Which batteries need a battery passport?

Three categories need the passport, all need the QR code

Under Art. 77(1) of Regulation (EU) 2023/1542, from 18.02.2027 every LMT battery, every industrial battery above 2 kWh and every electric-vehicle battery needs a battery passport. All other batteries need no passport, but the QR code of Art. 13(6), which leads to their information.

LMT, industrial and vehicle batteries have a passport

LMT batteries. LMT stands for “light means of transport”. They include the batteries of e-bikes and e-scooters. Whoever sells an e-bike battery under their own brand, or imports one, is responsible for its passport.

Industrial batteries above 2 kWh. For industrial batteries the energy decides: above 2 kWh the battery needs a passport, below that it does not, though it does need the QR code. So the energy is one of the first values you record per product.

Electric-vehicle batteries. For most online shops they are rare; whoever offers or imports such batteries under their own brand is responsible for their passport.

Portable batteries need only the QR code

Portable batteries, starter batteries (SLI) and industrial batteries up to 2 kWh need no battery passport. From 18.02.2027, however, they too carry a QR code. It leads to the label's information, the declaration of conformity, the due diligence report and the information on disposal (Art. 13(6)).

For your shop that means: products without a passport duty also need a page the code leads to. Produktpass calls this template “T-BAT-INFO”, the battery information page; the batteries with a passport duty get “T-BAT-PASS”.

Whoever places the battery on the market creates the passport

The category says whether a battery needs a passport; the role says whether you create it. Responsible is the economic operator who places the battery on the EU market (Art. 77(4)): the manufacturer, also as a retailer with an own brand, or the importer from a third country (Art. 3).

Whoever buys a branded battery within the EU and resells it does not place it on the market and does not have to create a battery passport for it (Art. 3). An e-bike battery under your brand and a bought-in branded battery of the same category may therefore be treated differently.

Three values per product settle the sorting

Go through every battery product, including devices with a built-in battery, and record three values: the category (portable, SLI, LMT, industrial, electric vehicle), for industrial batteries the energy in kWh, and who placed the battery on the market. That gives per product: battery passport and QR code, QR code only, or nothing in your responsibility.

In Produktpass you create these values as attributes in JTL-Wawi, such as dpp_battery_category and dpp_energy_kwh. The plugin chooses the template from them: an industrial battery above 2 kWh gets the battery passport, all other categories apart from LMT and electric vehicle the information page. The overview then shows every product with its state, from “no passport” to “published”.

If you have a battery in several variants, for example with 10.4, 13.4 and 17.0 Ah, the variants in Produktpass show their parent product's passport under their own GTIN. Values that differ, such as capacity or weight, you enter at the variant as its own value. So not every variant needs an entirely new passport, and shared information is kept in one place.

The whole picture with its dates is in The EU Batteries Regulation 2023/1542 explained; what the code holds is explained in battery QR code.

A passport covers a model, a batch or a battery

A passport can apply to a model, to a batch or to an individual battery. At which level the regulation asks for the passport is set by the relevant Union law; for the registration in the EU registry this is not settled yet (Implementing Regulation (EU) 2026/1778, Art. 8(2)). Produktpass allows all three levels per product, so that you do not have to commit in advance.

Frequently asked questions

Sources

• Regulation (EU) 2023/1542, Art. 3, Art. 13(6) and (7), Art. 77(1) and (4)
• Implementing Regulation (EU) 2026/1778, Art. 8(2)
• Help for Produktpass: Wawi mapping and the attributes' naming convention