art. 8, recital 6
Produktpass: Battery passport and battery QR code