Battery passport: mandatory from 18 February 2027, and the key data point sits outside the company
7 min read
A typical scenario, not our own case. A company that assembles industrial energy storage systems — battery packs above 2 kWh, destined for solar plants and factory microgrids in the energy sector — receives a request from a public-sector client: the battery passport for the latest batch delivered. The sales office knows how many units it shipped. The engineering office knows which cells it assembled them from. Neither, on its own, can say whether the cobalt and nickel in that cell come from a verified supply chain, what carbon footprint has been declared for the plant that manufactured them, or how many charge cycles that specific pack has already logged in the field.
The duty sits in Article 77; it applies from 18 February 2027
Regulation (EU) 2023/1542 of 12 July 2023, published in the Official Journal of the European Union L 191/1 of 28 July 2023, is directly applicable in every Member State: no transposing decree stands in between. Article 77(1) sets the date and the scope: “From 18 February 2027 each LMT battery, each industrial battery with a capacity greater than 2 kWh and each electric vehicle battery placed on the market or put into service shall have an electronic record (‘battery passport’).” Not a label: an electronic file, accessible through a QR code linked to a unique identifier (Art. 77(3)), which the economic operator placing the battery on the market must keep “accurate, complete and up to date” (Art. 77(4)).
The obligation does not appear out of nowhere on 18 February 2027: it sits on top of layers already in force. The due-diligence duty on the supply chain applies from 18 August 2025 (Art. 48(1)); state-of-health data has fed into the on-board management system since 18 August 2024 (Art. 14(1)); the carbon footprint declaration, depending on category, starts between 2025 and 2026 (Art. 7). The passport introduces no new data: it forces companies to bring together, in one searchable file, data the regulation already requires them to produce elsewhere — the same logic behind the technical file the Cyber Resilience Act demands for connected products’ software.
Where the data the passport asks for actually sits
Annex XIII lists what the passport must contain, and the list cuts across offices that do not currently talk to each other. Material composition — chemistry, hazardous substances, critical raw materials present — sits in the engineering office’s bill of materials, often in a PLM system kept apart from the ERP. The carbon footprint per manufacturing plant (Art. 7) is almost always a study commissioned from an outside consultant, with a different value for every production site and every process revision. The report on the due-diligence policy (Art. 52(3)) is held by procurement, rebuilt from supplier attestations that, in turn, depend on second- and third-tier suppliers. Performance parameters and the state of health of the individual battery (Art. 14; Annex XIII, point 4) sit in no corporate system at all: they live inside the battery’s own management system, built into the product itself, and only surface when someone reads them. And when a battery pack is repaired, repurposed or enters a second life, Article 77(7) requires a new passport, “linked to the battery passport or passports of the original battery or batteries” — an event that almost always happens outside the walls of whoever manufactured it, under an end-of-life logic not so different from the one Italy’s RENTRI waste-tracking system requires companies to prove step by step.
Five, six systems — PLM, the environmental office, procurement, the on-board management system, the service network — none of which alone holds the answer Annex XIII asks for. The same pattern has already shown up with the Packaging Regulation and with customs origin rules: here, though, one of the missing pieces does not even sit inside the company.
The one piece of data no corporate system holds in full
The piece that is almost always missing is the verified supply chain for critical raw materials: cobalt, natural graphite, lithium, nickel, and the chemical compounds derived from them (Annex X, point 1). Article 47 exempts operators that, in the financial year preceding the last financial year, recorded a net turnover below EUR 40 million, even calculated on a group basis; above that threshold, Article 48 requires that, from 18 August 2025, economic operators placing batteries on the market “set up and implement battery due diligence policies.” Article 51 requires that policy to be verified by a notified body, with periodic audits. Article 52(3) requires an annual report to be published containing “the data and information on steps taken … including findings of significant adverse impacts” in the social and environmental risk categories of Annex X. This data is not born inside the company: it is born at the mine or the refinery, passes through suppliers the final assembler often cannot even name, and must be verified by an independent third party before it can appear, publicly, in part 1 of the passport. It is not a document to pull from a drawer: it is a chain of custody to keep alive, year after year, on raw materials that change supplier more often than the battery model itself changes — and one that also feeds back into product liability if a pack turns out to be defective because of a component from that chain.
If a client — or the market surveillance authority — asked tomorrow morning for the complete passport on your most recent batch, how many systems would you need to open, how many people would you need to contact, and how long would it take before the due-diligence report, the carbon footprint calculation and the on-board management system’s data told the story of the same battery model again?
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Where we stop
We do not provide environmental or customs advice, and we do not qualify the compliance of any specific product: those are assessments for the manufacturer and its verification bodies. On penalties, Article 93 leaves the rules to the Member States, with the one shared constraint that they be “effective, proportionate and dissuasive,” and it set 18 August 2025 as the deadline for adopting them: we have not verified against a primary source whether or how Italy has defined them, nor which national authority has been designated for market surveillance under this regulation, and we therefore report no amounts. On recycled content (Art. 8), the supporting documentation only becomes mandatory from 18 August 2028, or 24 months after the delegated act fixing the calculation rules if later: in the 2027 passport it will appear “to the extent applicable to the category” of battery, not yet for every one.
The two axes, applied
Complying. In our system, the duty under Article 77 becomes a control running on the client’s documents and systems: for every battery model, which Annex XIII data is already available, which system holds it, who updates it — with an alert when the annual due-diligence report changes, a critical-raw-material supplier is replaced, or a repair touches a pack that already has a passport. The file comes out exportable and dated, ready for the QR code, instead of being rebuilt by hand across PLM, procurement and the on-board management system while the client waits.
Deciding. The same system brings together the ERP, PLM, accounts, procurement and supply-chain archives into a single operating model, on which AI agents execute decisions with a human operator in command: not just filling in the passport when asked, but knowing in advance which batch is about to fall outside the due-diligence report’s coverage, which second-tier supplier bears on which model, where to step in before the request lands. For large enterprises, defence, government and healthcare — wherever energy storage is critical infrastructure, not an accessory. Always in two delivery modes: on-premises, on autonomous machines that need no deep integration into the client’s network, or dedicated cloud, with a dedicated VPN and a data centre in Italy — always with shared management.
From the first session, at no cost, comes the dated list of your battery models, with, for each one, which Annex XIII data is already available, which system holds it and who updates it — blank boxes included. It stays yours even if we do not go on together. Talk to one of our engineers.