From 18 February 2027, EV batteries, light means of transport (LMT) batteries such as e-bike packs, and rechargeable industrial batteries above 2 kWh placed on the EU market must carry a battery passport: a structured digital record, unique to each individual battery, reachable through a QR code on the battery itself. The obligation comes from the EU Battery Regulation, Regulation (EU) 2023/1542, and it is the first product passport requirement with a fixed date, arriving ahead of the broader Digital Product Passport wave under ESPR.
Who is in scope, precisely
The passport obligation covers three battery classes: electric vehicle batteries, LMT batteries, and industrial batteries with capacity above 2 kWh. Portable consumer batteries, the AAs and coin cells, are not in passport scope, though they carry other obligations under the same regulation (labelling, collection, due diligence). The economic operator placing the battery on the EU market is responsible, which catches importers of Asian-made packs just as firmly as European manufacturers.
What the passport must contain
The regulation's Annex XIII enumerates the data: manufacturer and manufacturing plant identity, battery model and unique identifier, carbon footprint (with its own phased declaration rules), recycled content shares for cobalt, lithium, nickel and lead, performance and durability data updated over the battery's life, and information for dismantlers and recyclers. Access is tiered: some fields are public to anyone scanning, others restricted to authorities and operators with a legitimate interest.
Why this is an item-level problem, not a SKU-level one
Most packaging QR programs identify a product model. The battery passport identifies an individual battery, so each unit needs a unique identifier in its code, and the record behind it accumulates data over that unit's life: state of health, repairs, repurposing. In GS1 terms that is a GTIN plus serial, exactly what a Digital Link URI expresses as /01/GTIN/21/SERIAL, and what serialized QR programs already print at scale. Brands that already run serialized codes have solved the hard half of the passport plumbing.
The carrier question, answered once
The regulation requires a QR code linking to the passport record. It does not mandate a syntax, but the industry logic runs one way: batteries already carry GS1 identity for retail and logistics, passports need per-unit identity, and Digital Link is the standard that unifies both in one printable code. A conformant resolver then routes each scan by audience, the same mechanism serving consumers the public fields and authorities their view. On Onpack, per-unit identity, EU-scan-aware compliance content and serialized codes are all existing features of the free service; the passport data record itself lives with whichever system the operator designates, and the code on the battery is the stable pointer to it.
The timeline working backwards from February 2027
Now: confirm scope (which of your models cross the 2 kWh line, which markets), and assign GTINs plus a serialization scheme if none exists.
Mid 2026: pilot the code: print serialized Digital Link QRs on one model, resolve them, and verify the tiered-access story with your passport data provider.
Late 2026: production integration, so that units manufactured from January 2027 onward carry compliant codes; batteries placed on the market from 18 February 2027 must have the passport live.
The regulation text is long; the engineering is not. Per-unit codes pointing at per-unit records through a standard resolver is a solved pattern, and the free tooling for bulk code generation and resolution removes the infrastructure line from the budget.
Common questions
Which batteries need a passport from February 2027?
EV batteries, light means of transport batteries such as e-bike packs, and rechargeable industrial batteries above 2 kWh placed on the EU market from 18 February 2027. Ordinary portable consumer batteries are not in passport scope.
Is the battery passport per model or per individual battery?
Per individual battery. Each unit carries a unique identifier in its QR code, and its record accumulates lifecycle data, which makes serialization a prerequisite.
Does the QR code have to be a GS1 Digital Link?
The regulation mandates a QR code linking to the passport, not a specific syntax. Digital Link is the industry-standard way to encode per-unit identity (GTIN plus serial) in that code, which is why adoption is converging on it.
Who holds the passport data?
The economic operator placing the battery on the market is responsible for the record, typically via a passport data provider. The code on the battery is the permanent pointer; the resolver routes each audience to its permitted view.