Setting up battery passports

The steps

• Give every battery a unique identifier that follows the ISO/IEC 15459 series of standards. You can create identifiers yourself, with one of the options in those standards, or use a commercial service

• Collect the model data and the data of each battery, mostly from your supplier

• Publish a passport for each battery, hosted by you or by an operator you authorise in writing

• Put a QR code on each battery that links to its identifier and opens the passport

• Upload each identifier to the EU registry for digital product passports

• Keep the passport up to date while the battery is in use

The EU registry

Article 77(10) requires the company that places the battery on the market to upload its unique identifier to the registry set up under the Ecodesign Regulation. The registry opened on 20 July 2026. It records registrations and metadata; it doesn’t host the passports.

• A company verifies its identity with a qualified electronic seal or a qualified electronic attestation of attributes. A sole trader can also use a qualified electronic signature or an eID at assurance level high

• Verification lasts as long as the means used, and at most three years

• Registration works through an API, by hand, or as a bulk upload of passports exported from your own system

• Unlike other product passports, the battery passport’s registration doesn’t go in the customs declaration

What any passport system has to do

Articles 77 and 78 set the requirements, whoever builds or runs the system:

• Open standards and an interoperable, machine-readable, structured and searchable format, transferable without vendor lock-in

• Free access for consumers, economic operators and others, according to their access rights

• Access levels: public data for everyone, restricted data for parties with a legitimate interest, test results for authorities

• Only authorised parties can add or change data, and its authenticity, reliability and integrity are ensured

• A high level of security and privacy, and protection against fraud

• The passport stays available after the company responsible stops trading or leaves the EU, until the battery is recycled

• An operator that stores the data for you may not sell, re-use or process it beyond that service

The Regulation prescribes no technology. According to the Commission’s FAQ, blockchain is allowed but not required.

Keeping it up to date

Data that changes with use, such as the state of health, has to be updated at least when the battery’s status changes or a change is being considered, for example before it is remanufactured, repurposed or recycled. For an e-bike battery without a connection, the Commission’s FAQ considers updating it when the battery comes in for servicing appropriate.

Text that isn’t language-neutral has to be in a language that end-users in the country of sale easily understand.

Yourself, through your supplier or with a service

You can run the passports yourself, let your supplier manage them or use a service provider. Either way, the company that places the battery on the market stays responsible for the data and registers it. The Batteries Regulation doesn’t regulate passport service providers, so what they do for you depends on your contract.

Questions worth asking any provider:

• Can we export all passports in an open format and move them elsewhere?

• What happens to the passports if you, or we, stop trading?

• Who can see the restricted parts, and how are they protected?

• How do the identifiers get into the EU registry under our verified account?

• Which identifier scheme and data model do you use?