Battery Passport: Cells, Modules or the Finished Battery?

A supplier delivers three battery packs. They end up in the same energy storage installation. Does the project need three passports, one passport, or none under the battery rules? The number of boxes does not settle it. What matters is whether they are separate finished batteries or components of one battery.

This guide covers the battery passport under Regulation (EU) 2023/1542. It uses the September 2026 FAQ for batteries to explain how those rules apply to cells, modules and assembled systems. The FAQ is guidance prepared for the Commission and reflects its authors’ views; it does not amend the Regulation. These explanations should not be transferred automatically to toys, vehicles or other product passport regimes.

Start with the finished battery

Article 77 sets out the individual passport requirement for batteries placed on the market or put into service from 18 February 2027. For industrial batteries, the requirement applies to capacities greater than 2 kWh. A battery with a capacity of exactly 2 kWh is not covered by this requirement. Light means of transport (LMT) batteries and electric vehicle batteries need a passport regardless of capacity. Article 77 does not require passports for starting, lighting and ignition (SLI) batteries or portable batteries.

The FAQ describes the relevant battery as a finished product that can function safely and deliver electrical energy. It can contain several cells, modules or packs. For a traction battery, the finished product would normally include the battery management system (BMS) and other components needed for safe operation. The passport requirement applies to the finished battery; its individual components do not automatically need separate passports.

Cells, modules and finished batteries: examples

The energy storage examples in the table concern industrial batteries, to which the 2 kWh threshold applies. This threshold does not apply to LMT or electric vehicle batteries. We developed the numerical examples from the FAQ; the Commission did not publish them in this form.

Situation	Passport requirement
Cells or modules imported for later assembly	Cells and modules intended for assembly normally do not need separate passports. The finished battery will need a passport if it belongs to a category covered by the requirement.
Three packs of 0.9 kWh depend on a shared BMS and together form one safely functioning battery	The packs form one industrial battery with a capacity of 2.7 kWh. One passport is needed for the whole battery.
Three independently functioning industrial batteries of 0.9 kWh are installed at the same site	Each battery has a capacity of 0.9 kWh, so none exceeds the 2 kWh threshold or needs a passport. Their capacities are not added together for this requirement.
An EU battery manufacturer supplies a finished battery that a vehicle manufacturer only installs	If the battery requires a passport, the battery manufacturer is normally responsible for preparing it.
A machine is imported with a finished battery already installed	If the battery belongs to a category covered by the requirement, it needs a passport even when installed in a machine. The importer is normally responsible for it.

Installing several batteries at the same site or in the same cabinet does not make them one battery. A shared monitoring display does not settle the question either. What matters is whether the packs need a common BMS or other shared components to work and together form a finished battery. A wiring diagram, a description of the BMS and documentation of the battery’s operating conditions can support that conclusion.

The FAQ describes an exception for kits that an end user can assemble with commonly available tools. Cells or modules sold in this form may be subject to the passport requirement. Calling a product a “module” therefore does not establish that it is exempt.

Who is responsible for the finished battery’s passport

If an EU company imports components and completes the battery, for example by assembling packs with the necessary BMS, it is responsible when it places that finished battery on the market. The same logic applies when it puts the battery into service without first placing it on the market. Its task is to create the passport for the completed battery, using the relevant data from the component suppliers.

The September FAQ describes an EU battery manufacturer supplying a finished battery to an EU vehicle manufacturer. If the vehicle manufacturer only installs it, responsibility for the passport stays with the battery manufacturer. If it adds a BMS or other components needed to complete the battery, it may become responsible for the passport.

According to the FAQ, the importer is normally responsible for the passport of a finished battery in an imported machine or vehicle. The passport covers the battery. The machine or vehicle may also be subject to other rules, and a battery passport does not replace the documents those rules require. Our importer guide explains how to identify the rules that apply to a product.

Entrusting passport data tasks to a supplier

Article 77(4) allows practical passport tasks to be delegated through written authorisation. That can include a cell supplier, a hosting operator or a manufacturer outside the EU. The responsible economic operator still has to ensure that the battery data is accurate, complete and up to date. The mandate does not automatically turn the authorised supplier into an EU manufacturer or importer.

Preparing the passport data and submitting it to the EU Registry are separate tasks. According to the FAQ, registration is the responsibility of the operator placing the battery on the EU market or putting it into service. An agreement to prepare or store the data does not by itself establish that the contractor may register the passport in its own name. The Registry guide explains the registration rules, including the battery clarifications.

The passport after repair, remanufacturing or repurposing

A simple repair does not require a new battery passport. The relevant information can be updated in the existing passport. A new passport is required after remanufacturing or repurposing. This also applies when a battery has become waste and is prepared for reuse or repurposing. The new passport must be linked to the previous one and identify the new responsible operator.

This rule also applies to older batteries. According to the FAQ, a battery first placed on the EU market before 18 February 2027 can need a passport if it is remanufactured on or after that date and belongs to a category covered by the requirement. Not all data will necessarily be required. If the battery is exempt from a particular requirement, such as carbon footprint reporting, the corresponding information does not have to be included in the passport. The manufacturing date alone does not exempt a remanufactured battery from the passport requirement.

What to document before assigning an identifier

Record what constitutes the finished battery, its category and its capacity. State whether its modules or packs need a common BMS or other shared components. Identify who first places the battery on the market or puts it into service. Include the technical documents supporting these conclusions. Engineering, purchasing and compliance teams will then know which product needs a passport.

Next, choose the individual battery identifier and decide which information about its model and documents from component suppliers to use in the passport. For the dates and required data, see what to prepare before February 2027.

Read Next

• QR codes and labels for a product passport
• Importing products into the EU: DPP responsibilities
• What the EU DPP Registry stores
• Preparing for the battery passport in February 2027

Official Sources

• Batteries Regulation (EU) 2023/1542, Article 77 and Annex XIII
• September 2026 FAQ for battery passports

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Start with the data for one battery. Create an example passport on OriginPass.eu.