The EU battery passport from February 2027: what European buyers will ask Indian exporters for
- September 7, 2026
From 18 February 2027, certain batteries can only be placed on the EU market if they carry a digital battery passport. For an Indian BESS or e-mobility exporter, the legal duty usually sits with the European buyer. The data behind it, however, sits in the factory. In this informative Q&A-styled article, Niels van Veen, Founder, DPP Hero, explains what is coming, who is responsible, and which figures European buyers will start asking for well before the deadline.
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Niels van Veen, Founder, DPP Hero What is the battery passport, in practical terms?
It is not a label or a certificate. It is a structured, machine-readable record for an individual battery, reachable through a QR code on the product. The QR code itself becomes mandatory on the same date under Article 13(6) of Regulation (EU) 2023/1542. Behind it sits a data set whose contents are listed in Annex XIII of the regulation: material composition, carbon footprint, recycled content, performance figures, safety and dismantling information, and data on the individual battery over its life.
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Which batteries are covered from 18 February 2027?
Article 77(1) covers three categories: EV batteries, LMT batteries such as e-bike and e-scooter packs regardless of capacity, and industrial batteries above 2 kWh. Portable batteries stay outside the scope, and so do SLI batteries for starting, lighting and ignition, whatever their voltage.
For a BESS exporter this is the decisive line: a stationary storage system is neither an EV nor an LMT nor an SLI battery, so it falls under industrial batteries. The 2 kWh threshold is low compared with the systems now being sold, which means commercial and utility-scale products are covered as a matter of course.
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Does the duty apply to an Indian manufacturer, or only to the European buyer?
The duty attaches to placing the battery on the EU market, not to where it is made. Under Article 3(1), point (16), it falls on the economic operator who first makes the battery available on the Union market. In a typical export sale that is the European buyer or importer.
There are two exceptions worth knowing. An Indian company that sells into the EU in its own name, through a European subsidiary or directly, carries the duty itself. And a European system integrator who assembles cells or modules into a system and sells it under its own brand becomes the responsible operator for that system.
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If the buyer carries the duty, why should an exporter care?
Because the buyer cannot create the passport without the supplier. Almost none of the required data can be generated in Europe. Cell chemistry, the carbon footprint of production, recycled content shares, the sourcing of critical raw materials, test results: all of it originates in the factory and in its procurement records.
The practical consequence is that the request travels up the chain. European buyers who intend to sell after February 2027 will start asking their suppliers for these figures during 2026, because they need them in place before their own first shipment.
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Which parts of the passport are public?
More than most suppliers expect. Open to anyone who scans the QR code are the material composition including cell chemistry, hazardous substances and critical raw materials, the carbon footprint, the recycled and renewable content shares, rated capacity, voltages and power, expected lifetime in cycles and the warranty period, plus the responsible sourcing information taken from the due diligence report under Article 52(3).
This matters commercially. Figures that used to travel in a datasheet between two parties become visible to competitors, customers and analysts alike. Exporters should assume their published numbers will be compared.
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And which parts stay restricted?
The detailed composition of cathode, anode and electrolyte, spare part numbers and sources, dismantling information and safety measures go to persons with a legitimate interest and to the Commission. So do the entries for the individual battery: the performance and durability parameters under Article 10(1), the state of health under Article 14, the battery status, and usage data such as charging cycles.
Only the results of test reports are narrower still, limited to notified bodies, market surveillance authorities and the Commission. So the passport is not a wholesale disclosure of intellectual property, but it is more open than a datasheet.
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Which of this data is genuinely hard to produce?
Three items account for most of the effort. The carbon footprint has to be calculated over the life phases of the battery, which means knowing the energy input and origin of the cells rather than estimating them. The calculation methodology itself is still pending as a delegated act, so no final declaration can be made today; what takes time is gathering the underlying energy and sourcing data, and that work can start now. The recycled content share can only be evidenced by the cell or material supplier. And responsible sourcing reaches back to mine and refinery level, so it depends on how far up the chain visibility already exists.
Technical parameters and conformity documents, by contrast, usually exist already. The work is collecting them in one place and keeping them current for each series.
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Does an exporter need its own IT system for this?
No. The regulation specifies what the passport must contain and how it has to be accessible; it does not require every operator to run its own infrastructure. In practice this is a make-or-buy decision, and for most manufacturers buying is the sensible answer: a service maps the Annex XIII attributes, issues the identifier and QR code and manages the tiered access rights.
The cost rarely sits in the software. It sits in the working time needed to gather the missing figures from suppliers and keep them updated.
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Is the field catalogue final?
Not entirely. Parts of Annex XIII are still being detailed in delegated acts, so some entries will be specified further. That is a reason to start collecting the data that is already clearly required, not a reason to wait.
One frequent confusion is worth clearing up. The QR code is a legal requirement from 18 February 2027. GS1 Digital Link is the link syntax commonly used behind such codes: a widely adopted standard, not a legal obligation in itself.
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What should an exporter do in the next six months?
Four steps are enough. First, confirm which product lines are in scope: industrial systems above 2 kWh, LMT packs regardless of capacity, EV batteries. Second, hold Annex XIII against the documents you already have and mark the gaps. Third, put the requests to your own cell and material suppliers in writing and, where possible, into the contract, because their response times set the critical path. Fourth, decide who will generate and maintain the passport record itself.
Exporters who complete the first two steps in 2026 will be able to answer a European buyer’s questionnaire in days. Those who begin in January 2027 will be asking the same cell suppliers as everyone else, at the same time. In a market where European buyers must document their supply chain to sell at all, being ready early is not only compliance. It is a reason to be chosen.
About the author: Niels van Veen is founder of DPP Hero in Hannover, Germany, a GS1 Germany Solution Partner and provider of battery-passport software based on DIN SPEC 99100 for small and mid-sized manufacturers and importers. For more information, write to hello@dpphero.com or visit https://dpphero.com
Sources: Regulation (EU) 2023/1542, Articles 3(1)(16), 10(1), 13(6), 14, 52(3), 77(1) and Annex XIII (EUR-Lex); DIN SPEC 99100; Battery Pass Project (thebatterypass.eu).