Are you covered by the EU Battery Regulation?

The producer, meaning whoever manufactures batteries, builds them into their own product, imports them or sells them under their own name. Remanufacturers become the producer of the battery they place on the market again. Distributors, repairers and end-users have no producer obligations, but each have their own duties. If you are a producer, your batteries must have a QR code from 18 February 2027, regardless of battery type.

You can, but it is more than a QR code. Issuing a battery passport can look like a simple task. Technically and day to day, it is one of the most demanding data tasks manufacturers and importers face.

1. Data from the whole supply chain
The passport requires up to 90-100 data points, and they are not in one place. Among other things, the passport must contain:

• the battery's material composition, including chemistry, hazardous substances and critical raw materials
• the battery's carbon footprint
• information on responsible sourcing from the due diligence report
• recycled content

2. A passport that lives with the battery
The battery passport is not a static PDF document. It must be updated throughout the battery's life.

• The passport contains information on the battery model and on the individual battery, including information resulting from its use.
• For the individual battery, this includes state of health, status, number of charge cycles, accidents, temperature and state of charge.
• Whoever places the battery on the market must ensure that the information is complete, accurate and up to date.

3. Open standards and interoperability

• The information must be based on open standards and be machine-readable, structured and searchable.
• It must be transferable through an open, interoperable network without vendor lock-in.
• The passport must be fully interoperable with other digital product passports under the EU ecodesign rules.
• The passport must remain available, even if the company ceases to exist.
• Data must be authentic, reliable and protected against fraud.

4. One passport per battery
Where CE marking applies to a whole product series, the battery passport applies to the individual battery.

• The QR code on the battery links to a unique identifier assigned by whoever places the battery on the market.
• The QR code and identifier must comply with ISO/IEC 15459.

5. Second life, repair and recycling
The passport's life does not end when the product is sold.

• If the battery is reused, repurposed or remanufactured, it gets a new passport linked to the original.
• When the battery becomes waste, responsibility for the passport passes to the producer, a producer responsibility organisation or the waste management operator.
• The passport ceases to exist when the battery has been recycled.

Yes, as a rule. If you sell the product under your own name and are the first to make it available on the market of an EU Member State, you are the producer of the battery in it, even if you bought the battery from someone else. The regulation explicitly covers batteries built into appliances and vehicles.

LMT batteries, electric vehicle batteries and industrial batteries over 2 kWh must have a digital battery passport from 18 February 2027. Portable batteries, SLI batteries and industrial batteries under 2 kWh are exempt, but are still covered by producer responsibility, labelling and product requirements. This also applies to portable batteries of general use in the formats 4.5 V (3R12), button cells, D, C, AA, AAA, AAAA, A23 and 9 V (PP3). Whether or not the battery needs a passport, all batteries must be labelled with a QR code from 18 February 2027 (Art. 13(6)).

Yes. From 18 February 2027, all batteries must be labelled with a QR code, including portable batteries, portable batteries of general use such as AA, AAA and button cells, SLI batteries and industrial batteries under 2 kWh. For them, the QR code does not give access to a battery passport, but to the labelling information, the EU declaration of conformity, information on the management of waste batteries and, when you are covered by the due diligence requirements, the report on your due diligence policy. For SLI batteries, it must also show the recovered content of cobalt, lead, lithium or nickel (Art. 13(6)). Syntakk can deliver the QR solution and keep the information behind it up to date, even when you do not need a battery passport.

No. The 2 kWh capacity threshold only applies to industrial batteries. LMT and electric vehicle batteries need a battery passport regardless of capacity.

Run the check once per type. The requirements follow the individual battery category, so a range with both portable and industrial batteries can have different obligations.

No. The check is for guidance and is based on Regulation (EU) 2023/1542 and the Danish Executive Order No. 986 of 20 June 2025. Formal responsibility lies with the economic operator placing the battery on the market.