It promises full transparency across the value chain. For recyclers and second-life operators, however, its real value will depend on the quality and accessibility of the data behind the QR code.

What is the EU battery passport?

The battery passport is an electronic record linked to an individual battery and accessed via a QR code on the product. It is required under Article 77 of Regulation (EU) 2023/1542 and is designed to track a battery from raw material sourcing and manufacturing through use, repurposing and recycling.

Access is tiered:

• Public: most model-level information.
• Persons with a legitimate interest, such as recyclers, repairers and repurposers: restricted model data and data on the individual battery.
• Market surveillance authorities and the European Commission: compliance test reports and related data.

What data will it contain?

At model level, the passport covers:

• manufacturer and battery identification,
• chemistry, critical raw materials and hazardous substances,
• carbon footprint and recycled content,
• technical performance parameters,
• dismantling, safety and recycling information.

For each individual battery, the passport also includes dynamic data updated during use, such as state of health (SoH), charge cycles and information on incidents and operating conditions.

Where the passport falls short

For recyclers, the passport solves a real problem. Reliable information on chemistry, design, hazards and dismantling makes it easier to plan safe transport, storage and the right processing route.

Second-life decisions are a different matter. Deciding whether a battery can be reused, refurbished or repurposed for energy storage requires trustworthy, up-to-date data on the condition of that specific unit. The open questions are:

• how often, and by whom, state of health data will be updated,
• whether second-life operators will get practical access to it (the implementing act on legitimate-interest access was due by 18 August 2026),
• how far battery management system data can be trusted without independent testing.

None of this makes the passport less important. It does mean it will complement, not replace, independent diagnostics. Second-life operators will still need testing, and recyclers will still need verified information on what actually arrives at their gate.

How to prepare

Producers and importers of in-scope batteries should already be setting up processes to collect, manage and share passport data. Collection, treatment and recycling operators should plan how passport data will feed into their acceptance, storage and dismantling procedures.

Wastes Service Group specialises in the collection, transport and recycling of spent batteries, including EV and industrial batteries, across Poland and the EU. Get in touch to prepare your business for the new requirements.

FAQ

When does the EU battery passport become mandatory?

From 18 February 2027 for EV batteries, LMT batteries and industrial batteries above 2 kWh.

Do portable batteries need a battery passport?

No. Portable batteries and SLI (starter) batteries are outside the scope of the requirement.

Does the battery passport include state of health data?

Yes. Individual-battery data, including state of health, is updated during use, but only persons with a legitimate interest can access it.